State ex rel. Seeman v. Lower Republican NRD

319 Neb. 681
CourtNebraska Supreme Court
DecidedAugust 22, 2025
DocketS-24, 326, S-24-327
StatusPublished
Cited by1 cases

This text of 319 Neb. 681 (State ex rel. Seeman v. Lower Republican NRD) 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. Seeman v. Lower Republican NRD, 319 Neb. 681 (Neb. 2025).

Opinion

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

- 681 - Nebraska Supreme Court Advance Sheets 319 Nebraska Reports STATE EX REL. SEEMAN v. LOWER REPUBLICAN NRD Cite as 319 Neb. 681

State ex rel. Steve Seeman, appellee and cross-appellant, v. Lower Republican Natural Resources District et al., appellants and cross-appellees. State ex rel. SBS Farms, Inc., and Robert Bishop, president, appellees and cross-appellants, v. Lower Republican Natural Resources District et al., appellants. ___ N.W.3d ___

Filed August 22, 2025. Nos. S-24-326, S-24-327.

1. Actions: Mandamus. An action for a writ of mandamus is a law action. 2. Judgments: Appeal and Error. In a bench trial of a law action, the trial court’s factual findings have the effect of a jury verdict, and an appellate court will not disturb those findings unless they are clearly erroneous. 3. Judgments: Statutes: Appeal and Error. Questions of law and statu- tory interpretation require an appellate court to reach a conclusion independent of the decision made by the court below. 4. Immunity: Jurisdiction. Sovereign immunity is a jurisdictional matter that can be raised at any time by a party or the court. 5. Mandamus: Public Officers and Employees: Immunity. Immunity does not apply if a mandamus action against a public officer or body is not in effect one against the sovereign. 6. Actions: Public Officers and Employees: Immunity. An action against a public officer to obtain relief from an invalid act or from an abuse of authority by the officer or agent is not a suit against the State and is not prohibited by sovereign immunity. 7. ____: ____: ____. Suits which seek to compel affirmative action on the part of a state official are barred by sovereign immunity, but if a suit simply seeks to restrain the state official from performing affirmative acts, it is not within the rule of immunity. - 682 - Nebraska Supreme Court Advance Sheets 319 Nebraska Reports STATE EX REL. SEEMAN v. LOWER REPUBLICAN NRD Cite as 319 Neb. 681

8. Judgments: Collateral Attack. When a judgment is attacked in a manner other than by a proceeding in the original action to have it vacated, reversed, or modified, or by a proceeding in equity to prevent its enforcement, the attack is a collateral attack. 9. Judgments: Jurisdiction: Collateral Attack. Judgments entered with- out personal jurisdiction or subject matter jurisdiction are void and subject to collateral attack. 10. Mandamus: Words and Phrases. Mandamus is an extraordinary rem- edy, not a writ of right, issued to compel the performance of a purely ministerial act or duty, imposed by law upon an inferior tribunal, cor- poration, board, or person where (1) the relator has a clear right to the relief sought, (2) there is a corresponding clear duty existing on the part of the respondent to perform the act, and (3) there is no other plain and adequate remedy in the course of the law. 11. Mandamus: Proof. In a mandamus action, the party seeking manda- mus 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. 12. Mandamus. An act or duty is ministerial only if there is an absolute duty to perform in a specified manner upon the existence of cer- tain facts. 13. Waters: Corporations: Real Estate: Due Process: Notice. Where a corporation owns real estate having certified irrigated acres under the Nebraska Ground Water Management and Protection Act, due process requires that the corporation be served with notice reasonably calculated to inform it of the subject and issues involved in the proceeding. 14. Statutes. Statutory language is to be given its plain and ordinary meaning. 15. Waters: Real Estate. Under Neb. Rev. Stat. § 46-746(1) (Reissue 2021), a reduction of irrigated acres completed before a person acquires an interest in the real estate is not affected by the acquisition of such interest.

Appeals from the District Court for Harlan County: Terri S. Harder, Judge. Judgment in No. S-24-326 reversed. Judgment in No. S-24-327 affirmed as modified. Donald G. Blankenau and Kennon G. Meyer, of Blankenau, Wilmoth & Jarecke, L.L.P., and Blake E. Johnson, of Bruning Law Group, L.L.C., for appellants. - 683 - Nebraska Supreme Court Advance Sheets 319 Nebraska Reports STATE EX REL. SEEMAN v. LOWER REPUBLICAN NRD Cite as 319 Neb. 681

David A. Domina, of Domina Law Group, P.C., L.L.O., for appellees. Matthew R. Watson and Andrew M. Pope, of Crites, Shaffer, Connealy, Watson, Patras & Watson, P.C., L.L.O., for amicus curiae Nebraska Groundwater Coalition. Michael T. Hilgers, Attorney General, Justin D. Lavene, and Joshua E. Dethlefsen, for amicus curiae Nebraska Department of Natural Resources. Miller-Lerman, Cassel, Papik, and Freudenberg, JJ. Cassel, J. I. INTRODUCTION Two landowners brought mandamus actions to collaterally attack, for lack of jurisdiction, an order of a natural resources district (NRD) reducing certified irrigated acres pursuant to the Nebraska Ground Water Management and Protection Act (Act). 1 One, a corporation, owned real estate when the admin- istrative proceeding commenced. The other owner acquired real estate after it ended. The district court granted both relief. Because the administrative record failed to establish reasonable notice to the corporation, we affirm its judgment as modified. We reverse the other judgment, because the NRD established jurisdiction over that owner’s predecessor in title. II. BACKGROUND To better comprehend the underlying events resulting in forfeiture of certified irrigated acres and then this action for a writ of mandamus, it is important to understand the regu- lation of ground water in Nebraska. We start there—briefly addressing the Republican River Compact before summa- rizing Nebraska’s statutory framework and the rules and regulations of the local governing body. Then we discuss the 1 Neb. Rev. Stat. §§ 46-701 to 46-756 (Reissue 2021). - 684 - Nebraska Supreme Court Advance Sheets 319 Nebraska Reports STATE EX REL. SEEMAN v. LOWER REPUBLICAN NRD Cite as 319 Neb. 681

proceedings leading to a cease-and-desist order and the two actions seeking writs of mandamus.

1. Republican River Compact To provide for equitable division and the most efficient use of the Republican River Basin’s waters, the states of Colorado, Kansas, and Nebraska signed the Republican River Compact of 1943 (Compact). 2 The Compact made specific alloca- tions of water to each state for beneficial consumptive use. 3 Subsequently, Nebraska’s increased pumping of ground water led to litigation before the U.S. Supreme Court. 4 A settlement sought to accurately measure the supply and use of the water in the basin and to help the states stay within their allocations. 5 There seems to be no dispute that the certified acres at issue here relate to lands included in the Compact.

2. Nebraska Ground Water Management and Protection Act The Act originated in 1975. 6 The Legislature found that “ownership of water is held by the state for the benefit of its citizens.” 7 The Legislature proclaimed that “[e]very landowner shall be entitled to a reasonable and beneficial use of the ground water underlying his or her land.” 8 But it made such use “sub- ject to the provisions of . . . the . . . Act and the correlative rights of other landowners when the ground water supply is 2 2A Neb. Rev. Stat. appx. § 1-106 (Reissue 2016). 3 Id., art. IV. 4 See Kansas v. Nebraska, 574 U.S. 445, 135 S. Ct. 1042, 191 L. Ed. 2d 1 (2015). 5 See id. 6 See 1975 Neb. Laws, L.B.

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State ex rel. Seeman v. Lower Republican NRD
319 Neb. 681 (Nebraska Supreme Court, 2025)

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Bluebook (online)
319 Neb. 681, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-seeman-v-lower-republican-nrd-neb-2025.