State v. Yzeta, 983 N.W.2d 124

Yzeta, while imprisoned in the custody of the Nebraska Department of Correctional Services (DCS), requested final disposition of pending Hall County untried charges under the intrastate detainer statutes.
The county attorney acknowledged receipt in mid-October 2021; the county court held a preliminary hearing and bound two felony counts over to district court on December 22, 2021.
DCS discharged Yzeta from custody on December 29, 2021 after he completed an unrelated sentence.
The State filed an information in district court January 5, 2022; Yzeta was arraigned January 18 and a jury trial was scheduled for May. On April 22, 2022, Yzeta moved to dismiss under § 29-3805, claiming the 180-day statutory period had expired.
The district court overruled the motion, concluding the intrastate detainer statutes apply only while a defendant is a DCS "committed offender" (i.e., in DCS custody) and alternatively finding a continuance extended the 180-day period. The Nebraska Supreme Court affirmed.

Issue	Plaintiff's Argument (Yzeta)	Defendant's Argument (State)	Held
Whether the intrastate detainer statutes ( §§29-3801–3809 ) continue to apply after DCS discharges a prisoner	Yzeta: statutes still apply because he requested disposition while imprisoned and §29-3805 provides the exclusive remedy; the 180-day clock ran from the county attorney's acknowledgment in Oct. 2021	State: statutes apply only to persons who are imprisoned in a DCS facility; discharge ends the statute's application	The court held the intrastate detainer statutes cease to apply once DCS discharges the person from custody; §29-3805 did not protect Yzeta after Dec. 29, 2021
Whether a continuance extended the 180-day period so dismissal was unwarranted	Yzeta: the 180-day statutory limit expired and dismissal was required	State: continuance(s) tolled/extended the statutory period	Not reached as dispositive: the Supreme Court resolved the appeal by holding the statutes no longer applied after discharge and affirmed the denial of dismissal on that basis

State v. Tucker, 259 Neb. 225, 609 N.W.2d 306 (Neb. 2000) (prior Nebraska interpretation of intrastate detainer statutes)
State v. Kolbjornsen, 295 Neb. 231, 888 N.W.2d 153 (Neb. 2016) (construing intrastate detainer language concerning "committed offender")
State v. LeFever, 30 Neb. App. 562, 970 N.W.2d 792 (Neb. Ct. App. 2022) (Court of Appeals decision applying intrastate detainer rules)
State v. Ebert, 235 Neb. 330, 455 N.W.2d 165 (Neb. 1990) (explaining prisoner-request procedures under intrastate detainer statutes)
Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (constitutional speedy-trial framework)
State ex rel. Haynes v. Bellamy, 747 S.W.2d 189 (Mo. Ct. App. 1988) (UMDDA interpreted to stop applying once prisoner is released)