Nebraska Revised Statutes

Neb. Rev. Stat. § 25-1315 (2026)

Multiple claims or parties; effect

✓ current as of July 2026

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(1) When more than one claim for relief is presented in an action, whether as a claim, counterclaim, cross-claim, or third-party claim, or when multiple parties are involved, the court may direct the entry of a final judgment as to one or more but fewer than all of the claims or parties only upon an express determination that there is no just reason for delay and upon an express direction for the entry of judgment. In the absence of such determination and direction, any order or other form of decision, however designated, which adjudicates fewer than all the claims or the rights and liabilities of fewer than all the parties shall not terminate the action as to any of the claims or parties, and the order or other form of decision is subject to revision at any time before the entry of judgment adjudicating all the claims and the rights and liabilities of all the parties.

(2) When a court has ordered a final judgment under the conditions stated in subsection (1) of this section, the court may stay enforcement of that judgment until the entry of a subsequent judgment or judgments and may prescribe such conditions as are necessary to secure the benefit thereof to the party in whose favor the judgment is entered.

Notes of Decisions

Cited in 114 cases (37 in the last 5 years), 1949–2026 · leading case: Mann v. Mann, 978 N.W.2d 606 (Neb. 2022).

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Mann v. Mann, 978 N.W.2d 606 (Neb. 2022). · cites it 104× “A trial court’s decision to certify a final judgment pursuant to Neb. Rev. Stat. § 25-1315 (1) (Reissue 2016) is reviewed for an abuse of discretion, but whether § 25-1315 is impli- cated in a case is a question of law which an appellate court considers de novo.”

Guardian Tax Partners v. Skrupa Invest. Co., 889 N.W.2d 825 (Neb. 2017). · cites it 26× “A trial court’s decision to certify a final judgment pursuant to Neb. Rev. Stat. § 25-1315 (1) (Reissue 2016) is reviewed for an abuse of discretion.”

Cerny v. Todco Barricade Co., 733 N.W.2d 877 (Neb. 2007). · cites it 37× “The court certified its partial summary judgment as a final judgment pursuant to Neb. Rev. Stat. § 25-1315 (1) (Cum. Supp.”

Cattle Nat. Bank & Trust Co. v. Watson, 880 N.W.2d 906 (Neb. 2016). · cites it 16× “” The summary judgment order did not address Shona’s cross-claim against Robert, and it did not direct the entry of final judgment pursuant to Neb. Rev. Stat. § 25-1315 (Reissue 2008).”

State ex rel. Marcelo K. v. Ricky K., 912 N.W.2d 747 (Neb. 2018). · cites it 17× “But, as here, where the language of § 25-1315 is implicated, we must apply the requirements of that section in order to find a final, appealable order.”

Connelly v. City of Omaha, 769 N.W.2d 394 (Neb. 2009). · cites it 22× “The City moved for certification of a final judgment pursuant to Neb. Rev. Stat. § 25-1315 (Reissue 2008), and when that was granted by the district court, the City filed a notice of appeal.”

TDP Phase One v. The Club at the Yard, 307 Neb. 795 (Neb. 2020). · cites it 38× “Where the proceed- ings below involved multiple claims for relief or multiple parties, and the court has adjudicated fewer than all the claims or the rights and liabilities of fewer than all the parties, then, absent a specific statute governing the appeal providing otherwise,…”

Malolepszy v. State, 699 N.W.2d 387 (Neb. 2005). · cites it 29× “The third-party action filed by the State against Vrana was not resolved in the May 13 order, and the district court did not direct the entry of a final judgment under Neb. Rev. Stat. § 25-1315 (1) (Cum. Supp.”

Blue Cross & Blue Shield of Nebraska, Inc. v. Dailey, 687 N.W.2d 689 (Neb. 2004). · cites it 24× “Blue Cross asserts that we do not have jurisdiction over this appeal because the order from which Dailey appeals is not a final *695 order under Neb.Rev.Stat. § 25-1315 (Cum.Supp.2002). Dailey responds that the district court amended its original order to make it clear that the…”

Bailey v. Lund-Ross Constructors Co., 657 N.W.2d 916 (Neb. 2003). · cites it 20× “Lund-Ross appealed after the district court entered a “final judgment” pursuant to Neb. Rev. Stat. § 25-1315 (1) (Cum. Supp.”

Poppert v. Dicke, 747 N.W.2d 629 (Neb. 2008). · cites it 16× “" Before § 25-1315 was enacted, the dismissal of one of multiple causes of action was a final, appealable order, but an order dismissing one of multiple theories of recovery, all of which arose from the same set of operative facts, was not a final order for appellate purposes.”

Ryan v. Ryan, 313 Neb. 938 (Neb. 2023). · cites it 54× “A trial court’s decision to certify a final judgment pursuant to Neb. Rev. Stat. § 25-1315 (1) (Reissue 2016) is reviewed for an abuse of discretion, but whether § 25-1315 is impli- cated in a case is a question of law which an appellate court considers de novo.”

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— Neb. Rev. Stat. § 25-1315(1) — 60 cases

Cerny v. Todco Barricade Co., 733 N.W.2d 877 (Neb. 2007). “The court certified its partial summary judgment as a final judgment pursuant to Neb. Rev. Stat. § 25-1315 (1) (Cum. Supp.”

Mann v. Mann, 978 N.W.2d 606 (Neb. 2022). “A trial court’s decision to certify a final judgment pursuant to Neb. Rev. Stat. § 25-1315 (1) (Reissue 2016) is reviewed for an abuse of discretion, but whether § 25-1315 is impli- cated in a case is a question of law which an appellate court considers de novo.”

Cattle Nat. Bank & Trust Co. v. Watson, 880 N.W.2d 906 (Neb. 2016). “” The summary judgment order did not address Shona’s cross-claim against Robert, and it did not direct the entry of final judgment pursuant to Neb. Rev. Stat. § 25-1315 (Reissue 2008).”

Malolepszy v. State, 699 N.W.2d 387 (Neb. 2005). “The third-party action filed by the State against Vrana was not resolved in the May 13 order, and the district court did not direct the entry of a final judgment under Neb. Rev. Stat. § 25-1315 (1) (Cum. Supp.”

Bailey v. Lund-Ross Constructors Co., 657 N.W.2d 916 (Neb. 2003). “Lund-Ross appealed after the district court entered a “final judgment” pursuant to Neb. Rev. Stat. § 25-1315 (1) (Cum. Supp.”

— Neb. Rev. Stat. § 25-1315(l) — 1 case

Cerny v. Todco Barricade Co., 733 N.W.2d 877 (Neb. 2007). “The court certified its partial summary judgment as a final judgment pursuant to Neb. Rev. Stat. § 25-1315 (1) (Cum. Supp.”

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