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

Applied Underwriters, Inc. (Applied) and Applied Risk Services, Inc. (ARS) are Nebraska entities; S.E.B. Services of New York, Inc. (S.E.B.) is a New York corporation providing security services.
S.E.B. entered into a Reinsurance Participation Agreement (RPA) with AUCRAC (an Applied-related captive), and the signed RPA (attached to the complaint) named ARS as AUCRAC’s "billing agent."
S.E.B. fell behind on premiums; its president executed a promissory note in Applied’s favor for $42,362.59, which was fully paid on December 22, 2015.
Applied/ARS sued S.E.B. in Douglas County, Nebraska: Count I alleged breach of the promissory note (seeking $8,144.27); Count II alleged S.E.B. breached the RPA (seeking ~$752,927).
S.E.B. moved to dismiss for lack of personal jurisdiction and forum non conveniens; the district court dismissed for lack of personal jurisdiction and as an alternative found Nebraska an inconvenient forum.
On appeal the Nebraska Supreme Court ordered supplemental briefing on two jurisdictional issues: mootness of Count I (due to repayment) and standing of Applied/ARS to assert Count II (neither being a party to the RPA).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness of Count I (promissory note)	Note unpaid when filed; claim live	Note was paid after filing so claim is moot	Count I is moot; dismissal affirmed on that basis
Standing of Applied to sue for breach of RPA	Applied asserted injury via its role in AUCRAC-related programs	Applied is not a party/agent to RPA, so lacks rights under it	Applied lacks standing to bring Count II
Standing of ARS to sue for breach of RPA	ARS contends its designation as AUCRAC’s "billing agent" gives it authority/agency to enforce RPA	RPA does not grant ARS authority or power of attorney to sue; RPA limits enforcement to AUCRAC and affiliates	ARS has not shown an agency relationship or authorization to sue; lacks standing
Appropriate basis for dismissal	Plaintiffs argued district court erred re: long-arm statute, forum selection, and convenience	Defendants argued lack of personal jurisdiction and moved to dismiss; also raised subject-matter issues	Supreme Court affirmed dismissal but on grounds of mootness (Count I) and lack of standing (Count II), not the district court’s personal-jurisdiction rationale

Deutsche Bank Nat. Trust Co. v. Siegel, 279 Neb. 174 (loan servicer had standing as agent where contract and power of attorney authorized suit)
Blakely v. Lancaster County, 284 Neb. 659 (mootness doctrine and summary dismissal guidance)
Field Club v. Zoning Bd. of Appeals of Omaha, 283 Neb. 847 (standing standards at pleading stage)
In re Interest of Meridian H., 281 Neb. 465 (standing requires legal or equitable interest)