Neb. Rev. Stat. » Chapter 43
Nebraska Revised Statutes

Neb. Rev. Stat. § 43-278 (2026)

Adjudication hearing; held within ninety days after petition is filed; additional reviews; telephonic or videoconference hearing; authorized

✓ current as of July 2026
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Except as provided in sections 43-254.01 and 43-277.01, all cases filed under subdivision (3) of section 43-247 shall have an adjudication hearing not more than ninety days after a petition is filed. Upon a showing of good cause, the court may continue the case beyond the ninety-day period. The court shall also review every case filed under such subdivision which has been adjudicated or transferred to it for disposition not less than once every six months. All communications, notices, orders, authorizations, and requests authorized or required in the Nebraska Juvenile Code; all nonevidentiary hearings; and any evidentiary hearings approved by the court and by stipulation of all parties may be heard by the court telephonically or by videoconferencing in a manner that ensures the preservation of an accurate record. All of the orders generated by way of a telephonic or videoconference hearing shall be recorded as if the judge were conducting a hearing on the record.

Notes of Decisions
Cited in 19 cases (2 in the last 5 years), 1985–2025 · leading case: In Re Interest of Brandy M., 550 N.W.2d 17 (Neb. 1996).
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In Re Interest of Brandy M., 550 N.W.2d 17 (Neb. 1996). · cites it 11× “The Court of Appeals did note that of the 10 cases involved in the instant appeal, 1 case was filed pursuant to § 43-247(3)(b) and that § 43-278 provided this juvenile with a statutory right to an adjudication hearing within 90 days.”
State v. Lloyd T., 721 N.W.2d 676 (Neb. Ct. App. 2006). · cites it 6× “Lloyd claims that pursuant to Neb. Rev. Stat. § 43-278 (Reissue 2004), an adjudication must occur within 90 days of the filing of a petition or the State is required to make a showing of good cause, on the record, for why the petition should not be dismissed.”
In re Interest of Draygon W., 31 Neb. Ct. App. 400 (Neb. Ct. App. 2022). · cites it 8× “Neb. Rev. Stat. § 43-278 (Reissue 2016) pro- vides that an adjudication hearing shall be conducted within 90 days after a petition is filed.”
Carson P. ex rel Foreman v. Heineman, 240 F.R.D. 456 (D. Neb. 2007). · cites it 4× “HHS obtains legal custody and provides services to 3(b) juveniles only when the court has first conducted a hearing, determined that a child is a status offender, and has ordered the department’s involvement.”
Interest of C.P. v. M.A., 455 N.W.2d 138 (Neb. 1990). · cites it 7× “The 6-month period is to be calculated in the same manner as the 6-month period is calculated in criminal cases under § 29-1207. § 43-278. Although § 43-278 directs that an adjudication hearing be held within 6 months after a petition is filed, the Legislature has not directed…”
State v. Mitzi M., 591 N.W.2d 557 (Neb. 1999). · cites it 4× “With respect to the adjudicative phase of juvenile proceedings, we are aware that the version of § 43-278 in effect at the time of the proceedings herein provided, “All cases filed under subdivision (3) of section 43-247 shall have an adjudication hearing not more than ninety…”
In Re Interest of Azia B., 626 N.W.2d 602 (Neb. Ct. App. 2001). · cites it 4× “Finally, in its decision to deny Monique's request to participate in the termination hearing via telephone, the juvenile court relied, at least in part, upon Neb.Rev.Stat. § 43-278 (Reissue 1998), which the juvenile court interpreted to prohibit telephonic testimony in…”
In re Interest of A.A., 307 Neb. 817 (Neb. 2020). · cites it 2× “We note that successful appeals challenging orders of adju- dication would eliminate a juvenile court’s jurisdiction over the juvenile and its power to issue permanent dispositional orders, while successful appeals from temporary placement orders would not.”
In Re Interest of Brianna B., 614 N.W.2d 790 (Neb. Ct. App. 2000). · cites it 5× “Scott and Michelle asserted that the case warranted dismissal for lack of prosecution and argued that Neb. Rev. Stat. § 43-278 (Reissue 1998) required adjudication be completed within 90 days of the date of filing of the petition.”
In re Interest of Cassandra B. & Moira B., 290 Neb. 619 (Neb. 2015). · cites it 2× “17 As we have noted above, this includes the parents’ fundamental liberty interest in directing the education of their children.”
In Re Interest of Brittany C., 693 N.W.2d 592 (Neb. Ct. App. 2005). · cites it 2× “was decided, Neb. Rev. Stat. § 43-278 (Reissue 1988), specified that an adjudication hearing had to be held no later than 6 months after the petition was filed.”
Randall v. Dep't of Motor Vehs., 632 N.W.2d 799 (Neb. Ct. App. 2001). · cites it 3× “2d 138 (1990), the Nebraska Supreme Court determined that the use of the word “shall” in Neb. Rev. Stat. § 43-278 (Reissue 1988), which directs that an adjudication hearing be held within 6 months after a petition is filed, was directory and not mandatory.”
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