In re Interest of L.T., 886 N.W.2d 525

Douglas County Attorney filed a SOCA petition (alleged dangerous sex offender) against L.T.; Mental Health Board found L.T. a dangerous sex offender and ordered inpatient treatment.
L.T. timely appealed to the district court; the district court reversed the board, found insufficient evidence for SOCA commitment, and unconditionally discharged L.T.
The State sought to appeal the district court’s final order under Neb. Rev. Stat. § 71-1214, which permits appeals “in accordance with the procedure in criminal cases.”
Instead of using the general appeal statute, the State used the criminal error-proceeding route (§ 29-2315.01), sought leave to docket, and obtained Court of Appeals leave to docket the appeal.
The record contained no notice of appeal filed in the district court and no docket fee deposited under the general appeal statute (§ 25-1912); the State conceded it never filed a district-court notice of appeal.
The Supreme Court held that § 71-1214 requires use of the general appeal procedure (§ 25-1912) for all appeals from district-court SOCA final orders, and because the State failed to perfect the appeal, the Court dismissed for lack of jurisdiction.

Issue	Plaintiff's Argument (State)	Defendant's Argument (L.T.)	Held
Which "procedure in criminal cases" governs appeals under § 71-1214?	§ 29-2315.01 (error proceedings for prosecutors) applies to State appeals.	§ 25-1912 (general appeal procedure) governs; State failed to file district-court notice.	§ 25-1912 is the proper, single procedure for SOCA appeals regardless of appellant.
Did the State perfect its appeal?	It followed § 29-2315.01 and obtained leave to docket; that suffices.	No notice of appeal or docket fee was filed/deposited under § 25-1912, so appeal not perfected.	State did not file the required notice or deposit docket fee; appeal not perfected.
Is filing a notice of appeal and depositing the docket fee jurisdictional for § 25-1912 appeals?	(implicit) procedural requirements were met under State's chosen route.	These steps are mandatory and jurisdictional under § 25-1912.	Filing notice and depositing fee are mandatory and jurisdictional.
Result of failure to perfect appeal?	(State hoped appeal could proceed)	Dismiss for lack of jurisdiction.	Appeal dismissed for lack of appellate jurisdiction.

State v. Carter, 292 Neb. 16 (2015) (statutory interpretation and appellate jurisdiction principles)
In re Interest of Edward B., 285 Neb. 556 (2013) (failure to perfect appeal deprives appellate jurisdiction)
Huntington v. Pedersen, 294 Neb. 294 (2016) (plain-meaning canon for statutory language)
State v. Parmar, 255 Neb. 356 (1998) (filing notice and depositing docket fee are mandatory and jurisdictional)
State v. Dunlap, 271 Neb. 314 (2006) (when appellate court lacks jurisdiction, appeal must be dismissed)