Gem City Bone & Joint v. Meister, 947 N.W.2d 302

Meister, a Nebraska attorney, represented a minor who received surgery from Gem City Bone and Joint in Wyoming; the minor’s father assigned settlement proceeds to Gem City and a billing dispute arose.
Gem City sued Meister and his professional corporation in Wyoming for breach of the assignment; Meister moved to dismiss for lack of jurisdiction (and other grounds), but withdrew some claims; after a hearing with no additional evidence, the Wyoming court denied dismissal and later entered default judgment when defendants did not appear at trial.
Gem City registered the Wyoming judgment in Nebraska under the Nebraska Uniform Enforcement of Foreign Judgments Act (NUEFJA); Meister and his professional corporation challenged registration in Nebraska but the district court allowed registration and Meister did not timely appeal that ruling.
Gem City then sought garnishment against Meister individually; Meister moved to quash the garnishment and to vacate the registered Wyoming judgment, arguing the Wyoming court lacked personal jurisdiction over him (individual) because the relevant acts were by his professional corporation.
The Nebraska district court denied the motions and ordered garnishment of Meister’s bank account; the Nebraska Supreme Court held the denial was a final, appealable order and concluded Wyoming lacked personal jurisdiction over Meister as an individual, vacating the Nebraska garnishment order.

Issue	Gem City’s Argument	Meister’s Argument	Held
Appealability / final order	Orders after NUEFJA registration are not final for appeal; Meister’s challenge was untimely	The district court’s denial of the quash/vacate motion is a post-judgment order affecting a substantial right and is appealable	The denial of Meister’s post-registration motions was a final order under §25-1902(1)(c) because garnishment affected a substantial right, so appeal is timely
Personal jurisdiction over Meister (individual)	Meister had sufficient contacts (assignment, fax/email negotiations, acting in personal & professional capacities) to subject him to Wyoming jurisdiction	Contacts were actions of Meister’s professional corporation; no facts pled or proved to pierce the corporate veil or to attribute corporate acts to Meister personally	Wyoming lacked personal jurisdiction over Meister individually; contacts were corporate and no veil-piercing was shown; the Wyoming judgment is void as to Meister and Nebraska garnishment must be vacated
Preclusion / prior failure to appeal	Prior Nebraska ruling rejecting challenge to registration precludes later collateral attack	Orders in the same proceeding are not successive suits; issue/claim preclusion doesn’t apply and Gem City waived preclusion defense below	Issue and claim preclusion did not bar Meister’s current challenge; successive orders in same case do not trigger those doctrines and Gem City did not raise preclusion below

International Shoe Co. v. Washington, 326 U.S. 310 (1945) (establishes minimum contacts test for personal jurisdiction)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (clarifies purposeful availment and fair play/substantial justice analysis)
Ten Mile Indus. Park v. Western Plains Service, 810 F.2d 1518 (10th Cir. 1987) (corporate acts ordinarily do not subject individual officers to jurisdiction absent veil-piercing)
Newsome v. Gallacher, 722 F.3d 1257 (10th Cir. 2013) (discusses attribution of corporate activities to individuals for jurisdictional purposes)
Miller v. Steichen, 268 Neb. 328 (Neb. 2004) (treatment of default judgments and procedures for obtaining relief)
Simms v. Friel, 302 Neb. 1 (Neb. 2019) (defines "substantial right" and when postjudgment orders are appealable)