standing inquiry in Nebraska

2003Id.

2002Id.

1999Id., citing City of Ralston v. Balka, 247 Neb. 773 , 530 N.W.2d 594 (1995).

1999Id., citing City of Ralston v. Balka, 247 Neb. 773 , 530 N.W.2d 594 (1995).

2025Requirements for Standing We begin with a review of the principles governing our standing jurisprudence. [4-8] Standing refers to whether a party had, at the com- mencement of the litigation, a personal stake in the outcome of the litigation that would warrant a court’s exercise of its subject matter jurisdiction and remedial powers on that party’s behalf. 7 To have standing, the plaintiff must have some legal or equitable right, title, or interest in the subject matter of the controversy. 8 To show standing, it is generally insufficient for a plaintiff to have merely a general interest common

2025Requirements for Standing We begin with a review of the principles governing our standing jurisprudence. [4-8] Standing refers to whether a party had, at the com- mencement of the litigation, a personal stake in the outcome of the litigation that would warrant a court’s exercise of its subject matter jurisdiction and remedial powers on that party’s behalf. 7 To have standing, the plaintiff must have some legal or equitable right, title, or interest in the subject matter of the controversy. 8 To show standing, it is generally insufficient for a plaintiff to have merely a general interest common

2014In re Application A-18503, 286 Neb. 611 , 838 N.W.2d 242 (2013); Frenchman- Cambridge Irr.

2013The focus is on the party, not the claim itself.7 And standing requires that a litigant have such a personal stake in the outcome of a controversy as to warrant invocation of a court’s jurisdiction and justify exercise of the court’s remedial powers on the litigant’s behalf.8 Thus, generally, a litigant must assert the litigant’s own rights and interests, and cannot rest a claim on the legal rights or interests of third parties.9 [9] Specifically, a litigant first must clearly demonstrate that it has suffered an injury in fact.10 That injury must be concrete 3 Id. 4 Waste Connections of Neb. v

2000Id.; Hall v. Progress Pig, Inc., 254 Neb. 150 , 575 N.W.2d 369 (1998).

2000Id.; Hall v. Progress Pig, Inc., 254 Neb. 150 , 575 N.W.2d 369 (1998).

2025Requirements for Standing We begin with a review of the principles governing our standing jurisprudence. [4-8] Standing refers to whether a party had, at the com- mencement of the litigation, a personal stake in the outcome of the litigation that would warrant a court’s exercise of its subject matter jurisdiction and remedial powers on that party’s behalf. 7 To have standing, the plaintiff must have some legal or equitable right, title, or interest in the subject matter of the controversy. 8 To show standing, it is generally insufficient for a plaintiff to have merely a general interest common

2025Requirements for Standing We begin with a review of the principles governing our standing jurisprudence. [4-8] Standing refers to whether a party had, at the com- mencement of the litigation, a personal stake in the outcome of the litigation that would warrant a court’s exercise of its subject matter jurisdiction and remedial powers on that party’s behalf. 7 To have standing, the plaintiff must have some legal or equitable right, title, or interest in the subject matter of the controversy. 8 To show standing, it is generally insufficient for a plaintiff to have merely a general interest common

2024JACKSON Cite as 317 Neb. 141 While not inquiring into the legislative history of § 25-1902(1)(d) in our interpretation, 49 we are cognizant that members of the Legislature at the time of its adoption were concerned that the State’s sovereign immunity would be effec- tively lost if the matter cannot be raised in an interlocutory appeal. 50 However, insofar as the State Officials’ concerns involve taxpayer standing, other courts have observed that standing and sovereign immunity are “entirely distinct juris- dictional concepts.” 51 With sovereign immunity, the issue is “what sovereign immunity p

2024JACKSON Cite as 317 Neb. 141 While not inquiring into the legislative history of § 25-1902(1)(d) in our interpretation, 49 we are cognizant that members of the Legislature at the time of its adoption were concerned that the State’s sovereign immunity would be effec- tively lost if the matter cannot be raised in an interlocutory appeal. 50 However, insofar as the State Officials’ concerns involve taxpayer standing, other courts have observed that standing and sovereign immunity are “entirely distinct juris- dictional concepts.” 51 With sovereign immunity, the issue is “what sovereign immunity p

2023But first, we review the gen- eral principles that govern our standing analysis. [4,5] Standing is a jurisdictional component of a party’s case because only a party who has standing may invoke the jurisdiction of a court. 8 Because standing is a jurisdictional component, an appellate court must address it as a thresh- old matter. 9 [6-8] Standing refers to whether a party had, at the com- mencement of the litigation, a personal stake in the outcome of the litigation that would warrant a court’s exercise of its subject matter jurisdiction and remedial powers on that party’s behalf. 10 Standing

2023CHATTERJEE Cite as 313 Neb. 710 Standing refers to whether a party had, at the commencement of the litigation, a personal stake in the outcome of the litiga- tion that would warrant a court’s exercise of its subject matter jurisdiction and remedial powers on that party’s behalf. 4 To have standing, the plaintiff must have some legal or equitable right, title, or interest in the subject matter of the contro­ versy. 5 A plaintiff does not generally have standing to bring a case on behalf of a third party. 6 The focus of the standing inquiry is not whether the claim the plaintiff advances has mer

2023CHATTERJEE Cite as 313 Neb. 710 the standing inquiry is “on the party, not the claim itself.” For that very reason, in considering standing, the legal and factual validity of the claim presented must be assumed.

2023But first, we review the gen- eral principles that govern our standing analysis. [4,5] Standing is a jurisdictional component of a party’s case because only a party who has standing may invoke the jurisdiction of a court. 8 Because standing is a jurisdictional component, an appellate court must address it as a thresh- old matter. 9 [6-8] Standing refers to whether a party had, at the com- mencement of the litigation, a personal stake in the outcome of the litigation that would warrant a court’s exercise of its subject matter jurisdiction and remedial powers on that party’s behalf. 10 Standing

2023But first, we review the gen- eral principles that govern our standing analysis. [4,5] Standing is a jurisdictional component of a party’s case because only a party who has standing may invoke the jurisdiction of a court. 8 Because standing is a jurisdictional component, an appellate court must address it as a thresh- old matter. 9 [6-8] Standing refers to whether a party had, at the com- mencement of the litigation, a personal stake in the outcome of the litigation that would warrant a court’s exercise of its subject matter jurisdiction and remedial powers on that party’s behalf. 10 Standing

2023But first, we review the gen- eral principles that govern our standing analysis. [4,5] Standing is a jurisdictional component of a party’s case because only a party who has standing may invoke the jurisdiction of a court. 8 Because standing is a jurisdictional component, an appellate court must address it as a thresh- old matter. 9 [6-8] Standing refers to whether a party had, at the com- mencement of the litigation, a personal stake in the outcome of the litigation that would warrant a court’s exercise of its subject matter jurisdiction and remedial powers on that party’s behalf. 10 Standing

2023But first, we review the gen- eral principles that govern our standing analysis. [4,5] Standing is a jurisdictional component of a party’s case because only a party who has standing may invoke the jurisdiction of a court. 8 Because standing is a jurisdictional component, an appellate court must address it as a thresh- old matter. 9 [6-8] Standing refers to whether a party had, at the com- mencement of the litigation, a personal stake in the outcome of the litigation that would warrant a court’s exercise of its subject matter jurisdiction and remedial powers on that party’s behalf. 10 Standing

2020Fick v. Miller, 252 Neb. 164 , 560 N.W.2d 793 (1997). 14 State ex rel.

2020Fick v. Miller, 252 Neb. 164 , 560 N.W.2d 793 (1997). 14 State ex rel.

2019Id.

2018Co., 297 Neb. 798 , 901 N.W.2d 689 (2017). 3 Neb.

2018Co., 297 Neb. 798 , 901 N.W.2d 689 (2017). 3 Neb.

2018Stat. § 77-1701 (1) (Reissue 2009), which provides in part: “The county treasurer shall be ex officio county collector of all taxes levied within the county.” As we mentioned above, redemption, a term of art in § 77-1801 et seq., includes the payment of all property taxes due. [22] Thus, we hold that to satisfy the tax payment require- ment in § 77-1844, a party must show the tender or payment of taxes due to the county treasurer, and we disapprove of Hauxwell to the extent it can be read to authorize satisfying the standing requirement in § 77-1844 by tender or payment to the tax deed holder.

2018Stat. § 77-1701 (1) (Reissue 2009), which provides in part: “The county treasurer shall be ex officio county collector of all taxes levied within the county.” As we mentioned above, redemption, a term of art in § 77-1801 et seq., includes the payment of all property taxes due. [22] Thus, we hold that to satisfy the tax payment require- ment in § 77-1844, a party must show the tender or payment of taxes due to the county treasurer, and we disapprove of Hauxwell to the extent it can be read to authorize satisfying the standing requirement in § 77-1844 by tender or payment to the tax deed holder.

2018Stat. § 77-1844 (Reissue 2009), a party must show the tender or payment of taxes due to the county treasurer; Hauxwell v. Henning, 291 Neb. 1 , 863 N.W.2d 798 (2015), is disapproved to the extent it can be read to authorize satisfying the standing requirement in § 77-1844 by tender or payment to the tax deed holder. 23.

2016Id.

2015Cite as 291 Neb. 965 legally protectable interest or right in the controversy that would benefit by the relief to be granted.8 Persons claiming standing must show that their claim is premised on their own legal rights and not the rights of another.9 So, the standing issue turns on Mark and Roberta’s rights, if any, and how the placement order affected their rights.10 A par- ent has a fundamental liberty interest in the care, custody, and management of the child.11 And the State has an interest in the placement of a child derived from its role as parens patriae.12 Eternity’s interests are repre

2015Before reaching the legal issues presented for review, we must decide if we have jurisdiction.6 [5-7] Standing involves a real interest in the cause of action, meaning some legal or equitable right, title, or inter- est in the subject matter of the controversy.7 The purpose of the standing inquiry is to determine whether a person has a 2 In re Interest of Jahon S., 291 Neb. 97 , 864 N.W.2d 228 (2015). 3 Murray v. Stine, 291 Neb. 125 , 864 N.W.2d 386 (2015). 4 Jeffrey B. v. Amy L., 283 Neb. 940 , 814 N.W.2d 737 (2012). 5 Id. 6 Murray v. Stine, supra note 3 . 7 See Marcuzzo v. Bank of the West,

2015Before reaching the legal issues presented for review, we must decide if we have jurisdiction.6 [5-7] Standing involves a real interest in the cause of action, meaning some legal or equitable right, title, or inter- est in the subject matter of the controversy.7 The purpose of the standing inquiry is to determine whether a person has a 2 In re Interest of Jahon S., 291 Neb. 97 , 864 N.W.2d 228 (2015). 3 Murray v. Stine, 291 Neb. 125 , 864 N.W.2d 386 (2015). 4 Jeffrey B. v. Amy L., 283 Neb. 940 , 814 N.W.2d 737 (2012). 5 Id. 6 Murray v. Stine, supra note 3 . 7 See Marcuzzo v. Bank of the West,