In re Interest of Sandrino T., 295 Neb. 270

Two juveniles, Sandrino T. and Remus M., were each charged in Lancaster County juvenile court with six counts arising from ATM "skimming" (three Class IIIA felonies and three Class IV felonies).
Dental exams placed both juveniles at least 16 years old (possible ages up to ~17½; Sandrino possibly 18).
The State filed motions under Neb. Rev. Stat. § 43-274(5) to transfer both juvenile cases to county court for prosecution under the criminal code; the juvenile court granted the consolidated motions.
Sandrino and Remus each appealed the juvenile court’s orders transferring their cases to county court, arguing the transfer rulings were erroneous and final, appealable orders.
The Nebraska Supreme Court consolidated the appeals and considered only whether it had jurisdiction (i.e., whether the transfer orders were final and appealable) before reaching merits.
The Court concluded the transfer orders were not final, appealable orders because the transfers did not affect a "substantial right" that could not be vindicated on appeal after final judgment; therefore the appeals were dismissed for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile-court orders transferring cases to county court are final, appealable orders	Sandrino/Remus: L.B. 464 removed language making transfer rulings nonfinal, so transfer orders should be immediately appealable	State: Transfer orders are not final under § 25-1902 unless they affect a substantial right; statutory silence does not create interlocutory appeal rights	Transfer orders are not final/appealable because they do not affect a substantial right that cannot be vindicated by appeal after final judgment; appeals dismissed
Whether transfer to criminal court deprives juveniles of a constitutional right to juvenile proceedings	Sandrino/Remus: Losing access to juvenile forum and its rehabilitative services is a substantial right	State: Access to juvenile court is statutory, not constitutional; loss does not constitute a substantial right for interlocutory appeal purposes	No constitutional right to proceed in juvenile rather than criminal court; transfer does not affect a substantial right

In re Adoption of Jaelyn B., 293 Neb. 917 (discusses jurisdictional questions and appeals) (jurisdictional issue presenting question of law)
Cattle Nat. Bank & Trust Co. v. Watson, 293 Neb. 943 (addresses types of final orders under Neb. Rev. Stat. § 25-1902)
In re Adoption of Madysen S. et al., 293 Neb. 646 (defines "substantial right" as an essential legal right)
State v. Meese, 257 Neb. 486 (no constitutional right to juvenile rather than criminal prosecution)
In re Interest of Cassandra B. & Moira B., 290 Neb. 619 (jurisdictional requirement to determine appellate jurisdiction in juvenile cases)