Mid America Agri Prods. v. Perkins Cty. Bd. of Equal., 979 N.W.2d 95

Wheatland owns Perkins County real property and timely protested valuations for 2018–2020; those appeals to TERC were pending.
For 2021 the assessor made no valuation change and sent no notice; Wheatland hand-delivered a protest on July 1, 2021 (after the June 30 statutory deadline).
The county clerk notified Wheatland on July 2 that the protest was late and would not be heard; Wheatland’s counsel nevertheless attended the July 19 board meeting and later claimed the board accepted and discussed the 2021 protest.
The Perkins County Board of Equalization treated the 2021 protest as dismissed for being untimely; Wheatland appealed to TERC.
TERC held a jurisdictional hearing, found the protest was untimely, relied on the June 30 filing requirement and an administrative regulation providing for automatic dismissal, and concluded the board lacked authority to hear or waive the late filing.
The Nebraska Supreme Court affirmed: the June 30 deadline is mandatory, a county board cannot waive subject-matter authority, and TERC properly affirmed the dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a county board (and TERC) may hear an untimely property valuation protest filed after June 30	Deadline is directory/waivable; board accepted and heard the protest, so merits review should proceed	June 30 filing is mandatory; board lacks statutory authority to waive; regulation mandates automatic dismissal	The June 30 deadline is mandatory; board had no authority to hear or waive the late protest; TERC correctly affirmed dismissal

Village at North Platte v. Lincoln Cty. Bd. of Equal., 292 Neb. 533 (2016) (board must dismiss protests that fail statutory requirements; TERC lacks authority to reach merits when board lacked authority)
Betty L. Green Living Trust v. Morrill Cty. Bd. of Equal., 299 Neb. 933 (2018) (standard of appellate review for TERC decisions)
Ash Grove Cement Co. v. Nebraska Dept. of Rev., 306 Neb. 947 (2020) (properly adopted agency regulations filed with Secretary of State have effect of statutory law)
Karo v. NAU Country Ins. Co., 297 Neb. 798 (2017) (distinguishing jurisdictional requirements from claim-processing rules)
Williams v. Williams, 311 Neb. 772 (2022) (use of "shall" generally construed as mandatory)
County of Webster v. Nebraska Tax Equal. & Rev. Comm., 296 Neb. 751 (2017) (statutory interpretation in TERC review is a question of law)