In re Interest of Samantha L. & Jasmine L., 839 N.W.2d 265

Two Nebraska juveniles Jasmine and Samantha were in DHHS custody due to domestic violence and parental issues.
At adjudication, Kelly admitted to neglect and domestic violence in front of the children; William pled no contest to similar allegations.
The juvenile court found it in the children’s best interests to remain with DHHS in temporary custody.
February 2011–February 2012: DHHS provided services; a stipulation tolled a 43-292(7) termination period due to failure to provide reasonable efforts.
By February 2013, evidence showed continued parental noncompliance, housing instability, unemployment, and ongoing substance issues.
The February 26, 2013 order changed Jasmine’s permanency objective to independent living and Samantha’s to guardianship with a plan of adoption; reunification efforts were ended.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to include a separate assignments-of-error section on appeal is plain error.	Kelly/William argue the brief lacks proper assignments.	State/ DHHS contend plain-error review is appropriate.	No plain error; merits reviewed for plain-error standard.
Whether the court correctly found no further reasonable efforts were required for reunification.	Kelly/William contend continued services were needed.	DHHS argues ongoing services were not required.	No plain error; substantial evidence supported cessation of reasonable efforts.
Whether modifying permanency objectives was in the children’s best interests.	Parents argue modification was improper.	DHHS and guardians supported modification.	Not plain error; evidence supported change to independent living/adoption.

Hass v. Neth, 265 Neb. 321 (Neb. 2003) (plain-error review standard in juvenile contexts)
In re Interest of Jamyia M., 281 Neb. 964 (Neb. 2011) (discussion of appellate-waiver and plain error in juvenile appeals)
In re Interest of Karlie D., 283 Neb. 581 (Neb. 2012) (support for changes in permanency objectives)