Mutual of Omaha Bank v. Watson, 920 N.W.2d 284

Mutual of Omaha Bank obtained a foreclosure decree against Robert W. Watson and his former spouse; district court ordered execution sale and foreclosure, and Watson appealed.
This court affirmed the foreclosure in a prior opinion (Watson appealed and lost).
After the appeal, the district court entered a supplemental decree adding additional sums Mutual paid related to the mortgaged property to the amount owed.
Watson sought a statutory stay of the order of sale within 20 days of the supplemental decree’s entry.
The district court denied Watson’s request for a stay; Watson appealed that denial to the Nebraska Supreme Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court’s denial of Watson’s request for a stay after a supplemental decree is an appealable final order	Watson: He timely requested a stay within 20 days of the supplemental decree and thus has a statutory right to a stay under § 25-1506	Mutual: The supplemental decree merely increased personal liability and did not create a new right to a stay; denial is not a final, appealable order	Denied: The denial was not a final order affecting a substantial right and thus not appealable; appeal dismissed

Mutual of Omaha Bank v. Watson, 297 Neb. 479, 900 N.W.2d 545 (Neb. 2017) (prior appeal affirming foreclosure)
Prudential Ins. Co. v. Nethaway, 127 Neb. 330, 255 N.W. 26 (Neb. 1934) (supplemental decree increasing money judgment does not authorize a new statutory stay of sale)
Cullinane v. Beverly Enters.-Neb., 300 Neb. 210, 912 N.W.2d 774 (Neb. 2018) (framework describing three categories of final orders)
Deines v. Essex Corp., 293 Neb. 577, 879 N.W.2d 30 (Neb. 2016) (analysis focusing on whether an order affects a substantial right)