State v. Phillips, 297 Neb. 469

Christian E. Phillips was convicted in 2013 of third-degree sexual assault of a child and, as a result, was a 25-year registrant under Nebraska's Sex Offender Registration Act (SORA).
After release he provided a fictitious address and failed to register his actual residence, was charged with failing to register (a Class IIIA felony), pled no contest, and was sentenced to 12 months' imprisonment plus 12 months' postrelease supervision.
The district court imposed numerous postrelease supervision conditions (e.g., reporting, residence and address restrictions, searches, drug/alcohol testing, internet and electronic-device restrictions, prohibitions on pornographic materials, polygraph, fees, and possibility of modification by the court).
Phillips appealed, arguing (1) his 12-month jail sentence was excessive and (2) several supervision conditions were unconstitutional (First Amendment, Ex Post Facto, Fourth Amendment, Due Process) or not reasonably related to rehabilitation.
The State defended the sentence as within statutory limits and argued that Phillips waived his objections to the supervision conditions by not identifying specific challenges at sentencing.
The Nebraska Supreme Court considered statutory authority for postrelease supervision under the 2015 legislative scheme and relevant court rules for imposing conditions.

Issue	Phillips' Argument	State's Argument	Held
Was the 12-month imprisonment excessive?	Sentence excessive given limited criminal record.	Sentence within statutory limits for Class IIIA felony and appropriate given prior sexual-assault conviction and SORA violation.	Affirmed — not excessive; within statutory maximum and not an abuse of discretion.
Are the postrelease supervision conditions unconstitutional or unreasonable?	Several conditions violate constitutional protections and are not reasonably related to rehabilitation.	Conditions were authorized by statute/rules and Phillips waived specific objections by failing to raise them at sentencing.	Affirmed — conditions were authorized; Phillips waived preserved challenge by not specifying objections at hearing.

State v. Dixon, 286 Neb. 334 (Neb. 2013) (sentencing appellate-review principles)
State v. Dominguez, 290 Neb. 477 (Neb. 2015) (factors for sentencing and review)
State v. Marrs, 272 Neb. 573 (Neb. 2006) (waiver principles in sentencing challenges)
State v. Loding, 296 Neb. 670 (Neb. 2017) (recent sentencing authority referenced)