In re Interest of Zachary B., 299 Neb. 187

Juvenile Zachary B., born April 2000, was adjudicated a juvenile for truancy in March 2016 and placed on probation in the family home in June 2016 with requirement to attend school.
In January 2017 the State moved to revoke probation for continued truancy and failure to cooperate with services; Zachary admitted the violations in February 2017.
The juvenile court deferred disposition pending an updated predisposition report and continued the matter to April 12, 2017.
At the April 12 hearing the court found community-based services had been exhausted, that maintaining Zachary at home posed a significant risk to his education/future, and ordered placement at Boys Town while continuing disposition to June 22, 2017.
The court expressly stated the April 12 order was not a final dispositional order, intended the placement to be temporary under Neb. Rev. Stat. § 43-286, and planned to revisit placement at the next hearing.
Zachary appealed the April 12 order, arguing insufficient evidence supported the § 43-251.01(7) findings; the State argued the order was not final and therefore not appealable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the April 12, 2017 order placing Zachary at Boys Town is a final, appealable order	Zachary: order affected a substantial right (statutory right to remain in home under § 43-251.01(7)); denial of immediate review would deny meaningful appellate review	State: order was temporary, not a final disposition, did not affect rights with finality so no appellate jurisdiction	Court: order was temporary, intended to be revisited in ~60 days, did not affect right to home with finality; not appealable; appeal dismissed

In re Interest of Becka P. et al., 296 Neb. 365 (discusses juvenile appealability and substantial-right analysis)
In re Interest of Noah B. et al., 295 Neb. 764 (effect on substantial right requires finality)
In re Interest of Cassandra B. & Moira B., 290 Neb. 619 (parental rights and finality in juvenile orders)
In re Guardianship of Benjamin E., 289 Neb. 693 (child's reciprocal right to parent-child relationship)
In re Interest of Karlie D., 283 Neb. 581 (juvenile court continuing authority and finality considerations)
In re Guardianship of D.J., 268 Neb. 239 (parent-child relationship as fundamental right)