No Appellate Jurisdiction Without a Single Written Judgment Covering All Parties: Commentary on Continental Indemnity Co. v. Starr Indemnity & Liability Co.

No Appellate Jurisdiction Without a Single Written Judgment Covering All Parties:
A Commentary on Continental Indemnity Co. v. Starr Indemnity & Liability Co., 320 Neb. 574 (2025)

I. Introduction

The Nebraska Supreme Court’s decision in Continental Indemnity Co. v. Starr Indemnity & Liability Co., 320 Neb. 574 (Dec. 19, 2025), is a significant reaffirmation—and an important extension—of its recent decision in Elbert v. Keating, O’Gara, 319 Neb. 390, 22 N.W.3d 671 (2025). Together, these cases cement a strict “single judgment document” requirement for appellate jurisdiction in Nebraska civil cases and sharply limit litigants’ ability to manufacture appealability by voluntarily dismissing remaining claims or parties.

The core holding of Continental Indemnity is simple but far-reaching: where a case involves multiple parties (or multiple claims), an appellate court lacks jurisdiction unless the trial court has (1) either certified a partial judgment under Neb. Rev. Stat. § 25‑1315(1), or (2) signed a single written judgment document that states all the relief granted or denied in the action. Separate orders resolving different parties or claims are not enough, and they do not become appealable “by springing” into finality once the last order is entered.

This commentary explains the case’s background, summarizes the Court’s reasoning, examines the precedents and statutes at play, and highlights the practical impact on Nebraska practice. It also unpacks the complex procedural concepts—final judgments, final orders, “rendition” of judgment, and voluntary dismissals—so that the implications for litigants and trial courts are clear.

II. Background and Procedural History

A. The Parties and Claims

The plaintiff, Continental Indemnity Company (Continental), a New Mexico corporation, brought suit in the District Court for Douglas County against two insurance companies:

  • AXIS Surplus Insurance Co. (AXIS); and
  • Starr Indemnity & Liability Co. (Starr).

The complaint asserted causes of action for contribution and indemnity, i.e., claims typically arising among insurers who dispute which carrier ultimately bears responsibility for a loss or payout.

B. The Motions and the September 4, 2024 Orders

Two distinct procedural events framed this litigation:

  1. Starr’s Motion to Dismiss. Starr moved to dismiss for lack of personal jurisdiction under Neb. Ct. R. Pldg. § 6‑1112(b)(2).
  2. AXIS’ Efforts to Set Aside Default. The record did not include the actual default judgment, but AXIS filed a “Special Appearance & Motion to Set Aside Default Judgment,” alleging meritorious defenses and seeking leave to file a motion to dismiss.

On September 4, 2024, the district court entered two separate orders:

  • An order dismissing Starr with prejudice for lack of personal jurisdiction; and
  • An order setting aside the default judgment against AXIS and granting AXIS time to respond.

At this stage, claims against AXIS remained pending; only Starr had been fully dismissed.

C. The First Appeal and Summary Dismissal

Within 30 days of the order dismissing Starr, Continental filed a notice of appeal directed at that order alone. Starr moved for summary dismissal in the Court of Appeals under Neb. Ct. R. App. P. § 2‑107(B)(1). The Court of Appeals summarily dismissed the appeal for lack of jurisdiction, apparently on the ground that the order dismissing Starr was not a final, appealable order because claims against AXIS remained pending.

Continental did not seek further review of that first dismissal.

D. Dismissal of AXIS and the Second Appeal

Following issuance of the Court of Appeals’ mandate, proceedings resumed in the district court. At Continental’s request, the district court:

  • Dismissed Continental’s claims against AXIS without prejudice, with each party to bear its own costs.

Crucially, this order:

  • Did not mention Starr;
  • Did not restate or incorporate the earlier order dismissing Starr; and
  • Did not purport to be a unified final judgment encompassing the whole case.

Continental then filed a second appeal, again seeking to challenge the September 4, 2024 order dismissing Starr. Starr moved for summary dismissal. Initially, the Court of Appeals denied the motion and ordered briefing on jurisdiction.

However, shortly after the Nebraska Supreme Court issued Elbert v. Keating, O’Gara, 319 Neb. 390, 22 N.W.3d 671 (2025), Starr filed a renewed motion for summary dismissal. The Court of Appeals, citing Elbert, held that:

“single, signed written document stating all of relief granted or denied in action is required for judgment; appellate jurisdiction cannot be created through voluntary dismissal of claim without prejudice.”

The Court of Appeals thus dismissed the second appeal for lack of jurisdiction. This time, Continental filed a petition for further review, which the Nebraska Supreme Court granted.

III. Summary of the Opinion

The Nebraska Supreme Court affirmed the Court of Appeals’ dismissal for lack of jurisdiction. It held:

  1. Under Neb. Rev. Stat. § 25‑1301(2), a “judgment rendered” exists only when the trial court signs a single written document stating all of the relief granted or denied in an action.
  2. In a case involving multiple parties or claims, Neb. Rev. Stat. § 25‑1315(1) allows certification of a partial judgment as appealable; absent such certification, no appeal lies from an order adjudicating fewer than all claims against all parties.
  3. Here, the district court:
    • Entered one order dismissing Starr with prejudice; and
    • Later entered a separate order dismissing AXIS without prejudice;
    but never signed a single document combining those rulings into a final judgment, and never certified a partial judgment under § 25‑1315(1).
  4. As a result, no “judgment” had been rendered and no final order existed; the appellate courts therefore lacked jurisdiction.

The Court rejected Continental’s attempts to distinguish Elbert, emphasized that the single‑document requirement applies equally in multi-party cases, and declined to revisit at length the second, independent holding of Elbert—that voluntary dismissal of unresolved claims without prejudice cannot create appellate jurisdiction. Because lack of a “judgment rendered” was dispositive here, the Court invoked the principle that courts need not decide issues unnecessary to resolution of the case.

IV. Analysis

A. The Statutory Framework

1. Appealability and “Judgment Rendered”

Nebraska’s appellate jurisdiction in civil cases is primarily governed by:

  • Neb. Rev. Stat. § 25‑1911 (Reissue 2016) – authorizing appeals from a “judgment or decree rendered” or from a “final order”; and
  • Neb. Rev. Stat. § 25‑1912 (Cum. Supp. 2024) – governing the time and manner of taking appeals.

The critical definition appears in Neb. Rev. Stat. § 25‑1301:

  • § 25‑1301(1): “A judgment is the final determination of the rights of the parties in an action.”
  • § 25‑1301(2): “‘Rendition of a judgment’ is the act of the court, or a judge thereof, in signing a single written document stating all of the relief granted or denied in an action.” (emphasis added)

The Supreme Court makes explicit that, when § 25‑1911 requires a “judgment rendered,” it is referring to this statutory definition of “rendition”: a single, signed judgment document that provides the final determination of all parties’ rights and states all relief granted or denied.

Thus, in Nebraska:

  • Multiple separate orders disposing of different claims or parties do not collectively constitute a “judgment rendered” unless they are consolidated into one signed judgment; and
  • Without such a judgment (or a qualifying final order, discussed below), the clock for filing an appeal does not begin to run, and the appellate court has no jurisdiction.

2. Multiple Parties or Claims and § 25‑1315(1)

Neb. Rev. Stat. § 25‑1315(1) addresses “multiple claims for relief or multiple parties.” It authorizes the trial court, “in its discretion,” to:

  • “direct the entry of a final judgment as to one or more but fewer than all of the claims or parties,”
  • “only upon an express determination that there is no just reason for delay” and an express direction for the entry of judgment.

Absent such certification:

  • Orders adjudicating fewer than all claims or fewer than all parties are not final and remain subject to revision; and
  • No appeal lies until all claims against all parties are resolved and the court has rendered a single judgment, or until a proper § 25‑1315(1) certification is entered.

The Court, citing Mann v. Mann, 312 Neb. 275, 978 N.W.2d 606 (2022), reiterates this core rule: unless § 25‑1315(1) certification occurs, partial adjudications are nonfinal.

3. Final Orders Versus Final Judgments

Nebraska allows appeals both from:

  • Judgments or decrees (as defined by § 25‑1301), and
  • Final orders (a separate statutory category, not elaborated here but generally encompassing certain orders affecting substantial rights in special proceedings or on summary applications after judgment).

In Continental Indemnity, the Court treats the orders at issue as part of a conventional civil action, not as independent “final orders” in a special proceeding. The focus is therefore squarely on whether a judgment has been rendered or whether § 25‑1315(1) certification occurred. The answer to both is “no.”

B. Precedents Cited and Their Influence

1. Elbert v. Keating, O’Gara, 319 Neb. 390, 22 N.W.3d 671 (2025)

Elbert is the centerpiece precedent, and the Supreme Court’s reasoning in Continental Indemnity depends heavily on it.

a. The Facts and Procedural Posture in Elbert

In Elbert, the plaintiff filed two related defamation suits. The appeal before the Supreme Court concerned the second case, in which:

  • The plaintiff sued a law firm and one of its attorneys.
  • The attorney was dismissed by operation of law (nonservice).
  • The law firm filed a counterclaim seeking damages, costs, and attorney fees.
  • The court ultimately dismissed the plaintiff’s complaint for failure to state a claim but did not address the law firm’s counterclaim or its fee request in that dismissal order.

The plaintiff’s initial appeal was dismissed by the Court of Appeals for lack of a final order due to the unresolved counterclaim. Back in the district court, the law firm then voluntarily dismissed its counterclaim without prejudice. The district court entered an order granting that motion, which again did not address other relief in the case.

The plaintiff appealed a second time. The Nebraska Supreme Court dismissed this second appeal for lack of jurisdiction, giving two independent reasons.

b. First Holding in Elbert: No Single Written Judgment Document

The Court emphasized that § 25‑1301(2) requires a single written judgment document stating all relief granted or denied. In Elbert, the district court:

  • Entered one order dismissing the complaint; and
  • Later entered another order voluntarily dismissing the counterclaim;

but never signed a unified judgment document combining those rulings.

The Court explained that the purpose of § 25‑1301(2) is “to add clarity so that the parties know whether and when the court has rendered a judgment from which they must timely file a notice of appeal to protect their right to appellate review.” Because the court had not signed a single document resolving all relief, no judgment had been rendered, and appellate jurisdiction was absent.

c. Second Holding in Elbert: Voluntary Dismissal Without Prejudice Cannot Create Jurisdiction

The parties in Elbert argued that once the law firm voluntarily dismissed its counterclaim without prejudice, no issues remained to be decided; therefore, they claimed, the earlier dismissal of the complaint became appealable. The Supreme Court rejected this reasoning, holding:

  • Appellate jurisdiction cannot be manufactured by voluntarily dismissing unresolved claims without prejudice.
  • It does not matter which party requested the dismissal.
  • The Court adhered to a bright-line rule: where there is no judgment rendered, no § 25‑1315 certification, and no final order, voluntary dismissal of unadjudicated claims without prejudice cannot cure the jurisdictional defect.

Thus, in Elbert, the lack of a single judgment document and the improper attempt to create jurisdiction by voluntary dismissal both independently compelled dismissal of the appeal.

2. Mann v. Mann, 312 Neb. 275, 978 N.W.2d 606 (2022)

Mann is cited to reaffirm the longstanding principle embodied in § 25‑1315(1): in multi-claim or multi-party cases, any order adjudicating fewer than all claims or parties is interlocutory and subject to revision until a final judgment is entered or a proper § 25‑1315 certification is made.

Continental Indemnity builds on Mann by adding the requirement, through § 25‑1301(2) and Elbert, that a final judgment must take the form of a single, signed written document.

3. U.S. Specialty Ins. Co. v. D S Avionics, 320 Neb. 287, 26 N.W.3d 761 (2025)

The Court cites U.S. Specialty solely for a general principle of judicial restraint:

“An appellate court is not obligated to engage in an analysis that is not needed to adjudicate the controversy before it.”

In Continental Indemnity, the Court invokes this principle to avoid re‑analyzing at length the Elbert holding on voluntary dismissals; once it concludes that no judgment was rendered under § 25‑1301(2), further discussion is unnecessary to resolve the case.

C. The Court’s Legal Reasoning in Continental Indemnity

1. The Central Question: Was There a “Judgment Rendered”?

The Supreme Court centers its analysis on whether the district court had rendered a “judgment” under §§ 25‑1301 and 25‑1911. To have appellate jurisdiction, the Court must be reviewing a “judgment or decree rendered” (or a final order). A “judgment rendered” is:

“a final determination of the rights of the parties in an action, which is set forth by the court in a single, signed written document stating all of the relief granted or denied in an action.” (internal quotation summarizing § 25‑1301(1) and (2), as interpreted in Elbert)

In this case:

  • The district court issued one order dismissing Starr with prejudice for lack of personal jurisdiction.
  • Later, it issued another order dismissing Continental’s claims against AXIS without prejudice.
  • Neither order purported to be a unified judgment resolving the entire case.
  • Neither order referenced or incorporated the other, or summarized all the relief granted or denied in the action.

Therefore, under the Elbert framework and § 25‑1301(2), the district court had not yet rendered a judgment. Without such a judgment, the appellate courts lack statutory authority to entertain an appeal.

2. Application of § 25‑1315(1) to Multi-Party, Single-Claim Situations

Continental attempted to distinguish Elbert by arguing that, unlike that case (which involved multiple claims—complaint and counterclaim), this case involved only one type of claim (contribution/indemnity) but against two separate defendants. Continental contended that:

  • The order dismissing Starr was a “judgment” as to Starr because “there was no other claim.”
  • The order dismissing AXIS was a “judgment” as to AXIS because, at that time, no other claim remained.

The Supreme Court rejected this distinction as a “difference without a difference.” It emphasized:

  • Section 25‑1315(1) applies both in cases with multiple claims and cases with multiple parties.
  • If an order “adjudicates fewer than all the claims or the rights and liabilities of fewer than all of the parties,” § 25‑1315(1) applies and the order is nonfinal absent certification.
  • Here, the first order resolved the rights and liabilities of only one defendant (Starr); AXIS remained in the case. No § 25‑1315 certification was obtained. Thus, the first order was interlocutory.
  • The second order resolved Continental’s claims against AXIS but did not restate or incorporate the earlier disposition of Starr. Standing alone, it did not constitute a final judgment for the entire action.

Accordingly, the presence of multiple defendants (rather than multiple claims) does not change the analysis: orders disposing of fewer than all parties are inherently interlocutory unless properly certified, and they do not collectively form a “judgment rendered” absent a single written judgment document.

3. Rejection of the “Springing Final Order” Theory

At oral argument, Continental advanced a “springing” finality theory grounded in § 25‑1315. Its position was, in substance:

  • The September 4 order dismissing Starr was interlocutory when entered.
  • Once the district court later dismissed AXIS, there were no remaining claims or parties to adjudicate.
  • Therefore, Continental argued, the earlier Starr dismissal order effectively “sprang” into finality upon the subsequent dismissal of AXIS, and could then be appealed.

The Supreme Court firmly rejected this construction. It noted:

  • The text of § 25‑1315(1) contains no suggestion that a previously interlocutory order spontaneously becomes a “final judgment” once all other claims or parties are later resolved.
  • Such a reading would conflict with the legislative intent, as understood in Elbert, to provide clarity and a clear, identifiable juncture when a judgment is “rendered.”
  • Under § 25‑1301(2), the event that triggers appealability is the signing of a single written judgment document, not the mere occurrence of a final disposition in fact.

In other words, a series of orders that, taken together, may have disposed of all claims and parties does not automatically generate a “judgment rendered” in Nebraska. Something additional is required: the court must sign a unified judgment document conforming to § 25‑1301(2).

4. Treatment of the Voluntary Dismissal Without Prejudice

Consistent with Elbert, the Court acknowledged a second possible ground to find no jurisdiction: Continental’s voluntary dismissal of AXIS without prejudice could not serve to create appellate jurisdiction over Starr’s earlier dismissal.

However, the Court declined to fully re‑litigate this issue. It stated that it was unnecessary to decide whether the voluntary dismissal rule of Elbert independently barred jurisdiction, because the lack of a “judgment rendered” was already dispositive. Citing U.S. Specialty Ins. Co. v. D S Avionics, the Court reminded that appellate courts need not address issues unnecessary to the outcome.

Still, by quoting and relying on Elbert, and by not disavowing its second holding, the Court effectively leaves the Elbert bright-line rule intact:

  • Voluntarily dismissing unadjudicated claims without prejudice—whether by plaintiff or defendant—cannot create appellate jurisdiction where it does not already exist.

5. Jurisdiction Remains with the District Court

In its concluding points, the Supreme Court underscores an important corollary:

“In the absence of a final judgment or final order, jurisdiction to complete the proceeding by appropriate action remains vested in the district court.”

Because no judgment had been rendered and no final order entered, the district court retained full authority to:

  • Revise or clarify its previous orders; and
  • Enter a proper, single written judgment document that states all the relief granted or denied in the action.

This signals to litigants and trial judges that the solution, when appellate jurisdiction is found wanting, is not to compel the appellate courts to stretch jurisdictional limits, but rather to return to the trial court for entry of an appropriate unified judgment.

D. Impact and Practical Implications

1. For Trial Courts

The combined effect of Elbert and Continental Indemnity is to impose a clear expectation on Nebraska trial courts:

  • When a case involving multiple claims or parties is fully resolved (whether through dismissals, summary judgment, trial, or voluntary dismissals), the court should:
    • Enter a single, signed written judgment that:
    • Lists all claims and all parties; and
    • Specifies all relief granted or denied to each party on each claim.
  • If a court wishes to permit an immediate appeal from a partial resolution while other claims or parties remain, it must:
    • Invoke § 25‑1315(1);
    • Make explicit findings that there is “no just reason for delay”; and
    • Direct the entry of a final judgment as to specific claims or parties in a written judgment that complies with § 25‑1301(2).

The decisions strongly discourage a piecemeal, order-by-order approach without a culminating judgment document. Failure to enter such a judgment risks:

  • Confusion about whether and when an appeal must be filed; and
  • Inevitable jurisdictional dismissals at the appellate level.

2. For Litigants and Counsel

For lawyers, Continental Indemnity carries multiple practice lessons:

  • Do not assume that a dispositive order is appealable simply because it fully resolves one party’s role in the case.
    • If other parties or claims remain and the order is not certified under § 25‑1315, it is interlocutory.
    • It does not become appealable automatically when the remaining aspects of the case are resolved piecemeal in separate orders.
  • Do not rely on voluntary dismissals without prejudice to “clear the decks” for appeal.
    • Elbert and Continental Indemnity together make clear that such tactics cannot create appellate jurisdiction.
    • If a claim is dismissed without prejudice, the case is not truly final as to that claim, reinforcing the interlocutory character of prior orders.
  • Affirmatively seek a single judgment document.
    • Once all claims and parties are resolved—whether by adjudication or with-prejudice dismissals—counsel should consider moving the trial court to enter a single final judgment that:
      • Expressly references all prior dispositive rulings; and
      • Consolidates them into a unified statement of all relief granted or denied.
    • The appeal period under § 25‑1912 will run from the rendition of that unified judgment.
  • Use § 25‑1315(1) strategically.
    • If a critical ruling disposes of one party (e.g., for lack of personal jurisdiction) but the remainder of the case will be lengthy or complex, counsel may:
      • Move the court to certify that ruling as a final judgment under § 25‑1315(1); and
      • Request entry of a compliant single judgment document as to that party.
    • Without certification, counsel must wait for a unified final judgment resolving all parties and claims.

3. For Appellate Courts

The decision reinforces a bright-line, text-based approach to appellate jurisdiction:

  • Appellate courts will look strictly to:
    • Whether a judgment has been “rendered” as defined by § 25‑1301(2);
    • Whether a final order exists; or
    • Whether § 25‑1315(1) certification has occurred.
  • They will not infer jurisdiction from:
    • The practical effect that no issues remain in the trial court; or
    • Parties’ attempts to end-run the rules via voluntary dismissal without prejudice.

This promotes uniformity and reduces fact-intensive disputes over whether a given order is “final enough” for appeal.

4. Potential Future Questions

While the Court’s approach is clear, it invites several practical questions likely to arise in future litigation:

  • Form of the unified judgment. The Court does not prescribe detailed formatting, but it clearly requires:
    • A single written document;
    • Signed by the judge; and
    • Stating all relief granted or denied to all parties.
  • Use of nunc pro tunc judgments. Where multiple separate orders exist, parties may reasonably ask trial courts to enter a unified judgment “nunc pro tunc” summarizing prior rulings. The opinion suggests this would be an appropriate way to cure the absence of a single judgment document, at which point an appeal could proceed.
  • Distinction between dismissals with prejudice and without prejudice. While Elbert expressly focuses on voluntary dismissals without prejudice as insufficient to create jurisdiction, dismissals with prejudice would generally qualify as adjudications for finality purposes—provided they are encompassed within a single judgment document or properly certified under § 25‑1315. Counsel must be precise about the prejudice status of dismissals when strategizing about appeal rights.

V. Complex Concepts Simplified

A. “Judgment,” “Rendition,” and “Final Order”

  • Judgment – The court’s final determination of the rights of the parties in a case.
  • Rendition of judgment – Under § 25‑1301(2), this is the act of the judge signing a single written document that states all the relief granted or denied in the case. This is the crucial moment for appealability.
  • Final order – A separate statutory concept (not central here) that covers certain orders resolving substantial rights in special proceedings or on summary applications after judgment. If an order qualifies as a final order, it may be appealable even if it is not the judgment.

In ordinary multi-party civil actions like Continental Indemnity, appellate courts most often look for a judgment rendered under § 25‑1301(2) or, failing that, a final order specifically authorized by statute.

B. Interlocutory Orders

An interlocutory order is one that does not finally resolve the entire case. Examples include:

  • An order dismissing one defendant while claims against another remain;
  • An order dismissing some claims but not others; or
  • An order resolving liability but not yet addressing damages.

Unless certified under § 25‑1315(1), interlocutory orders are:

  • Not immediately appealable; and
  • Subject to revision by the trial court at any time before final judgment.

C. Section 25‑1315(1) Certification

When there are multiple claims or multiple parties, a trial court can, in narrow circumstances, allow an immediate appeal from a partial disposition by:

  1. Making an express finding that there is “no just reason for delay”; and
  2. Entering a judgment as to one or more, but fewer than all, claims or parties in a written document that complies with § 25‑1301(2).

This is sometimes called a “Rule 54(b)”-style certification (by analogy to the federal rule), and it transforms what would otherwise be a nonfinal order into an appealable judgment. Absent this certification, partial rulings remain nonfinal.

D. Voluntary Dismissal “Without Prejudice”

A claim dismissed “without prejudice” can be refiled; the merits are not finally resolved. In contrast, a dismissal “with prejudice” is a final adjudication that bars refiling.

Elbert (and implicitly Continental Indemnity) holds that:

  • A voluntary dismissal without prejudice of unresolved claims does not transform earlier interlocutory orders into a final judgment for purposes of appeal.
  • Parties cannot “clear out” remaining issues without prejudice just to force earlier rulings into appellate review.

E. “Springing Finality”

“Springing finality” is the notion that an interlocutory order might later become appealable automatically once all remaining aspects of the case happen to be resolved (e.g., when the last defendant is dismissed, even in a separate order). Nebraska rejects this concept:

  • The measuring event for appealability is the rendition of a judgment—a single judgment document—not the mere fact that nothing remains pending.

VI. Conclusion: Key Takeaways and Significance

Continental Indemnity Co. v. Starr Indemnity & Liability Co. solidifies a clear, formalistic, and text-driven framework for appellate jurisdiction in Nebraska civil cases:

  1. A Nebraska appellate court cannot exercise jurisdiction unless:
    • There is a judgment rendered under § 25‑1301(2) (a single, signed written document stating all relief granted or denied in the action); or
    • There is a final order as defined by statute; or
    • A partial judgment has been properly certified as final under § 25‑1315(1).
  2. Separate orders disposing of different parties or claims—even if together they exhaust all matters in the case—do not create a “judgment rendered” unless the court consolidates them into a single judgment document.
  3. In multi-party or multi-claim cases, orders adjudicating fewer than all claims or parties remain interlocutory and nonappealable absent § 25‑1315(1) certification.
  4. Litigants cannot create appellate jurisdiction by voluntarily dismissing remaining claims without prejudice, a doctrine reaffirmed from Elbert.
  5. Until a final judgment or final order exists, the trial court retains jurisdiction to “complete the proceeding by appropriate action,” including entry of a proper unified judgment.

Doctrinally, Continental Indemnity is less about creating new law than about applying—and making unmistakably clear—the implications of Elbert and the § 25‑1301(2) “single-document” requirement in the context of multi-party litigation. Practically, however, it is highly consequential: it instructs trial judges to be deliberate and explicit in how they conclude cases, and it warns litigants that appellate deadlines and rights hinge on the formal rendition of a unified judgment, not merely on the practical exhaustion of claims and parties.

In the broader landscape of Nebraska civil procedure, this case marks another step toward a more regimented, predictable appellate jurisdiction regime—one that emphasizes clarity, written formalities, and bright-line rules over flexible, result-oriented assessments of finality.

Case Details

Year: 2025
Court: Supreme Court of Nebraska

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