American Family Mut. Ins. Co. v. Hadley
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.