In re Interest of Becka P, 298 Neb. 98

Parents Robert P. and Veronica M. have three children (Becka, Thomas, and Robert Jr.); prior neglect allegations were investigated and largely unfounded, but multiple citations existed for failure to use child safety restraints.
In Dec. 2015 the State filed juvenile petitions; the children were adjudicated (adjudication later affirmed on appeal by Court of Appeals).
While some appellate matters were pending, the juvenile court appointed an educational surrogate and later held a dispositional hearing on DHHS’s court report recommending family preservation and return of custody to the parents.
The juvenile court rejected DHHS’s recommendation and ordered that custody remain with DHHS, plus specific directives including that DHHS confirm and, if necessary, update the children’s immunizations (with DHHS to pay if parents/insurance could not).
Parents appealed only the authority of the juvenile court to order DHHS to immunize the children, arguing § 43-285(1) limits the court to assenting to DHHS decisions rather than setting such conditions itself.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile court had authority to order DHHS to update children’s immunizations	Robert/Veronica: Court lacks power to impose immunization directive because § 43-285(1) limits court to assenting to DHHS decisions	State: Court may impose conditions under § 43-288 when juvenile remains in home or returns, including requiring medical care	Court affirmed: juvenile court authorized to require immunizations as a condition of disposition under § 43-288

In re Interest of Becka P. et al., 296 Neb. 365, 894 N.W.2d 247 (2017) (discussing appellate review and related prior orders in this matter)
In re Interest of Carmelo G., 296 Neb. 805, 896 N.W.2d 902 (2017) (authoritative statement on de novo review and legal questions on appeal)