State v. Dill, 300 Neb. 344

Jesse M. Dill pleaded no contest to a Class IIIA felony and received a determinate 1-year prison term followed by 18 months of postrelease supervision.
The district court ordered fees tied to postrelease supervision: $30 one-time enrollment fee, $25 monthly programming fee, $5 monthly chemical-testing fee, and payment for evaluations/counseling ordered by the supervision officer.
At sentencing, Dill’s counsel objected to the fees, asserting Dill had previously been found indigent and no new assessment of ability to pay had been made; the court overruled those objections.
Dill preserved the objection at sentencing and appealed solely challenging the imposition of postrelease supervision fees and related costs.
The Nebraska Supreme Court treated postrelease supervision as a form of probation and reviewed the district court’s sentence for abuse of discretion.

Issue	Plaintiff's Argument (Dill)	Defendant's Argument (State)	Held
Whether the district court abused its discretion by imposing postrelease supervision fees and costs	Fees are excessive and constitute a de facto fine; Dill lacks ability to pay given prior indigency finding	Fees are authorized by statute and rule; Dill failed to tie claims of inability to pay to the record	Court affirmed: no abuse of discretion; fees are statutorily authorized and subject to future waiver/reassessment
Whether the court improperly delegated authority to probation officer to require evaluations/treatment	(Argued in brief) Delegation to PO was improper	State did not concede; delegation consistent with statutory scheme and rules	Not considered on appeal because Dill did not assign this as error

State v. Hunt, 299 Neb. 573 (discusses postrelease supervision framework)
State v. Kennedy, 299 Neb. 362 (postrelease supervision treated as form of probation)
State v. Phillips, 297 Neb. 469 (waiver/ preservation principles for postrelease conditions)
State v. Rieger, 286 Neb. 788 (courts may impose probation conditions authorized by statute)
State v. Edwards, 278 Neb. 55 (requirement to annotate factual assertions to record on appeal)
State v. Chacon, 296 Neb. 203 (assignment and argument rules for appellate review)
State v. Jedlicka, 297 Neb. 276 (appellate courts do not consider errors argued but not assigned)