Background
Maria E. Mines, now known as Maria E. Ahrens, and Brody A. Prante-Ballue are the unmarried parents of Oliver, born in 2021. After Maria and Oliver moved from western Nebraska to Nebraska City in November 2022, Maria filed an action in November 2024 seeking to establish paternity, custody, parenting time, and child support. Brody represented himself and had not filed an answer by the October 2025 trial.
The district court found Brody to be Oliver’s father and found both parents fit. It awarded the parents joint legal custody, with Maria having final authority over education, but awarded Maria physical custody because the parents lived too far apart for joint physical custody. Brody received one weekend of parenting time per month during the school year and two months during the summer, and he was ordered to pay $390 per month in child support. The court denied his motion to alter or amend, and he appealed.
The Court’s Holding
The Nebraska Court of Appeals affirmed. Brody did not file a bill of exceptions, so the appellate court could consider only the pleadings together with the district court’s judgment. Without a record of the evidence presented at trial, the court was required to presume that the evidence supported the district court’s factual findings and judgment. That limitation prevented review of Brody’s challenges concerning the children’s best interests, the evidentiary record and rulings, witness appearances, schooling, relocation, finances, and cumulative error.
The court declined to review Brody’s claim that service requirements impaired his ability to respond because his brief offered only conclusory factual summaries, without a coherent legal argument, transcript citations, or supporting authority. It also held that his challenge to the temporary custody order was moot because the permanent custody order had replaced it. Based on the limited record and briefing, the court declined to review any assigned error and affirmed the judgment.
Key Takeaways
- An appellant bears responsibility for providing a bill of exceptions containing the evidence necessary to review claimed trial-court errors.
- Without a bill of exceptions, a Nebraska appellate court generally presumes that the evidence supports the trial court’s factual findings and judgment.
- Merely assigning an error is insufficient; the appellant must support it with a coherent analytical argument.
- A challenge to a temporary custody order becomes moot once a permanent custody order replaces it.
Why It Matters
The decision underscores that appellate review depends on both an adequate record and adequately developed briefing, even when a litigant is self-represented. Claims involving custody, evidence, relocation, and finances ordinarily require the trial record; without it, the appellate court cannot reassess what occurred below.
The opinion also distinguishes between unreviewable fact-dependent claims, an inadequately argued procedural claim, and a moot challenge to temporary relief. The affirmance rested on those appellate limitations, not on a substantive appellate determination that each challenged custody or support ruling was independently correct.