State v. Phillips, 297 Neb. 469

Phillips previously convicted of third-degree sexual assault of a child and was a 25-year SORA registrant required to register his address.
After release, Phillips provided a fictitious Sarpy County address, later found to be living elsewhere and never reported the new address to law enforcement.
He pled no contest to failure to register (Class IIIA felony) and was sentenced to 12 months imprisonment and 12 months postrelease supervision.
The district court imposed extensive supervision conditions (employment/treatment, residence reporting, searches, drug/alcohol testing, internet and electronic-device restrictions, bans on pornography, polygraphs, fees, and modifiability of conditions).
Phillips appealed, arguing his prison sentence was excessive and multiple postrelease supervision conditions were unconstitutional (First Amendment, Fourth Amendment, Due Process, Ex Post Facto, and not reasonably related to rehabilitation).
The Supreme Court affirmed, concluding the prison term was within statutory limits and not an abuse of discretion, and that Phillips waived most challenges to the supervision conditions by failing to raise specific objections at sentencing.

Issue	Phillips' Argument	State's Argument	Held
Whether 12-month imprisonment was excessive	Sentence disproportionate given limited criminal history	Sentence within statutory range and justified by SORA violation and prior sexual-assault conviction	Affirmed — within statutory limits; no abuse of discretion
Validity of postrelease supervision and its duration	Some conditions unconstitutional and overly broad	Postrelease supervision authorized by statute; conditions permissible and modifiable	Court: PRS lawful; duration permissible
Constitutionality of specific supervision conditions (speech, internet, searches, etc.)	Conditions violate First, Fourth, Due Process, Ex Post Facto, and not related to rehabilitation	Conditions tailored to risk/rehabilitation and authorized by statute/regulations	Phillips waived most challenges by not raising specific objections at sentencing; conditions not addressed on merits
Whether defendant preserved objections (waiver)	Denied signing attestation shows lack of consent; preserved error	Defendant received notice and chance to object but failed to specify issues at hearing	Held waiver — defendant adequately informed and did not articulate specific objections, so claims largely forfeited

State v. Dixon, 286 Neb. 334, 837 N.W.2d 496 (2013) (standards for appellate review of sentencing within statutory limits)
State v. Dominguez, 290 Neb. 477, 860 N.W.2d 732 (2015) (factors for sentencing consideration)
State v. Marrs, 272 Neb. 573, 723 N.W.2d 499 (2006) (waiver and preservation principles in sentencing context)
State v. Loding, 296 Neb. 670, 895 N.W.2d 669 (2017) (recent sentencing authority referenced)