Applied Underwriters v. S.E.B. Servs. of New York, 297 Neb. 246

Applied Underwriters, Inc. (Applied) and Applied Risk Services, Inc. (ARS) (Plaintiffs) are Nebraska entities; S.E.B. Services of New York, Inc. and 20th Century Services of New York, Inc. (S.E.B.) are New York corporations.
S.E.B. entered a Reinsurance Participation Agreement (RPA) with Applied Underwriters Captive Risk Assurance Co. (AUCRAC); ARS is identified in the RPA as AUCRAC’s "billing agent."
Applied sued S.E.B. in Nebraska state court on (I) a promissory note (Applied) for $8,144.27 and (II) breach of the RPA (ARS) for $752,926.98.
After suit was filed, the promissory note was paid in full (December 2015). S.E.B. moved to dismiss for lack of personal jurisdiction and on forum non conveniens grounds.
The district court dismissed for lack of personal jurisdiction (and alternatively inconvenient forum). On appeal the Nebraska Supreme Court found the promissory-note claim moot and that neither plaintiff had standing to sue for breach of the RPA, and affirmed dismissal on those grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Count I (promissory note) is moot	Promissory note was unpaid when suit filed, so claim remains justiciable	Note was paid after filing; no live controversy remains	Moot — note was paid; claim dismissed as moot
Whether Applied/ARS have standing to enforce the RPA (Count II)	ARS: as AUCRAC’s billing agent under the RPA, ARS has agency authority to sue; Applied argued it had rights	S.E.B.: Plaintiffs are nonparties to the RPA and lack contractual or agency authority to sue	No standing — Applied admits lack of standing; ARS failed to show agency or express authorization to sue; claim dismissed for lack of subject‑matter jurisdiction
Whether personal jurisdiction/forum non conveniens required decision	Plaintiffs contended Nebraska was appropriate forum and district court erred in dismissing for lack of personal jurisdiction	S.E.B. argued lack of personal jurisdiction and that Nebraska was an inconvenient forum	Court did not reach merits — disposition affirmed on mootness (Count I) and lack of standing (Count II), obviating need to address jurisdictional forum issues

Blakely v. Lancaster County, 284 Neb. 659 (defines mootness and its effect on jurisdiction)
Deutsche Bank Nat. Trust Co. v. Siegel, 279 Neb. 174 (loan servicer standing as trustee’s agent when contract and power of attorney authorize suit)
Field Club v. Zoning Bd. of Appeals of Omaha, 283 Neb. 847 (standing standard at pleading stage)
Greater Omaha Realty Co. v. City of Omaha, 258 Neb. 714 (moot cases generally subject to summary dismissal)
Citizens Opposing Indus. Livestock v. Jefferson County, 274 Neb. 386 (standing is a defect of subject‑matter jurisdiction)