State v. Zitterkopf

Summary

The Nebraska Supreme Court affirmed Zitterkopf’s conviction for unlawful distribution of an intimate image. It held that the statute survives strict scrutiny because it serves a compelling privacy interest and is narrowly tailored, and that the defendant failed to establish substantial overbreadth. The court rejected the ineffective-assistance claim concerning an unmade hearsay objection because no prejudice could be shown, while finding the record insufficient to review the claim concerning omitted defense testimony.