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Cite as 306 Neb. 710

Gem City Bone and Joint, P.C., appellee, v. 

Michael W. Meister and Michael 

W. Meister, Attorney at Law, 

P.C., L.L.O., appellants.

___ N.W.2d ___

Filed August 7, 2020. No. S-19-849.

1. Judgments: Jurisdiction: Appeal and Error. A jurisdictional question 

that does not involve a factual dispute is determined by an appellate 

court as a matter of law, which requires the appellate court to reach a 

conclusion independent of the lower court’s decision.

2. Jurisdiction: Appeal and Error. Before reaching the legal issues 

presented for review, it is the duty of an appellate court to determine 

whether it has jurisdiction over the matter before it.

3. Jurisdiction: Final Orders: Appeal and Error. For an appellate court 

to acquire jurisdiction over an appeal, there must be a final order or final 

judgment entered by the court from which the appeal is taken.

4. Judgments: Final Orders: Words and Phrases. A judgment is the 

final determination of the rights of the parties in an action.

5. ____: ____: ____. A final judgment is one that disposes of the case by 

dismissing it either before hearing is had upon the merits or after trial 

by rendition of judgment for the plaintiff or defendant. Conversely, 

every direction of a court or judge, made or entered in writing and not 

included in a judgment, is an order.

6. Judgments. An order on “summary application in an action after judgment” under Neb. Rev. Stat. § 25-1902 (Supp. 2019) is an order ruling 

on a postjudgment motion in an action.

7. Final Orders: Words and Phrases. A “substantial right” is an essential 

legal right, not a mere technical right.

8. Final Orders. A substantial right is affected if the order affects the subject matter of the litigation, such as diminishing a claim or defense that 

was available to an appellant prior to the order from which an appeal 

is taken.

Nebraska Supreme Court Online Library

www.nebraska.gov/apps-courts-epub/

10/01/2020 12:09 AM CDT
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9. ____. It is not enough that the right itself be substantial; the effect of the 

order on that right must also be substantial.

10. ____. Whether the effect of an order is substantial depends on whether 

it affects with finality the rights of the parties in the subject matter.

11. Final Orders: Appeal and Error. Most fundamentally, an order affects 

a substantial right when the right would be significantly undermined or 

irrevocably lost by postponing appellate review.

12. Foreign Judgments: Jurisdiction: Collateral Attack: Presumptions.

While it is presumed that a foreign court rendering a judgment had jurisdiction over the parties, a foreign judgment can be collaterally attacked 

by evidence that the rendering court was without such jurisdiction, so 

long as the attack is timely done within the framework of the Nebraska 

Uniform Enforcement of Foreign Judgments Act.

Appeal from the District Court for Scotts Bluff County: 

Derek C. Weimer, Judge. Judgment vacated.

Michael W. Meister for appellants.

Andrew W. Snyder, of Chaloupka, Holyoke, Snyder, 

Chaloupka & Longoria, P.C., L.L.O., for appellee.

Heavican, C.J., Miller-Lerman, Cassel, Stacy, Funke, 

Papik, and Freudenberg, JJ.

Freudenberg, J.

NATURE OF CASE

Michael W. Meister and his professional corporation, 

Michael W. Meister, Attorney at Law, P.C., L.L.O. (individually and collectively Meister), appeal from the denial of his 

motion to quash and vacate in a garnishment action, which 

sought to collaterally attack a Wyoming judgment obtained by 

Gem City Bone and Joint, P.C. (Gem City), against Meister. 

Earlier in the registration and enforcement process, Meister 

and his professional corporation challenged the foreign judgment, claiming the Wyoming court lacked personal jurisdiction to enter a judgment against either his professional 

corporation or himself, personally. The district court rejected 

their argument and permitted the registration of the foreign order. Meister and his professional corporation failed 
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to timely appeal the district court’s decision. Gem City then 

requested a garnishment to enforce the registered judgment 

against Meister individually, which prompted Meister to file a 

motion to quash the garnishment and to vacate the Wyoming 

judgment. The district court denied Meister’s motion to quash 

and vacate. Meister appeals.

BACKGROUND

Meister, an attorney in Scottsbluff, Nebraska, represented 

Alejandra Garza (Alejandra), a minor, in a personal injury matter. During the course of that representation, it was determined 

that Alejandra needed surgery. The doctor treating Alejandra 

recommended that the surgery be performed by Gem City in 

Laramie, Wyoming. Alejandra’s father signed an authorization 

for treatment and an assignment from any potential settlement 

proceeds to ensure payment of Alejandra’s surgery.

Following the surgery, but before settlement occurred, 

Alejandra’s father passed away and Alejandra obtained the 

age of majority. Upon settlement, Gem City requested the full 

amount billed for the treatment, $15,337. Meister disputed this 

billing, claiming that Gem City should have billed Medicaid 

and that Nebraska law did not permit Gem City to charge 

above the Medicaid reimbursement rate of $5,112.33.

A settlement was not reached, and Gem City pursued, in 

Wyoming, a breach of contract action against Meister and 

his professional corporation to recover the portion of the 

settlement assigned to them. Meister entered an appearance in 

Wyoming, filing a “Rule 12” motion to dismiss for (1) lack 

of subject matter jurisdiction, (2) lack of personal jurisdiction, (3) improper venue, and (4) failure to state a claim upon 

which relief can be granted. Before the motion was ruled 

upon, Meister withdrew the lack of venue and subject matter claims.

Gem City’s jurisdictional allegations are contained in the 

pleadings of the original Wyoming action. Such allegations 

asserted that the assignment to Gem City has Meister’s name 

listed as the attorney of record. The signature block contains 
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a stamp for “Michael Meister,” and the assignment was faxed 

from Meister’s professional corporation’s office in Scottsbluff 

to Gem City. It is further asserted that after receiving the settlement money on the original claim, Meister sent emails to negotiate payment with Gem City. Gem City claims that Meister 

and his professional corporation’s involvement in the assignment and the negotiation emails qualify as directed activities 

and that Meister and his professional corporation should have 

expected to be sued in Wyoming in the event of a breach. 

In addition, Gem City pleads that personal jurisdiction over 

Meister and his professional corporation was proper because 

Meister acted in both a personal and professional capacity in 

representing his client.

There was a hearing on the jurisdiction issue in Wyoming, 

but the record does not show that any evidence was produced. The district court in Wyoming denied Meister and 

his professional corporation’s motion and proceeded to trial. 

Neither Meister nor his professional corporation appeared, and 

the Wyoming court entered default judgment against Meister 

and his professional corporation, jointly and severally. The 

Wyoming judgment was not appealed.

Gem City submitted the Wyoming judgment for filing in the 

district court for Scotts Bluff County pursuant to Neb. Rev. 

Stat. § 25-1587.03 (Reissue 2016) of the Nebraska Uniform 

Enforcement of Foreign Judgments Act (NUEFJA). 1 Meister 

and his professional corporation first responded by making 

a motion to dismiss, claiming that the applicant is not an 

attorney licensed to practice in the State of Nebraska and that 

the foreign judgment creditor is a professional corporation. 

This motion was overruled. Shortly thereafter, Meister and his 

professional corporation filed a pleading entitled “Response 

to Foreign Judgment,” where they again raised the issue of 

personal jurisdiction. They claimed that Meister and his professional corporation lacked sufficient contacts with the State 

1 Neb. Rev. Stat. §§ 25-1587.01 to 25-1587.09 (Reissue 2016 & Cum. Supp. 

2018).
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of Wyoming and that “the court lacked jurisdiction, such to 

offend the due process clause of the fourteenth amendment.” 

The pleading sought the vacation of the foreign judgment.

Following a hearing in which both parties presented evidence, the district court rejected Meister and his professional 

corporation’s argument and found that they had failed to rebut 

the presumption that the Wyoming court had personal jurisdiction. 2 The district court entered an order overruling Meister 

and his professional corporation’s request to vacate, which the 

court referred to as “overruling their motion to dismiss,” and 

permitted the registration of the Wyoming judgment on March 

25, 2019. In the order, the district court made no distinctions between Meister as an individual and Meister’s professional corporation.

An appeal was filed on April 25, 2019. However, the 

Nebraska Court of Appeals determined that the appeal was 

untimely and dismissed it pursuant to Neb. Ct. R. App. P. 

§ 2-107(A)(2) (rev. 2017).

After registering the judgment, the district court ordered 

garnishment against Meister personally. There is nothing in the 

record showing Gem City pursued collection efforts against 

Meister’s professional corporation following the registration of 

the Wyoming judgment. Meister moved to quash the garnishment and vacate the “judgment registered in the above captioned matter.” Once again, Meister raised the argument that 

the Wyoming court did not have personal jurisdiction over him. 

Meister also argued that because he had legitimate defenses 

to the default judgment in Wyoming, the court should vacate 

the entry of the foreign judgment and allow him to raise his 

defenses in an action in Nebraska. 3

The district court overruled Meister’s motions to quash 

and vacate on August 19, 2019, reasoning Neb. Rev. Stat. 

§ 25-2001 (Reissue 2016) does not give Nebraska courts the 

2 See, Olson v. England, 206 Neb. 256, 292 N.W.2d 48 (1980); Repp v. 

Repp, 156 Neb. 45, 54 N.W.2d 238 (1952).

3 See Miller v. Steichen, 268 Neb. 328, 682 N.W.2d 702 (2004).
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authority to vacate the judgment of a court in a sister state. 

It also noted that Meister had an opportunity to appeal the 

order registering the foreign judgment but had failed to timely 

do so.

On August 21, 2019, the district court entered an order for 

Meister’s property to be delivered to the court. On September 

5, Meister filed a notice of appeal.

ASSIGNMENTS OF ERROR

Meister assigns that the district court erred by finding that 

the Wyoming court had personal jurisdiction over Meister and 

his professional corporation. He also assigns as error the failure by the district court to treat the judgment like a Nebraska 

judgment, which can be vacated where there is a valid defense 

to the judgment and the judgment was entered as a default 

judgment rather than a judgment entered on the merits. 4

STANDARD OF REVIEW

[1] A jurisdictional question that does not involve a factual 

dispute is determined by an appellate court as a matter of law, 

which requires the appellate court to reach a conclusion independent of the lower court’s decision. 5

ANALYSIS

[2,3] As a preliminary matter, we must determine whether 

this appeal is properly before the court as a final order or judgment. Before reaching the legal issues presented for review, it 

is the duty of an appellate court to determine whether it has 

jurisdiction over the matter before it. 6 For an appellate court to 

acquire jurisdiction over an appeal, there must be a final order 

or final judgment entered by the court from which the appeal 

is taken. 7

4 See id.

5 Green v. Seiffert, 304 Neb. 212, 933 N.W.2d 590 (2019).

6 In re Adoption of Madysen S. et al., 293 Neb. 646, 879 N.W.2d 34 (2016).

7 Id.
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[4,5] We have explained that a judgment is the final determination of the rights of the parties in an action. 8 A final judgment is one that disposes of the case by dismissing it either 

before hearing is had upon the merits or after trial by rendition 

of judgment for the plaintiff or defendant. 9 Conversely, every 

direction of a court or judge, made or entered in writing and 

not included in a judgment, is an order. 10 The orders entered in 

a NUEFJA proceeding are not the result of a trial, nor do any 

of the orders finally decide the rights of a party in an action. 

A party registers a foreign judgment and then can pursue 

enforcement using a series of orders until the judgment is satisfied. 11 Under this definition, all of the entries by the district 

court below, executed under the same case number, are orders 

entered after the judgment is registered. Therefore, the question 

is whether we currently have before us a final order.

Neb. Rev. Stat. § 25-1902 (Supp. 2019) defines final orders 

and currently states:

(1) The following are final orders which may be 

vacated, modified, or reversed:

(a) An order affecting a substantial right in an action, 

when such order in effect determines the action and prevents a judgment;

(b) An order affecting a substantial right made during a 

special proceeding;

(c) An order affecting a substantial right made on 

summary application in an action after a judgment is 

entered[.]

First, we must determine what kind of proceeding is involved 

to determine if it fits within a subsection of § 25-1902(1). We 

find subsection (1)(c) of § 25-1902 applicable to our final 

order analysis in the present case. This type of order has two 

8 Id.

9 Id.

10 Id.

11 See §§ 25-1587.01 to 25-1587.09.
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requirements. First, it must be an order on “summary application in an action after a judgment is entered.” Second, the order 

must affect a substantial right.

We note that under a previous version of the NUEFJA, the 

registration was a separate action that ended with the registration that was a final judgment amenable to immediate appeal. 

Under the prior statutory scheme, a judgment debtor had 

30 days to respond to the registration, whereby a defendant 

could plead a lack of jurisdiction and have the registration set 

aside. 12 The court’s ruling on such challenge was determined 

upon the court’s ultimate judgment registering or refusing to 

register the foreign judgment. 13 Under the prior scheme, the 

failure to take advantage of the statutory procedure to challenge the jurisdiction of the foreign judgment before its registration resulted in a waiver of such claim and the court’s registration operated in subsequent, separate enforcement actions, 

as claim preclusion on the question of the jurisdiction of the 

foreign court. 14

In contrast, under the current version of the NUEFJA, the 

statutes no longer provide for a separate action only for the 

registration resulting in a final judgment of registration in 

which the court necessarily made a final determination of 

the foreign court’s jurisdiction. 15 Instead, once the judgment 

is registered by the clerk of the court, the creditor may then 

proceed with enforcement. Under the current scheme, the 

registration does not determine the jurisdiction of the foreign 

court; rather, the statutory scheme expressly provides that the 

registered foreign judgment is subject to the same procedures 

12 See Neb. Rev. Stat. §§ 25-1587 to 25-15,104 (Reissue 1989). See, also, 

Olson v. England, supra note 2; Schroeder v. Homestead Corp., 163 Neb. 

43, 77 N.W.2d 678 (1956).

13 See § 25-1597. See, also, Schroeder v. Homestead Corp., supra note 12.

14 See, generally, Hara v. Reichert, 287 Neb. 577, 843 N.W.2d 812 (2014); 

Schroeder v. Homestead Corp., supra note 12.

15 See §§ 25-1587.01 to 25-1587.09. See, also, Deuth v. Ratigan, 256 Neb. 

419, 590 N.W.2d 366 (1999).
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and challenges as a Nebraska judgment, which the statute contemplates will occur after its ministerial registration with the 

clerk of the court. 16

Such challenges are brought by motions challenging the 

creditor’s enforcement actions against the debtor’s assets. 17

The creditor may seek enforcement through a whole series of 

orders directing the transfer of specific property to satisfy the 

judgment while it remains enforceable. Likewise, the judgment 

debtor may make motions to stay or vacate the enforcement in 

a variety of situations. 18

[6] We have explained that an order on “‘summary application in an action after judgment’” under § 25-1902 is an 

order ruling on a postjudgment motion in an action. 19 We find 

that motions to vacate the registration of a foreign judgment 

should be treated in a similar fashion as motions challenging 

garnishment and execution under other sections of chapter 25 

of the Nebraska Revised Statutes. 20 Each motion that a debtor 

or creditor makes after a judgment is registered under the 

NUEFJA constitutes a postjudgment motion. 21 Thus, the court 

order presently appealed, ruling on Meister’s motions to vacate 

and quash, meets the first requirement to be a final order 

under § 25-1902(1)(c).

[7-11] The last step to determine if we have a final order 

is to ascertain whether a substantial right has been affected. 

A “substantial right” is an essential legal right, not a mere 

technical right. 22 A substantial right is affected if the order 

16 See § 25-1587.03.

17 See Deuth v. Ratigan, supra note 15.

18 See § 25-1587.05.

19 Heathman v. Kenney, 263 Neb. 966, 969, 644 N.W.2d 558, 561 (2002).

20 See Cattle Nat. Bank & Trust Co. v. Watson, 293 Neb. 943, 880 N.W.2d 

906 (2016).

21 See § 25-1587.03.

22 Simms v. Friel, 302 Neb. 1, 921 N.W.2d 369 (2019) (citing Steven S. v. 

Mary S., 277 Neb. 124, 760 N.W.2d 28 (2009)).
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affects the subject matter of the litigation, such as diminishing a claim or defense that was available to an appellant prior 

to the order from which an appeal is taken. 23 It is not enough 

that the right itself be substantial; the effect of the order on 

that right must also be substantial. 24 Whether the effect of an 

order is substantial depends on whether it affects with finality 

the rights of the parties in the subject matter. 25 Most fundamentally, an order affects a substantial right when the right would 

be significantly undermined or irrevocably lost by postponing 

appellate review. 26

In the present case, we have a series of orders ruling upon 

motions that Meister made to challenge the registration of the 

Wyoming judgment. Subsequently, the court issued an order 

overruling Meister’s motions to quash and vacate the garnishment of his property, which Meister appealed. We hold that 

orders denying motions to vacate a foreign judgment affect a 

substantial right. Once the court ordered the garnishment of his 

bank account, forcing Meister to postpone his appeal from such 

order would significantly undermine his right to the use and 

enjoyment of his property. Thus, we have held in other cases 

that an order to quash a garnishment clearly affects a substantial right. 27 We find that the court order denying the motion to 

quash and vacate was a final order pursuant to § 25-1902(1)(c) 

and that Meister has timely appealed the matter to this court. 

Therefore, we have jurisdiction over this appeal.

Although the court had previously determined Meister’s 

jurisdictional challenge in ruling on a previous motion to 

23 Id.

24 Simms v. Friel, supra note 22. See, also, Cano v. Walker, 297 Neb. 580, 

901 N.W.2d 251 (2017).

25 Id.

26 Simms v. Friel, supra note 22. See, also, Tilson v. Tilson, 299 Neb. 64, 907 

N.W.2d 31 (2018).

27 See Shawn E. on behalf of Grace E. v. Diane S., 300 Neb. 289, 912 

N.W.2d 920 (2018). See, also, Western Ethanol Co. v. Midwest Renewable 

Energy, 305 Neb. 1, 938 N.W.2d 329 (2020).
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vacate, and Meister failed to timely appeal that order, Meister 

is not bound by the court’s prior determination. The doctrines 

of issue and claim preclusion do not apply to orders issued 

in the same proceedings. 28 We have explained that both issue 

and claim preclusion are triggered only when there are successive suits dealing with the same claim(s) or issue(s) between 

the same parties or related parties. 29 In the present case, we 

have successive orders issued by the same court in the same 

case. We also note that issue and claim preclusion are matters that ordinarily must be timely raised as a defense by the 

opposing party or else they are waived. 30 At no point below 

did Gem City raise in response to Meister’s motion to quash 

and vacate the defense of issue or claim preclusion. We find 

that Meister is not barred from litigating in this appeal the 

question of whether the Wyoming judgment is void for lack 

of jurisdiction.

Meister’s Personal Jurisdiction 

Challenge

Having determined that the district court’s order authorizing 

the garnishment of Meister’s personal bank account is properly 

before us, we turn to Meister’s assignments of error. Meister 

contends, first, that the district court for Scotts Bluff County 

failed to find as a matter of law that the Wyoming court was 

without jurisdiction. Second, Meister contends that if registration was proper, the court should vacate the registration 

and Meister should receive a trial on the merits, pursuant to 

Miller v. Steichen.

 31 We conclude that the Wyoming court was 

without personal jurisdiction over Meister as an individual, and 

because the Wyoming judgment is void against Meister as an 

28 See Money v. Tyrrell Flowers, 275 Neb. 602, 748 N.W.2d 49 (2008).

29 See id.

30 See Ballard v. Union Pacific RR. Co., 279 Neb. 638, 781 N.W.2d 47 

(2010). See, also, DeCosta Sporting Goods, Inc. v. Kirkland, 210 Neb. 

815, 316 N.W.2d 772 (1982).

31 See Miller v. Steichen, supra note 3.
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individual, we need not address Meister’s second assignment 

of error.

[12] While it is presumed that a foreign court rendering a 

judgment had jurisdiction over the parties, a foreign judgment 

can be collaterally attacked by evidence that the rendering 

court was without such jurisdiction, so long as the attack is 

timely done within the framework of the NUEFJA. 32 We note 

that the jurisdictional question on appeal applies solely to 

Meister as an individual, because the August 21, 2019, order 

for garnishment was of Meister’s personal bank account. We 

decline to address the hypothetical question of whether jurisdiction would be proper over Meister’s professional corporation, because such issue is not currently before us.

The Wyoming court’s exercise of jurisdiction comes from 

Wyo. Stat. Ann. § 5-1-107 (2019), which provides: “(a) A 

Wyoming court may exercise jurisdiction on any basis not 

inconsistent with the Wyoming or United States constitution.” 

Thus, Wyoming courts have adopted the personal jurisdiction framework created by federal precedent. 33 That framework focuses on the limitations to jurisdiction under the 

Due Process Clause of the 14th Amendment to the U.S. 

Constitution.

The Due Process Clause authorizes personal jurisdiction 

if two elements are met. First, a defendant must have “purposefully established ‘minimum contacts’ within the forum 

State.” 34 Second, the assertion of personal jurisdiction must 

comport with traditional notions of fair play and substantial justice. 35

32 First Fed. Sav. & Loan Assn. v. Wyant, 238 Neb. 741, 472 N.W.2d 386 

(1991).

33 See, O’Bryan v. McDonald, 952 P.2d 636 (Wyo. 1998); Markby v. St. 

Anthony Hosp. Systems, 647 P.2d 1068 (Wyo. 1982).

34 See Burger King Corp. v. Rudzewicz, 471 U.S. 462, 474, 105 S. Ct. 2174, 

85 L. Ed. 2d 528 (1985) (citing Internat. Shoe Co. v. Washington, 326 U.S. 

310, 66 S. Ct. 154, 90 L. Ed. 95 (1945)).

35 See id.
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Wyoming has adopted a three-part test for personal jurisdiction under these principles: (1) The defendant must purposefully avail himself of the privilege of acting in the forum state 

or of causing important consequences in that state, (2) the 

cause of action must arise from the consequences in the forum 

state of the defendant’s activities, and (3) the activities of the 

defendant or the consequences of those activities must have a 

substantial enough connection with the forum state to make the 

exercise of jurisdiction reasonable. 36

Gem City brought the original action against Meister, individually, and his professional corporation. For jurisdictional 

purposes, these are separate entities. 37 One of the primary purposes of incorporation is to create a separate legal entity that 

limits personal liability for the shareholders. 38 A professional 

corporation enjoys such protections as provided to other corporations under the laws of the state in which it is incorporated. 

Thus, the issue of whether the Wyoming court had jurisdiction 

over Meister’s professional corporation and over Meister personally are distinct questions.

Whether the Wyoming court had personal jurisdiction over 

Meister as an individual depends upon actions in the record 

that can be attributed to Meister personally and which satisfy 

constitutional requirements. Under the principles of corporate 

law, it is generally held that “[w]here the acts of individual 

principals of a corporation in the jurisdiction were carried out 

solely in the individuals’ corporate or representative capacity, 

the corporate structure will ordinarily insulate the individuals 

from the court’s jurisdiction.” 39 This principle prevents a court 

36 See O’Bryan v. McDonald, supra note 33.

37 See State v. Nugget Coal Co., 60 Wyo. 51, 144 P.2d 944 (1944).

38 See Wyo. Stat. Ann. §§ 17-16-101 to 17-16-1720 (2019). See, also, State 

v. Nugget Coal Co., supra note 37.

39 See Ten Mile Indus. Park v. Western Plains Service, 810 F.2d 1518, 1527 

(10th Cir. 1987). See, also, Newsome v. Gallacher, 722 F.3d 1257 (10th 

Cir. 2013).
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from exercising jurisdiction over the representatives of a corporation based on a finding that jurisdiction over the corporation is proper unless it can be shown that the facts compel the 

court to pierce the corporate veil. 40

Gem City did not plead, nor has it argued at any point in 

these proceedings, that the actions of Meister warrant the piercing of the corporate veil, so as to treat Meister’s professional 

corporation as an alter ego of Meister individually. Likewise, 

the Wyoming court gave no indication that it was applying this 

doctrine to find that jurisdiction over Meister as an individual 

was warranted. Absent such a finding from the Wyoming court, 

we must conclude that Meister’s professional corporation is a 

separate legal entity from Meister as an individual.

On the record before us, we are unable to identify any 

actions in the pleadings or at subsequent hearings that can be 

attributed to Meister as an individual, which would lead us to 

find that the Wyoming court had jurisdiction over Meister as 

an individual. All of the actions by Meister identified by the 

pleadings constitute actions by Meister’s professional corporation in the course of representing Alejandra. Neither Gem City 

nor the Wyoming court provides any precedent that imputes 

actions done in a professional capacity to an individual personally for jurisdictional purposes.

General principles of corporate law provide that the burden 

is on Gem City to show why piercing the corporate veil would 

be appropriate before jurisdiction is gained over Meister individually for the actions taken by Meister’s professional corporation. All of the communications by fax and email were done 

by Meister as an agent of his professional corporation. Gem 

City’s pleadings do not separate actions taken by Meister’s 

professional corporation and by Meister himself, and although 

there was a hearing on Meister’s motion to dismiss, no additional evidence was offered. Likewise, all of the facts recited 

by the Wyoming court in support of finding jurisdiction are 

40 See Ten Mile Indus. Park v. Western Plains Service, supra note 39.
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actions taken by Meister’s professional corporation. On these 

facts, there is not a single action in our record that can be 

attributed to Meister as an individual that would subject him to 

Wyoming jurisdiction.

In order to satisfy constitutional requirements for jurisdiction, there must be some action taken by the party that 

makes the exercise of personal jurisdiction proper. Without 

any actions taken by Meister as an individual that can satisfy the minimum contacts requirements for jurisdiction, we 

must conclude that the Wyoming court improperly exercised 

personal jurisdiction over Meister as an individual. Without 

jurisdiction, the Wyoming order is void as to Meister as an 

individual. 41 The order entered by the district court for Scotts 

Bluff County on August 21, 2019, garnishing Meister’s bank 

account must be vacated because it is based on the registration 

of a void judgment.

CONCLUSION

The only order properly before us on appeal is the August 21, 

2019, order, which garnishes Meister’s personal bank account. 

On the facts presented, we find that the Wyoming court incorrectly determined that it had jurisdiction of Meister as an individual. We make no finding as to whether there was personal 

jurisdiction over Meister’s professional corporation. Because 

we are vacating the Nebraska order garnishing Meister’s personal bank account, we need not address Meister’s second 

assignment of error.

Judgment vacated.

41 See First Fed. Sav. & Loan Assn. v. Wyant, supra note 32.