In American Family Mut. Ins. Co. v. Hadley, 264 Neb. 435, 648 N.W.2d 769 (Neb 2002), the Nebraska Supreme Court addressed the issue in the context of a conviction for negligent child abuse. 648 N.W.2d at 774. Despite the lack of intent under the negligent child abuse statute NebRevStat 28-707(3), that court held the use of the phrase "any criminal conviction" in an identical exclusion was not ambiguous and did include both negligent and intentional criminal convictions. Id. at 778.