Nebraska Revised Statute 69-2312
Landlord retaining personal property; civil action authorized.
Any landlord who retains personal property in violation of the Disposition of Personal Property Landlord and Tenant Act shall be liable to the tenant in a civil action for:
(1) Actual damages not to exceed the value of the personal property if such property is not surrendered: (a) Within a reasonable time after the tenant requests surrender of the personal property; or (b) if the landlord has demanded payment of reasonable costs associated with removal and storage and the tenant has complied with the requirements of section 69-2311. Three days shall be presumed to be a reasonable time in the absence of evidence to the contrary; and
(2) Reasonable attorney's fees and costs.
Under this section, the phrase "value of the personal property" in its relation to "[a]ctual damages" is the fair market value of the property at the time the tenant's property is improperly detained by the landlord. Pan v. IOC Realty Specialist, 301 Neb. 256, 918 N.W.2d 273 (2018).