State v. Phillips, 297 Neb. 469

Christian E. Phillips was previously convicted (Sept. 2013) of third-degree sexual assault of a child and was a 25-year SORA registrant required to keep his registration current.
After release he provided a fictitious address and later lived at a different address without updating his SORA registration.
Phillips pled no contest to a Class IIIA felony for failure to register under SORA and was sentenced to 12 months’ imprisonment and 12 months’ postrelease supervision (PRS).
The district court’s PRS order contained numerous standard and sex-offender–specific conditions (reporting, search and seizure, internet restrictions, electronic-device/credentials disclosure, drug testing, treatment, polygraphs, fees, etc.) and allowed modification by the court or supervising officer.
Phillips appealed, arguing his prison term was excessive and that various PRS conditions violated the First, Fourth, and Due Process Clauses and the Ex Post Facto Clause, or were not reasonably related to rehabilitation.

Issue	Phillips' Argument	State's Argument	Held
Whether 12-month imprisonment was excessive	Sentence excessive given limited criminal record	Sentence within statutory limits and justified by prior sexual-assault conviction and failure to register	Court affirmed: 12 months not an abuse of discretion (within statutory range)
Whether PRS and its conditions were unauthorized	Some conditions unconstitutional (First, Fourth, Due Process, Ex Post Facto)	Court properly imposed PRS and conditions under statutes and rules	Court upheld imposition of PRS and conditions as authorized
Whether specific constitutional challenges to PRS conditions were preserved	Phillips contends conditions unconstitutional	State contends Phillips waived challenges by not articulating specific objections at sentencing	Court found Phillips was given notice and opportunity; because he did not specify objections at sentencing, he waived them
Whether sentencing court complied with postrelease supervision procedure	PRS scheme under 2015 statutes challenged as new	Court followed Neb. Ct. R. § 6-1904 and statutory authority for determinate sentence + PRS	Court concluded procedures and authority were followed and PRS properly imposed

State v. Dixon, 286 Neb. 334 (discusses standards for reviewing alleged excessive sentences)
State v. Dominguez, 290 Neb. 477 (addresses sentencing factor considerations)
State v. Marrs, 272 Neb. 573 (waiver principles related to sentencing objections)
State v. Loding, 296 Neb. 670 (general sentencing review principles)