Neb. Rev. Stat. » Chapter 28
Nebraska Revised Statutes

Neb. Rev. Stat. § 28-510 (2026)

Consolidation of theft offenses

✓ current as of July 2026
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Conduct denominated theft in sections 28-509 to 28-518 constitutes a single offense embracing the separated offenses heretofore known as larceny, embezzlement, false pretense, extortion, blackmail, fraudulent conversion, receiving stolen property, and the like. An accusation of theft may be supported by evidence that it was committed in any manner that would be theft under sections 28-509 to 28-518, notwithstanding the specification of a different manner in the indictment or information, subject only to the power of the court to insure fair trial by granting a continuance or other appropriate relief where the conduct of the defense would be prejudiced by lack of fair notice or by surprise.

Notes of Decisions
Cited in 24 cases (2 in the last 5 years), 1939–2025 · leading case: State v. Jonusas, 694 N.W.2d 651 (Neb. 2005).
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State v. Jonusas, 694 N.W.2d 651 (Neb. 2005). · cites it 14× “§ 28-510 (Reissue 1995) provides: Conduct denominated theft in [§§] 28-509 to 28-518 constitutes a single offense embracing the separated offenses heretofore known as larceny, embezzlement, false pretense, extortion, blackmail, fraudulent conversion, receiving stolen property,…”
State v. Miner, 733 N.W.2d 891 (Neb. 2007). · cites it 5× “” 24 Although the two offenses are codified separately, §§ 28-511 and 28-517 must be read in conjunction with Neb. Rev. Stat. § 28-510 (Reissue 1995), which provides: Conduct denominated theft in sections 28-509 to 28-518 constitutes a single offense embracing the separated…”
State v. Scott, 403 N.W.2d 351 (Neb. 1987). · cites it 18× “Defendant’s assignments of error may be consolidated for the purpose of this opinion into four: (1) That the trial court erred in failing to hold that Neb. Rev. Stat. §§ 28-510 and 28-512 (Reissue 1985) are unconstitutionally vague; (2) That the court erred in failing to provide…”
State v. Schaaf, 449 N.W.2d 762 (Neb. 1989). · cites it 6× “§ 28-510 (Reissue 1985) of the Nebraska Criminal Code, which provides: "Conduct denominated theft in sections 28-509 to 28-518 constitutes a single offense embracing the separated offenses heretofore known as larceny, embezzlement, false pretense, extortion, blackmail,…”
State v. Ballew, 291 Neb. 577 (Neb. 2015). · cites it 3× “§§ 28-511 and 28-517 (Reissue 2008), constituted a single offense, because Neb. Rev. Stat. § 28-510 (Reissue 2008) specifically provides: “Conduct denominated theft in sections 28-509 to 28-518 constitutes a single offense .”
State v. Copple, 401 N.W.2d 141 (Neb. 1987). · cites it 2× “Also, § 28-511(1) must be read with Neb. Rev. Stat. § 28-510 (Reissue 1985): “Conduct denominated theft in sections 28-509 to 28-518 constitutes a single offense embracing the separated offenses heretofore known as larceny, embezzlement, false pretense, extortion, blackmail,…”
State of Iowa v. Betty Ann Nall, 894 N.W.2d 514 (Iowa 2017). “See Neb. Rev. Stat. Ann. § 28-510 . The statute further provides that “[a]n accusation of theft may be supported by evidence that it was committed in any manner that would be theft under sections 28-509 to 28-518.”
Jones v. State, 493 A.2d 1062 (Md. 1985). · cites it 2× “§ 45-6-301 (1979); Neb. Rev. Stat. § 28-510 (1979); N.H. Rev.”
State v. Fleming, 388 N.W.2d 497 (Neb. 1986). · cites it 4× “Fleming contends the district court erred in (1) failing to find that the evidence was insufficient to sustain a conviction for theft by deception, (2) allowing the State to ask Fleming’s witness whether she had been convicted of writing insufficient-fund checks, and (3)…”
State v. Nuss, 454 N.W.2d 482 (Neb. 1990). · cites it 2× “See Neb. Rev. Stat. § 28-510 (Reissue 1989). Unlike the words “receiving” and “disposing,” the word “retaining” is not defined in Nebraska’s Criminal Code.”
State v. Hert, 224 N.W.2d 188 (Neb. 1974). · cites it 4× “Defendant was charged under the provisions of section 28-510, R. R. S. 1943, with having concealed certain cattle which he knew had been stolen.”
State v. Sievers, 300 Neb. 26 (Neb. 2018). · cites it 2× “See Neb. Rev. Stat. § 28-510 (Reissue 2016). See Neb.”
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