Salguero-Arriaza v. Navarijo-Davila

Nebraska Court of Appeals·Decided September 8, 2026·No. A-25-948·Published

Opinion

Nebraska Supreme Court Online Library www.nebraska.gov/apps-courts-epub/ 09/08/2026 08:08 AM CDT

- 455 -

Nebraska Court of Appeals Advance Sheets 34 Nebraska Appellate Reports SALGUERO-ARRIAZA v. NAVARIJO-DAVILA Cite as 34 Neb. App. 455

Claudina Salguero-Arriaza, appellant, v.

Juan V. Navarijo-Davila, appellee.

___ N.W.3d ___

Filed September 8, 2026. No. A-25-948.

1. Statutes. Statutory interpretation presents a question of law. 2. Judgments: Appeal and Error. An appellate court independently reviews questions of law decided by a lower court. 3. Federal Acts: Minors: Appeal and Error. An appellate court, when reviewing a trial court’s special immigration juvenile determinations, applies the same standard of review ordinarily applied to judicial determinations in the type of action or proceeding in which the determinations were requested.

4. Federal Acts: Minors. Under 8 U.S.C. § 1101(a)(27)(J) (2018) of the federal Immigration and Nationality Act, special immigrant juvenile status provides certain immigrant children the ability to seek lawful permanent residence in the United States. 5. Jurisdiction: Minors: Child Custody. In Nebraska, a court with jurisdiction to determine custody of a child has jurisdiction to make special immigrant juvenile status determinations regarding such child. 6. Courts: Minors. The role of state courts in the special immigrant juvenile status determination is to make the findings of fact necessary to the U.S. Citizenship and Immigration Service’s legal determination of the immigrant child’s entitlement to special immigrant juvenile status. 7. Jurisdiction: Minors: Child Custody: Evidence. Pursuant to Neb.

Rev. Stat. § 43-1238(b) (Cum. Supp. 2024), if the preponderance of the evidence supports making the requested special immigrant juvenile status findings, a Nebraska court exercising jurisdiction over an initial child custody proceeding shall issue an order including them. 8. Paternity: Minors: Appeal and Error. In a filiation proceeding in which special immigrant juvenile findings are requested, an appellate court reviews for an abuse of discretion.

Nebraska Court of Appeals Advance Sheets 34 Nebraska Appellate Reports SALGUERO-ARRIAZA v. NAVARIJO-DAVILA Cite as 34 Neb. App. 455

9. Judges: Words and Phrases. A judicial abuse of discretion exists if the reasons or rulings of a trial judge are clearly untenable, unfairly depriving a litigant of a substantial right and denying just results in matters submitted for disposition.

10. Courts: Minors: Evidence. Courts requested to make special immigrant juvenile status decisions are required to either make the requested special findings or find that the evidence was not credible or insufficient to do so.

11. Courts: Minors: Child Custody: Evidence. In making a best interests determination for purposes of determining special immigrant juvenile status, a court should consider the best interests factors routinely considered in making custody and removal determinations to the extent evidence of such factors is present in the record.

Appeal from the District Court for Douglas County: Peter C. Bataillon, Judge. Affirmed in part, and in part vacated and remanded with directions.

Tyler D. McIntosh, of Roth Weinstein, L.L.C., for appellant. No appearance for appellee. Riedmann, Chief Judge, and Pirtle and Piccolo, Judges. Riedmann, Chief Judge.

I. INTRODUCTION

Claudina Salguero-Arriaza (Claudina) filed a complaint against Juan V. Navarijo-Davila (Juan) to establish paternity and custody of her two minor children in the district court for Douglas County. In the course of the proceedings, she also requested the court make specific factual findings under Neb. Rev. Stat. § 43-1238(b) (Cum. Supp. 2024) that would allow the children to petition the federal government for special immigrant juvenile (SIJ) status.

Following evidentiary hearings, the district court entered an order that established Juan’s paternity and awarded Claudina sole physical and legal custody of the two children. The court also entered a separate order concerning the requested SIJ findings. This order is the subject of Claudina’s appeal. For

Nebraska Court of Appeals Advance Sheets 34 Nebraska Appellate Reports SALGUERO-ARRIAZA v. NAVARIJO-DAVILA Cite as 34 Neb. App. 455

the foregoing reasons, we affirm in part, and in part vacate and remand with directions.

II. BACKGROUND

Claudina and Juan were unmarried and living in Guatemala when their two children were born, one in August 2008 and the other in December 2015. Claudina and Juan’s relationship ended in 2017, and she and the children moved from Guatemala to the United States sometime in 2019.

Claudina filed her complaint to establish paternity and custody in the district court in February 2025. The complaint alleged, in relevant part, that Juan had physically abused both Claudina and the older child; that Juan had abandoned the familial home in Guatemala in 2017 and had not had any “verbal contact” with the children since 2022; that reunification of the children with Juan was not possible because of his abuse, neglect, and “constructive abandonment”; and that it was not in the children’s best interests to return to Guatemala because of such abuse, neglect, and constructive abandonment.

Claudina filed a motion requesting that the court allow her to serve Juan by substitute service because service could “not be made with reasonable diligence by any other method provided by statute.” Her counsel submitted an affidavit with the motion that stated efforts to obtain Juan’s address had failed and his whereabouts could not be verified despite diligent search and inquiry. However, counsel had been able to find a “Facebook” profile belonging to an individual with the same name as Juan. The court granted Claudina’s motion and ordered that she give Juan notice by publication and send notice through Facebook as well. The record shows that Claudina complied with the statutory requirements of notice by publication and that notice was sent to this Facebook profile.

After Juan failed to enter an appearance, Claudina filed a motion for a “default hearing.” Hearings were held on July 2 and 23, 2025, and Claudina testified to the following.

Nebraska Court of Appeals Advance Sheets 34 Nebraska Appellate Reports SALGUERO-ARRIAZA v. NAVARIJO-DAVILA Cite as 34 Neb. App. 455

Claudina, Juan, and the two children lived together in Guatemala in the home of Juan’s parents. Starting around 2013, Juan began physically and verbally abusing Claudina, and he did so several times in front of the children. On one occasion, her older child attempted to intervene, and Juan hit the child “[a]bout three times” to the point of leaving “a mark.” Claudina once reported Juan’s abuse to the police, but the police never came, which she testified was “customary” in Guatemala.

In 2017, Juan left the familial home to pursue a relationship with another woman. Claudina did not know where he went and did not have any contact with him after he left, although he did provide her with monthly payments by giving them to his mother, who then gave them to Claudina. However, after about 6 months, Claudina and the minor children moved from Juan’s parents’ home because she was afraid Juan would return, it was uncomfortable living with them, and she did not feel she had their support. Claudina denied that Juan’s parents helped care for her or the children.

Claudina and the children moved into a house that was “about two streets” away. Claudina did not know if Juan knew where she and the children had moved after she left his parents’ home. When Claudina and the children moved into their own home, Juan stopped making payments. Claudina did not know why Juan stopped sending money, but he had not provided for the children since that time. Claudina also had not spoken to Juan since he left the family home in 2017. In fact, both Juan and his parents had blocked Claudina from contacting them through the messaging application they had previously used to communicate.

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Salguero-Arriaza v. Navarijo-Davila, (Neb. Ct. App. 2026).

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