State v. Fredrickson, 939 N.W.2d 385

Richard Fredrickson was charged with robbery, possession/use of a deadly weapon; county court initially adjudged him indigent and appointed counsel.
Fredrickson failed to file a poverty affidavit initially; case transferred to district court, where he pled no contest to robbery in exchange for dismissal of other counts.
The State moved to determine indigency and to sell an impounded vehicle to reimburse the County for appointed counsel fees; the court ordered sale proceeds first applied to costs and attorney fees.
Fredrickson submitted financial affidavits showing a bank account and listed vehicle value; he later conceded receipt of about $80,000 from a jointly owned real estate sale but testified most of those funds were spent by his power of attorney for family/child-support expenses.
The district court found Fredrickson indigent and appointed appellate counsel at the County’s expense; the State appealed that order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the order appointing appellate counsel is a final, appealable order	The order affects a substantial right because it obligates the County to pay appointed counsel and the State must be able to appeal that obligation now	The appointment is not a final judgment; fee and reimbursement issues remain for later proceedings and statutory remedies exist	The order is not final or a judgment and did not affect a substantial right; Court lacks jurisdiction and appeal dismissed
Whether the trial court abused its discretion in finding Fredrickson indigent and refusing to apply his other assets to reimburse the County	Fredrickson failed to disclose finances, acquired undisclosed funds ($80,000), and has sufficient assets to pay counsel	Fredrickson says remaining funds are allocated for child support and that any incorrect affidavit could lead to later reimbursement; State may seek recoupment under statute	Merits were not reached due to lack of appellate jurisdiction; State retains statutory avenues (e.g., post-appointment reimbursement) to challenge indigency or recover fees

State v. Coble, 299 Neb. 434, 908 N.W.2d 646 (Neb. 2018) (discusses what constitutes a judgment)
Webb v. Nebraska Dept. of Health & Human Servs., 301 Neb. 810, 920 N.W.2d 268 (Neb. 2018) (appellate jurisdiction exists only as provided by statute)
In re Grand Jury of Douglas Cty., 302 Neb. 128, 922 N.W.2d 226 (Neb. 2019) (sets test for whether an order affects a substantial right)
State v. Ratumaimuri, 299 Neb. 887, 911 N.W.2d 270 (Neb. 2018) (in criminal cases the appealable judgment is the sentence)
In re Claim of Rehm and Faesser, 226 Neb. 107, 410 N.W.2d 92 (Neb. 1987) (county may seek reimbursement for appointed counsel fees)
Mutual of Omaha Bank v. Watson, 301 Neb. 833, 920 N.W.2d 284 (Neb. 2018) (discusses final-order standards)