In re Interest of Seth C., 951 N.W.2d 135

State filed juvenile petition after a road-rage altercation in which Seth approached the victim’s vehicle and punched him multiple times; Seth admitted to an amended allegation of disturbing the peace.
Victim received medical treatment the same day; medical bills showed $3,330.96 outstanding.
Juvenile court placed Seth on probation and scheduled a restitution hearing to determine amount.
At the restitution hearing Seth (about to turn 19) testified he earned ~$800–900/month and paid ~ $435 in monthly expenses.
The juvenile court found restitution for medical expenses authorized, but, given Seth’s limited time on probation and finances, ordered Seth to pay $500.
Seth appealed, arguing (1) the Juvenile Code does not authorize restitution for medical (bodily) injuries, (2) the evidence was insufficient to support causation/amount, and (3) he lacked ability to pay.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 43-286(1)(a) authorizes restitution for a victim's medical expenses	State: “including” is nonexhaustive; Juvenile Code aims to promote reconciliation and restitution as means of rehabilitation, so medical restitution is authorized	Seth: statute authorizes restitution only for property stolen or damaged, not bodily injury/medical expenses	Court: § 43-286(1)(a) lists examples; nonexhaustive. Juvenile Code’s purposes support ordering restitution for medical expenses when in juvenile’s rehabilitative interest.
Whether the record supports causation and the $500 award	State: admission, police reports showing Seth was initial aggressor, medical bills dated same day, victim’s testimony linking treatment to incident	Seth: injuries might have arisen from striking a median; bills lack injury detail; victim impact statement hearsay	Court: despite some ambiguity, record (admission, police report, bills, testimony) sufficiently links injuries to Seth and supports the reduced $500 award.
Whether Seth had the ability to pay $500	State/Court: considered earnings, expenses, short probation period, and reduced total restitution to an amount Seth could reasonably pay	Seth: $500 exceeds his ability and undermines restitution’s rehabilitative purpose	Court: evidence showed Seth had ~$500–600 disposable monthly income; $500 was rationally related to proofs and consistent with rehabilitation and ability to pay.

In re Interest of Laurance S., 274 Neb. 620, 742 N.W.2d 484 (Neb. 2007) (juvenile restitution: permissible methods and factors including ability to pay)
State v. Jedlicka, 305 Neb. 52, 938 N.W.2d 854 (Neb. 2020) (statutory use of “include/including” indicates nonexhaustive examples)
In re Interest of Veronica H., 272 Neb. 370, 721 N.W.2d 651 (Neb. 2006) (foremost objective of Juvenile Code is juvenile’s best interests)
Ash Grove Cement Co. v. Nebraska Dept. of Rev., 306 Neb. 947, 947 N.W.2d 731 (Neb. 2020) (statutory construction principles: text, context, purpose)
In re Interest of Donald B. & Devin B., 304 Neb. 239, 933 N.W.2d 864 (Neb. 2019) (juvenile court is a statutory court of limited and special jurisdiction)
In re Interest of Brandon M., 273 Neb. 47, 727 N.W.2d 230 (Neb. 2007) (juvenile proceeding is an ameliorative alternative to criminal prosecution)