In re Interest of Nowa K.

33 Neb. Ct. App. 446, 33 Neb. 446
CourtNebraska Court of Appeals
DecidedFebruary 11, 2025
DocketA-24-305 through A-24-307
StatusUnpublished

This text of 33 Neb. Ct. App. 446 (In re Interest of Nowa K.) is published on Counsel Stack Legal Research, covering Nebraska Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Interest of Nowa K., 33 Neb. Ct. App. 446, 33 Neb. 446 (Neb. Ct. App. 2025).

Opinion

- 446 - Nebraska Court of Appeals Advance Sheets 33 Nebraska Appellate Reports IN RE INTEREST OF NOWA K. Cite as 33 Neb. App. 446

In re Interest of Nowa K., a child under 18 years of age. State of Nebraska, appellee, v. Nowa K., appellant. ___ N.W.3d ___

Filed February 11, 2025. No. A-24-305 through A-24-307.

1. Juvenile Courts: Appeal and Error. An appellate court reviews juve- nile cases de novo on the record and reaches its conclusions indepen- dently of the juvenile court’s findings. 2. Juvenile Courts: Probation and Parole: Pleadings. Neb. Rev. Stat. § 43-286(5) (Cum. Supp. 2024) authorizes a juvenile court to change an existing disposition of probation, but its power to do so is premised upon the existence of an appropriate motion and upon its compliance with the specified procedures. 3. Juvenile Courts. Neb. Rev. Stat. § 43-286(6) (Cum. Supp. 2024) restricts a juvenile court’s ability to change a juvenile’s disposition. 4. Constitutional Law: Due Process. Generally, procedural due process requires parties whose rights are to be affected by a proceeding to be given timely notice, which is reasonably calculated to inform the person concerning the subject and issues involved in the proceeding; a reason- able opportunity to refute or defend against a charge or accusation; a reasonable opportunity to confront and cross-examine adverse witnesses and present evidence on the charge or accusation; representation by counsel, when such representation is required by constitution or statute; and a hearing before an impartial decisionmaker.

Appeal from the Separate Juvenile Court of Douglas County: Mary M.Z. Stevens, Judge. Reversed and remanded with directions. Christine D. Henningsen for appellant. - 447 - Nebraska Court of Appeals Advance Sheets 33 Nebraska Appellate Reports IN RE INTEREST OF NOWA K. Cite as 33 Neb. App. 446

Laura E. Lemoine, Deputy Douglas County Attorney, and Trenton Hoeft, Senior Certified Law Student, for appellee. Riedmann, Chief Judge, and Pirtle and Arterburn, Judges. Riedmann, Chief Judge. INTRODUCTION Nowa K. appeals from the order of the separate juve- nile court of Douglas County that terminated his probation unsatisfactorily, ordered that his record remain unsealed, and terminated the jurisdiction of the juvenile court. Because the procedure utilized by the juvenile court was unauthorized and violated Nowa’s due process rights, we reverse the judgment of the juvenile court and remand the cause with directions. BACKGROUND Nowa, born in July 2006, was involved in three separate cases before the juvenile court. The first two cases at issue are those in case Nos. A-24-305 and A-24-306. Both originated in the separate juvenile court of Douglas County in December 2018. In both cases, Nowa was adjudicated under Neb. Rev. Stat. § 43-247(1) (Reissue 2016). He was placed on an open- ended term of probation in February 2020. In April 2023, this was changed to “administrative probation.” The third case involved in this appeal, case No. A-24-307, began in the sepa- rate juvenile court of Lancaster County in December 2020. In October 2021, Nowa was adjudicated in that case under § 43-247(2). That same month, the case was transferred to the separate juvenile court of Douglas County. A February 2024 “Continuance Order” was filed in all three cases. It noted that Nowa and the State each offered one exhibit that was received into evidence. Referencing the State’s exhibit, the order stated that Nowa entered a plea of no contest to one count of robbery, a Class II felony, and one count of theft by unlawful taking, $5,000 or more, a Class IIA felony, both in Douglas County District Court, and that the matter was set for sentencing on July 11. - 448 - Nebraska Court of Appeals Advance Sheets 33 Nebraska Appellate Reports IN RE INTEREST OF NOWA K. Cite as 33 Neb. App. 446

At a hearing on March 22, 2024, on Nowa’s motion to add an authorized visitor, the State made an oral motion to termi- nate the jurisdiction of the juvenile court in all three cases. The State noted that Nowa had pled to serious charges in the district court, Nowa had counsel in that case, and there was not a need “to keep coming into juvenile court when he is now in an adult situation and he’s obviously facing some pretty sig- nificant sentence[s].” The State specified that it was not alleg- ing a violation of probation or asking to terminate probation; it was asking only to terminate the jurisdiction of the juvenile court. The State offered no evidence in support of its motion. Nowa and his guardian ad litem objected to the motion. Following the hearing, the juvenile court entered an order in all three cases finding that Nowa did not satisfactorily com- plete probation, terminating his probation as unsatisfactorily completed, ordering that his record remain unsealed at that time, and terminating the jurisdiction of the juvenile court. Nowa appeals. ASSIGNMENTS OF ERROR Nowa assigns that the juvenile court erred in overruling his objection to the State’s motion to terminate jurisdiction that did not comport with the basic tenants of due process, erred in terminating his probation unsatisfactorily, and erred in ter- minating jurisdiction over him and ordering that his records not be sealed. STANDARD OF REVIEW [1] An appellate court reviews juvenile cases de novo on the record and reaches its conclusions independently of the juvenile court’s findings. In re Interest of Gunner B., 312 Neb. 697, 980 N.W.2d 863 (2022). ANALYSIS Nowa’s assignments of error all relate to a March 27, 2024, order issued by the juvenile court following a hearing on his motion to add an authorized visitor, which he withdrew at the - 449 - Nebraska Court of Appeals Advance Sheets 33 Nebraska Appellate Reports IN RE INTEREST OF NOWA K. Cite as 33 Neb. App. 446

hearing. After the juvenile court recognized that the motion was withdrawn, the State orally moved that the juvenile court terminate its jurisdiction based upon Nowa’s no contest plea “to some very serious charges in District Court” of which “the Court is very well aware.” However, no testimony was adduced, no exhibits were offered, and the juvenile court was not asked to take judicial notice of any pleadings. Our record consists only of arguments made by counsel at the hearing. [2] Following the hearing, the juvenile court issued an order terminating Nowa’s probation as unsatisfactorily completed, terminating its jurisdiction over him, and ordering that his records not be sealed. Although we note the State specifically argued that it was not seeking a revocation of Nowa’s proba- tion, the court’s order terminating Nowa’s probation as unsat- isfactorily completed did just that, resulting in Nowa’s record not being sealed. See Neb. Rev. Stat. § 43-286.01(10) (Cum. Supp. 2024) (providing juvenile’s record be sealed upon suc- cessful completion of probation). Prior to a revocation of a juvenile’s probation, however, certain statutory procedures must be followed to protect a juvenile’s procedural rights. Neb. Rev. Stat. § 43-286(5) (Cum. Supp. 2024) authorizes a juvenile court to change an existing disposition of probation, but its power to do so is premised upon the existence of an appropriate motion and upon its compliance with the speci- fied procedures. In re Interest of Josue G., 299 Neb.

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Bluebook (online)
33 Neb. Ct. App. 446, 33 Neb. 446, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-interest-of-nowa-k-nebctapp-2025.