State ex rel. Douglas Cty. Sch. Dist. No. 66 v. Ewing

319 Neb. 663
CourtNebraska Supreme Court
DecidedAugust 22, 2025
DocketS-24-192
StatusPublished

This text of 319 Neb. 663 (State ex rel. Douglas Cty. Sch. Dist. No. 66 v. Ewing) is published on Counsel Stack Legal Research, covering Nebraska Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State ex rel. Douglas Cty. Sch. Dist. No. 66 v. Ewing, 319 Neb. 663 (Neb. 2025).

Opinion

Nebraska Supreme Court Online Library www.nebraska.gov/apps-courts-epub/ 08/22/2025 09:13 AM CDT

- 663 - Nebraska Supreme Court Advance Sheets 319 Nebraska Reports STATE EX REL. DOUGLAS CTY. SCH. DIST. NO. 66 v. EWING Cite as 319 Neb. 663

State of Nebraska ex rel. Douglas County School District No. 66, also known as Westside Community School District, appellant, v. John Ewing, in his official capacity as county treasurer of Douglas County, Nebraska, appellee, and Douglas County School District No. 0001, also known as Omaha Public schools, intervenor-appellee. ___ N.W.3d ___

Filed August 22, 2025. No. S-24-192.

1. Motions to Vacate: Time: Appeal and Error. The decision to vacate an order any time during the term in which the judgment is rendered is within the discretion of the court; such a decision will be reversed only if it is shown that the district court abused its discretion. 2. Judgments: Words and Phrases. An abuse of discretion occurs when a trial court’s decision is based upon reasons that are untenable or unreasonable or if its action is clearly against justice or conscience, reason, and evidence. 3. Constitutional Law: Courts. The construction of the Nebraska Constitution is a judicial function, and the Nebraska Constitution is interpreted as a matter of law. 4. Statutes: Appeal and Error. Statutory interpretation is a question of law that an appellate court resolves independently of the trial court. 5. Contracts: Appeal and Error. The construction of a contract is a matter of law, in connection with which an appellate court has an obli- gation to reach an independent, correct conclusion irrespective of the determinations made by the court below. 6. Mandamus: Words and Phrases. Mandamus is a law action and rep- resents an extraordinary remedy, not a writ of right. 7. Mandamus. Whether to grant a writ of mandamus is within a court’s discretion. 8. Mandamus: Proof. Mandamus relief is available if the movant can show (1) a clear right to the relief sought, (2) a corresponding clear - 664 - Nebraska Supreme Court Advance Sheets 319 Nebraska Reports STATE EX REL. DOUGLAS CTY. SCH. DIST. NO. 66 v. EWING Cite as 319 Neb. 663

duty to perform the act requested, and (3) no other plain and adequate remedy is available in the ordinary course of law. 9. ____: ____. In a mandamus action, the party seeking mandamus has the burden of proof and must show clearly and conclusively that such party is entitled to the particular thing the relator asks and that the respondent is legally obligated to act. 10. Mandamus: Public Officers and Employees. Mandamus is available to enforce the performance of ministerial duties of a public official but is not available if the duties are quasi-judicial or discretionary. 11. ____: ____. A duty imposed by law which may be enforced by writ of mandamus must be one which the law specifically enjoins as a duty resulting from an office, trust, or station. 12. Mandamus. The general rule is that an act or duty is ministerial only if there is an absolute duty to perform in a specified manner upon the existence of certain facts. 13. ____. A duty or act is ministerial when there is no room for the exer- cise of discretion, official or otherwise, the performance being required by direct and positive command of the law. 14. Public Officers and Employees. A ministerial duty is not dependent upon a public officer’s judgment or discretion—it is performed under the conditions specified in obedience to the mandate of legal author- ity, without regard for the exercise of the officer’s judgment upon the propriety of the act being done.

Appeal from the District Court for Douglas County: Katie L. Benson, Judge. Affirmed in part, and in part reversed and remanded with direction. Michael F. Coyle, Michael B. Duffy, and Sarah L. McGill, of Fraser Stryker, P.C., L.L.O., for appellant. Donald W. Kleine, Douglas County Attorney, Dana N. Livingston, and Jimmie L. Pinkham III, for appellee. Megan S. Wright, Trenten P. Bausch, and Kimberly A. Duggan, of Cline, Williams, Wright, Johnson & Oldfather, L.L.P., for intervenor-appellee. Funke, C.J., Miller-Lerman, Cassel, Stacy, and Freudenberg, JJ. - 665 - Nebraska Supreme Court Advance Sheets 319 Nebraska Reports STATE EX REL. DOUGLAS CTY. SCH. DIST. NO. 66 v. EWING Cite as 319 Neb. 663

Funke, C.J. I. INTRODUCTION Under the Nebraska Constitution and subsequently enacted statutes, payments in lieu of taxes (PILOT funds) are to be distributed by county treasurers to eligible entities in accord­ ance with a specified formula. This case raises the question of whether an eligible entity may obtain a writ of mandamus directing a county treasurer to properly distribute PILOT funds. For the reasons set forth below, we conclude that the relevant constitutional and statutory provisions create such a ministerial duty. Because all other prerequisites for a writ of mandamus are met, we further conclude that the district court, although properly vacating the first writ of mandamus, erred in denying the renewed motion for a writ and, therefore, abused its discre- tion in dismissing the case with prejudice. As such, we affirm in part, and in part reverse and remand with direction for the district court to enter an alternative writ of mandamus directing the treasurer to show cause why a peremptory writ should not be issued requiring the treasurer to pay the eligible entity the amounts it was entitled to receive by law. II. BACKGROUND 1. Westside Underpaid Under article VIII, § 11, of the Nebraska Constitution, and subsequently enacted Neb. Rev. Stat. §§ 70-651.01 through 70-651.05 (Reissue 2018), Douglas County School District No. 66, also known as Westside Community School District (Westside), was entitled to receive PILOT fund distributions from John Ewing, in his official capacity as the county trea- surer of Douglas County, Nebraska (treasurer). In May 2022, however, Nebraska’s Auditor of Public Accounts issued a report showing that in 2021, the treasurer erroneously distributed the PILOT funds in such a manner that certain entities were overpaid, and certain entities were underpaid. Specific to this case, the report indicated that Westside had been underpaid by millions of dollars, while - 666 - Nebraska Supreme Court Advance Sheets 319 Nebraska Reports STATE EX REL. DOUGLAS CTY. SCH. DIST. NO. 66 v. EWING Cite as 319 Neb. 663

Douglas County School District No. 0001, also known as Omaha Public Schools (OPS); Douglas County; and the city of Omaha were overpaid by similarly large amounts. Although our record reflects differing amounts for the payment errors at issue, the precise amounts are immaterial to the issues before us. The report also stated it was likely that such errors had occurred in previous years, although there was no further discussion on this point. The auditor “recommend[ed] the [treasurer] correct the erroneous distributions.” None of the parties dispute that Westside was underpaid, that other entities were overpaid, and that the underpay- ments and overpayments constituted error on the part of the treasurer. In light of the underpayment, Westside filed suit against the treasurer, seeking an alternative and peremptory writ of manda- mus directing the treasurer to correct the errors. 2. Settlement Agreement After the litigation began, Westside, the treasurer (reflected in the agreement as “Douglas County”), and the city of Omaha were parties to a settlement agreement intending to rectify underpayments and overpayments from 2019, 2020, and 2021. OPS declined to participate in the settlement agreement. The settlement agreement provided that “Douglas County” and the city of Omaha would make six equal payments to Westside over the span of 6 years, starting in 2024 and ending in 2029, totaling the amount they had been overpaid.

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Cite This Page — Counsel Stack

Bluebook (online)
319 Neb. 663, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-douglas-cty-sch-dist-no-66-v-ewing-neb-2025.