Dunham v. Dunham Consolidated Cases - Parental Rights Appeal
Summary
The Nebraska Court of Appeals issued a consolidated opinion in Dunham v. Dunham addressing multiple parental rights appeals, clarifying standards for what constitutes a final appealable order in termination of parental rights proceedings. The court examined whether various trial court determinations met the threshold for appellate review under Nebraska law, addressing the legal requirements for final orders that trigger appeal rights.
Attorneys handling parental rights termination cases in Nebraska juvenile courts should ensure that any appeal is taken from a proper final order as defined by the court — the jurisdictional defect arising from attempting to appeal a non-final order cannot be cured by filing from a separate related decree. Juvenile court practitioners should review pending matters to confirm finality before filing notices of appeal.
What changed
The Nebraska Court of Appeals issued a consolidated decision addressing multiple parental rights termination appeals. The court clarified that for an appellate court to obtain jurisdiction over a parental rights termination case, the trial court must issue a final order from which appeal lies — determining that while an appeal from a final decree in a separate case may be timely, the appellate court lacks jurisdiction over the parental rights matter itself without a proper final order.
Parties involved in parental rights termination proceedings and their counsel should note that appellate jurisdiction in Nebraska juvenile courts depends on the entry of a final order as defined by statute and case law. The court's analysis provides guidance on what constitutes a final order in the context of parental rights termination, which may affect trial strategy and the timing of appellate filings in similar cases.
Archived snapshot
Apr 21, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
Nebraska Supreme Court Online Library www.nebraska.gov/apps-courts-epub/ 04/21/2026 04:12 PM CDT
___ N.W.3d ___
Parental Rights: Judgments: Appeal and Error.-
Evidence: Appeal and Error.
Jurisdiction: Appeal and Error.
Jurisdiction: Final Orders: Appeal and Error.
Final Orders: Appeal and Error.
Juvenile Courts: Appeal and Error. Final Orders: Words and Phrases. Final Orders. Final Orders: Appeal and Error. Parental Rights: Proof. Parental Rights. Parental Rights: Words and Phrases. -
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- - Benjamin S. v. Crystal S. Id. Kellogg v. Mathiesen In re Interest of Johnny H.
In re Interest of Ricardo T. et al. - Christine W. v. Trevor W. - Khaitov
- Greater Omaha Packing Co.
- (i) File Stamps on Notices of Appeal -
(ii) Final, Appealable Order? - - In re Interest of Manuel C. & Mateo S. modified on denial of rehearing In re Interest of Isabel P. et al. - In re Interest of Johnny H. - Id. Id. In re Interest of
Manuel C. & Mateo S., supra In re Interest of Isabel P. et al., supra In re Interest of Joseph S. et al. reversed on other grounds
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running of the time for filing a notice of appeal shall be terminated as to all parties by a timely motion to alter or amend a judgment
id.
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- Benjamin S. v. Crystal S. - Benjamin S. v. Crystal S., supra. Id. Id. id. Kitsmiller v. Kitsmiller
Id. - - Benjamin S. v. Crystal S., supra- - and Kitsmiller v. Kitsmiller, supra - - - -
Kitsmiller v. Kitsmiller, supra - - -
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- - - Kitsmiller v. Kitsmiller - - Benjamin S. v. Crystal S.
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