Moore v. Nebraska Acct. & Disclosure Comm., 310 Neb. 302

Timothy Moore served as chair of the Village of Madrid Board of Trustees from 1998–2016; chair compensation was set by ordinance/resolution and increased in 2014.
In 2014–2016 Moore performed additional work for the village (utilities cover, budget/audit assistance, legal-related tasks, miscellaneous chores) and billed an hourly rate that the board had preapproved.
Moore submitted monthly payment requests for that extra work; the board routinely approved and paid the requests at regular meetings but the requests were not listed as agenda items, and Moore did not declare his interest or abstain from voting.
A resident complaint led the Nebraska Accountability and Disclosure Commission (NADC) to hold a hearing; the NADC found implied contracts existed between Moore and the village and that Moore violated the disclosure/abstention rules of §49-14,103.01(5); it imposed a $500 civil penalty.
Moore sought judicial review under the Administrative Procedure Act; the district court affirmed the NADC’s ruling, and the Nebraska Supreme Court affirmed, holding competent evidence supported an implied contract and that Moore violated the statute by failing to follow disclosure/abstention requirements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Moore had "an interest in any contract" with the village triggering §49-14,103.01	Moore: No contract or meeting of the minds existed; therefore §49-14,103.01(5) did not apply	NADC: Parties' conduct (board preapproval of work and rate, routine approvals/payments) evidenced implied contracts and Moore received direct pecuniary payments	Court: Implied contracts existed; Moore failed to follow §49-14,103.01(5) (agenda, disclosure, abstention); NADC decision and $500 penalty affirmed
Whether Moore was acting as an employee (so statute would not apply)	Moore: Performed extra work as a village employee, not as an officer	NADC: Moore acted as a trustee/officer when performing the work; statutory limits on trustees performing paid work apply	Court: District court rejected the employee argument; Supreme Court did not address it on appeal because Moore did not assign error to that aspect

Big Blue Express v. Nebraska Dept. of Rev., 309 Neb. 838 (standards for APA judicial review)
Peterson v. Jacobitz, 309 Neb. 486 (statutory construction and legislative intent)
Vokal v. Nebraska Acct. & Disclosure Comm., 276 Neb. 988 (statutory interpretation principles)
Linscott v. Shasteen, 288 Neb. 276 (implied contract and meeting-of-minds doctrine)
Heese v. Wenke, 161 Neb. 311 (historical rule treating officer contracts with village as void)