and Mr. Sledge.” Officer Smith then observed a third officer run over to the group, and testified the four individuals “went down to the ground in a pile.” In describing Sledge’s actions, Officer Clarke testified that during the encounter Sledge (1) “was yelling, screaming, upset and irate when he was arrested”; (2) made several threats after he was arrested and handcuffed; (3) “wasn’t very cooperative in that he was moving his arms”; and (4) exhibited “resistive angry behavior.” Carriker testified Sledge attempted to get away from the officers twice, and stated “the first time handcuffs were not used,” but “[t]he second time, they were.” On these facts, probable cause existed to believe Sledge was resisting arrest. See State v. Campbell, 260 Neb. 1021, 620 N.W.2d 750, 757 (2001) (<HOLDING>). Thus, even assuming arguendo the detention
holding an arrestee who resists being handcuffed and struggles with officers may be convicted of resisting arrest under nebraska law holding that police seizure of weapon in plain view even though appellant was handcuffed and under the control of the officers was lawful because there were other occupants in the house who were not handcuffed and who would have had access to the weapon holding avoiding arrest is not the same as resisting arrest holding that resisting arrest is lesser offense of assault on an officer holding that an officers noncompliance with the strip search statute was not a defense to resisting an officer with violence