State v. Phillips, 297 Neb. 469

Christian E. Phillips, a 25-year registrant under Nebraska's Sex Offender Registration Act (SORA) based on a 2013 conviction for third-degree sexual assault of a child, failed to properly register his residence.
He pled no contest to a Class IIIA felony for failing to register and was sentenced to 12 months’ imprisonment and 12 months’ postrelease supervision. He served 6 months and was released to supervision with credit for good time.
The district court’s postrelease supervision order contained numerous conditions (employment, reporting, searches, drug/alcohol testing, internet and electronic-device restrictions, bans on pornography, polygraphs, fees, etc.) and allowed the court or supervising officer to modify conditions.
Phillips objected on the record to signing an agreement to the conditions but only acknowledged receipt; he did not specify particular constitutional objections at sentencing. He later appealed claiming his sentence was excessive and several supervision conditions were unconstitutional (First Amendment, Ex Post Facto, Fourth Amendment, Due Process, and not reasonably related to rehabilitation).
The State argued Phillips waived many objections by failing to specifically raise them at sentencing and that postrelease supervision and its conditions were authorized by statute and court rules.

Issue	Phillips' Argument	State's Argument	Held
Whether 12-month imprisonment was excessive	1-year term is excessive given limited criminal history	Sentence within statutory range and justified by SORA-related sexual-assault history and failure to comply	Court: No abuse of discretion; sentence not excessive
Whether postrelease supervision and its duration were proper	Argued conditions and supervision unlawful/excessive	Statutes authorize determinate sentence plus postrelease supervision up to statutory limit	Court: Imposition of 12 months postrelease supervision proper under statute and court rule
Whether specific supervision conditions violated constitutional protections (First, Ex Post Facto, Fourth, Due Process)	Challenged many conditions as unconstitutional and not related to rehabilitation	Conditions fall within statutory/rule-authorized scope; defendant waived many objections by failing to identify them at sentencing	Court: Conditions not preserved for review (waiver); no reversible error identified
Whether Phillips waived challenges to conditions by not adequately objecting at sentencing	Phillips claims he refused to agree and thus preserved issues	State: Phillips acknowledged receiving conditions but did not specify objections, so waived	Court: Phillips had notice and opportunity to object but failed to specify concerns; objections waived

State v. Dixon, 286 Neb. 334 (discusses sentencing review and abuse-of-discretion standard)
State v. Dominguez, 290 Neb. 477 (addresses sentencing factors and postrelease supervision context)
State v. Marrs, 272 Neb. 573 (procedure on preservation of sentencing issues)
State v. Loding, 296 Neb. 670 (recent sentencing precedent referenced)