State v. Roberts, 934 N.W.2d 845

Roberts received two separate sentences: Madison County (364 days jail + 9 months postrelease supervision) and Pierce County (394 days jail + 18 months postrelease supervision); both were ordered consecutive to other sentences.
He served both incarceration terms, was released June 18, 2017, and began postrelease supervision; Madison County's PRS was terminated effective March 18, 2018.
The State charged Roberts in Pierce County (April 10, 2018) with violating Pierce County PRS and sought revocation; the State treated the Pierce PRS as beginning March 18, 2018 (after Madison PRS termination).
Roberts argued the Pierce PRS began on his Pierce release date (June 18, 2017) and thus any revocation incarceration could not extend past December 18, 2018; the Pierce court ruled PRS terms run consecutively and set the Pierce PRS end date as September 18, 2019.
The court revoked PRS and ordered Roberts jailed until September 18, 2019; Roberts appealed, but by the time of oral argument he had fully served the sentence.
The parties agreed the appeal was moot; Roberts asked the court to decide the merits under the public interest exception, but the Nebraska Supreme Court declined and dismissed the appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness of appeal	Roberts sought merits under public interest exception despite sentence completion	State urged dismissal as moot because Roberts fully served the sentence	Appeal is moot; dismissal affirmed — court declined public interest exception
Whether PRS terms may run consecutively / whether revocation incarceration exceeded lawful time	Roberts: Pierce PRS began on June 18, 2017, so revocation jail could not extend beyond Dec 18, 2018	State: Sentences were ordered consecutive, so PRS terms (and remaining revocation exposure) run consecutively, ending Sept 18, 2019	Merits not decided; court treated Roberts’ claim as an attack on the original sentence (must be raised on direct appeal) and therefore inappropriate to reach via public-interest mootness exception

State ex rel. Peterson v. Ebke, 303 Neb. 637 (2019) (mootness is a jurisdictional question reviewed de novo)
Bramble v. Bramble, 303 Neb. 380 (2019) (discussing public interest exception to mootness)
Evertson v. City of Kimball, 278 Neb. 1 (2009) (three-factor test for public interest exception)
State v. Dill, 300 Neb. 344 (2018) (postrelease supervision is a form of probation)
State v. Paulsen, 304 Neb. __ (2019) (discussion of finality and need to raise claims at first opportunity)
State v. Englehart, 231 Neb. 579 (1989) (cannot attack underlying conviction in probation-revocation appeal)
State v. Patterson, 237 Neb. 198 (1991) (appeal of conviction or sentence is generally moot once sentence is fully served)