Saylor v. State, 306 Neb. 147

James Saylor, a Nebraska Department of Correctional Services inmate, filed 16 presuit tort claims with the State Risk Manager between June 2016 and February 2017 using the Risk Manager’s "Tort & Miscellaneous Claim Form."
Each form was completed in required fields except field No. 9 ("Total Amount of Claim"), where Saylor wrote "[t]o be proven" rather than a dollar amount.
The Risk Manager acknowledged receipt, assigned claim numbers, did not request additional information, and ultimately denied the claims on the merits (denial letters dated June 15, 2017).
Saylor sued the State on June 16, 2017. The State moved for dismissal (treated as summary judgment), arguing Saylor failed to file claims "in the manner prescribed by the State Claims Board" because he did not state a dollar amount.
The district court granted summary judgment for the State and dismissed Saylor’s complaint. The Nebraska Supreme Court reversed, holding Saylor substantially complied with STCA presuit content requirements and remanding for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the substantial compliance doctrine applies to presuit content under the State Tort Claims Act (STCA)	Saylor: doctrine should apply as under the PSTCA to assess content compliance.	State: STCA requirements must be followed strictly; substantial compliance is inconsistent with waiver-of-sovereign-immunity rules.	Court: Substantial compliance applies to presuit content under STCA (but not to timing or delivery to proper recipient).
Whether Saylor’s claim forms satisfied the STCA requirement to be filed "in the manner prescribed by the State Claims Board" when field No. 9 read "[t]o be proven" instead of a dollar amount	Saylor: his forms provided all information called for and the narrative described general damages; the Risk Manager accepted and investigated the forms.	State: Field No. 9 required an amount; absence of a dollar figure meant claims did not "contain all information called for" under Board regulations.	Court: Saylor’s responses substantially complied—"[t]o be proven" was sufficient for general damages and caused no prejudice to the State.
Whether the State waived any procedural challenge by accepting and processing the submitted forms	Saylor: acceptance, assignment of claim numbers, and investigation waived challenge.	State: Acceptance did not waive formal compliance defense.	Court: Because it found substantial compliance on the merits, it did not decide waiver argument.

City of Lincoln v. Pirner, 59 Neb. 634, 81 N.W. 846 (1900) (early adoption of substantial-compliance approach to municipal presuit notice)
Chicago Lumber Co. v. School Dist. No. 71, 227 Neb. 355, 417 N.W.2d 757 (1988) (liberal construction of PSTCA presuit-content requirements; substantial compliance suffices)
West Omaha Inv. v. S.I.D. No. 48, 227 Neb. 785, 420 N.W.2d 291 (1988) (content need not state dollar amount; substantial compliance when purpose of notice met)
Jill B. & Travis B. v. State, 297 Neb. 57, 899 N.W.2d 241 (2017) (statutes waiving sovereign immunity construed strictly—context for assessing State's argument)
Cole v. Isherwood, 264 Neb. 985, 653 N.W.2d 821 (2002) (treating presuit presentment and final disposition as procedural conditions precedent rather than jurisdictional)
Komar v. State, 299 Neb. 301, 908 N.W.2d 610 (2018) (STCA presuit and final disposition framework)