State v. Phillips, 297 Neb. 469

Christian E. Phillips was convicted in 2013 of third-degree sexual assault of a child and was required to register under Nebraska's Sex Offender Registration Act (SORA) as a 25-year registrant.
After release, Phillips reported a fictitious address and later lived elsewhere without updating his SORA registration; he was charged with failing to register (Class IIIA felony).
Phillips pled no contest pursuant to a plea agreement and was sentenced to 12 months’ imprisonment and 12 months’ postrelease supervision under the determinative-sentence/postrelease-supervision scheme enacted by L.B. 605 (2015).
The district court imposed numerous postrelease supervision conditions (e.g., restrictions on internet and electronic devices, searches, drug testing, residence/employment reporting, counseling, polygraphs, association restrictions, fees) and reserved authority to modify conditions.
Phillips appealed asserting (1) the 12-month imprisonment was excessive and (2) multiple postrelease supervision conditions were unconstitutional (First Amendment, Ex Post Facto, Fourth Amendment, Due Process) or unrelated to rehabilitation.

Issue	Phillips' Argument	State's Argument	Held
Whether 12 months imprisonment was excessive	Sentence excessive given limited criminal history	Sentence within statutory range and justified by sexual-assault conviction and failure to register	Court affirmed: within statutory limits and not an abuse of discretion
Whether postrelease supervision and conditions were improperly imposed	Conditions were unconstitutional (First, Fourth, Ex Post Facto, Due Process) and not reasonably related to rehabilitation	Court properly imposed determinate sentence + postrelease supervision under statutes and rules; conditions permissible	Court affirmed conditions in principle; Phillips waived many objections by failing to specify challenges at sentencing
Whether Phillips preserved objections to conditions	He refused to sign attestation but did not identify specific objections at hearing	Record shows he received notice and opportunity to challenge; objections were not articulated	Court held Phillips waived his challenges for failure to specify objections at sentencing

State v. Dixon, 286 Neb. 334 (general standard for reviewing alleged excessive sentences)
State v. Dominguez, 290 Neb. 477 (factors court should consider when imposing sentence)
State v. Marrs, 272 Neb. 573 (waiver principles regarding post-sentencing challenges)
State v. Loding, 296 Neb. 670 (recent sentencing precedent considered by court)