In re Interest of Miah T. & DeKandyce H., 875 N.W.2d 1

Child DeKandyce (b. 2007) was adjudicated under Neb. Rev. Stat. § 43-247(3)(a) after her mother Everlyn pled no contest following an incident of alcohol-related violence; children were placed in Department custody.
Father DeKarlos had unsupervised visitation early in the case but had multiple domestic-violence–related arrests, entries on the child abuse/neglect registry, intermittent incarceration, and an outstanding child-support warrant.
January 2015 dispositional order required DeKarlos to obtain "domestic violence education" to be considered for placement.
April 2015 review order (from which DeKarlos appealed) specified that DeKarlos must complete a batterers’ intervention course and a victims’ impact group before being considered for placement; State also filed a supplemental petition alleging DeKarlos had failed to participate and/or had neglected the child.
Foster placement changed in spring 2015; juvenile court approved continued placement in a nonrelative foster home over DeKarlos’s objection after evidence the prior foster family felt harassed by parents and concerns about DeKarlos’s fitness.
DeKarlos appealed two orders: (1) the April 2015 rehabilitation-course requirement (A-15-417) and (2) the June 2015 order continuing placement in nonrelative foster care instead of placing the child with him (A-15-694). Court affirmed both orders.

Issue	DeKarlos' Argument	State's Argument	Held
Whether the April 2015 order requiring batterers’ intervention and victims’ impact group was a final, appealable order and, if so, whether it was improper	The April order was unlawful because DeKarlos was not adjudicated; the requirements do not address the circumstances of the child’s adjudication and unjustly affect his right to raise his child	The April order materially changed the earlier, broader requirement and affected a substantial parental right, so it was appealable; requirements were reasonably related to reunification and safety	Court held the April 2015 order was appealable (material change) and valid: juvenile court had jurisdiction over parents and could prescribe rehabilitation reasonably related to reunification and safety
Whether juvenile court erred by keeping DeKandyce in nonrelative foster care rather than placing her with DeKarlos	DeKarlos claimed he is a fit parent able to provide a safe, stable home and that parental preference favors biological placement	State relied on evidence of unresolved domestic violence history, registry entries for neglect, repeated incarcerations, outstanding warrant, and failure to complete court-ordered programs — showing current unfitness	Court held sufficient evidence showed DeKarlos was presently unfit; parental-preference doctrine overcome; placement in nonrelative foster home affirmed

In re Interest of Karlie D., 283 Neb. 581 (discusses de novo review and trial-court factfinder weight)
In re Interest of Octavio B., et al., 290 Neb. 589 (finality of juvenile orders and appealability)
In re Interest of Mya C. & Sunday C., 286 Neb. 1008 (material change to case plan can affect appealability)
In re Interest of Devin W., et al., 270 Neb. 640 (juvenile court jurisdiction over parents of adjudicated children)
In re Interest of Rylee S., 285 Neb. 774 (juvenile court may prescribe reasonable parental rehabilitation)
In re Interest of Ty M. & Devon M., 265 Neb. 150 (orders requiring rehabilitation plans generally affect substantial parental rights)
In re Interest of Tabatha R., 255 Neb. 818 (rehabilitation plan as appealable dispositional order)
In re Interest of Amber G., et al., 250 Neb. 973 (parental preference doctrine; deprivation only if parent is unfit or forfeited right)