State v. Phillips, 900 N.W.2d 522

Defendant Christian E. Phillips was convicted in 2013 of third‑degree sexual assault of a child and therefore was a 25‑year SORA registrant.
After release, Phillips reported a fictitious Sarpy County address and later lived at a different address without notifying the sheriff; he was charged with failing to register under the Sex Offender Registration Act (SORA).
Phillips pled no contest to a Class IIIA felony SORA violation pursuant to a plea agreement.
The district court sentenced Phillips to 12 months’ imprisonment (within the 3‑year statutory maximum) and 12 months’ postrelease supervision, imposing numerous supervision conditions (e.g., restrictions on internet/electronic device use, searches, drug testing, residence reporting, fees, treatment, and monitoring).
Phillips appealed, claiming (1) his sentence was excessive and (2) several postrelease supervision conditions were unconstitutional (First Amendment, Ex Post Facto, Fourth Amendment, Due Process, and not reasonably related to rehabilitation).

Issue	Phillips' Argument	State's/Respondent's Argument	Held
Was the 12‑month imprisonment excessive?	Sentence excessive given limited criminal record	Sentence within statutory limits and appropriate given sexual‑assault conviction and failure to register	No abuse of discretion; 12 months within statutory range and not excessive
Were the postrelease supervision conditions unconstitutional?	Various conditions violated First Amendment, Ex Post Facto, Fourth Amendment, Due Process, and were unrelated to rehabilitation	Conditions authorized by statute and court followed postrelease supervision procedure; defendant waived many objections by not specifying them at sentencing	Waived: defendant had notice and opportunity to object but failed to preserve specific challenges; conditions upheld

State v. Dixon, 286 Neb. 334 (appellate review of sentence focuses on abuse of discretion)
State v. Dominguez, 290 Neb. 477 (sentencing factors and considerations)
State v. Marrs, 272 Neb. 573 (discussion of challenges to conditions and preservation)
State v. Loding, 296 Neb. 670 (context on sentencing standards)