State v. Phillips, 297 Neb. 469

Christian E. Phillips, a 25-year SORA registrant based on a 2013 conviction for third-degree sexual assault of a child, failed to register his correct address after release.
He pled no contest to failure to register under SORA (Class IIIA felony).
The district court sentenced Phillips to 12 months’ imprisonment and 12 months’ postrelease supervision.
The court imposed extensive supervisory conditions (e.g., search/monitoring, restrictions on internet and electronic devices, chemical testing, treatment, polygraph, fees, residence/employment reporting, and prohibition on pornography).
At sentencing Phillips refused to sign an attestation of agreement to conditions but signed an acknowledgment of receipt and did not specify particular objections on the record.
Phillips appealed, arguing the prison term was excessive and that multiple postrelease conditions violated the First, Fourth, and Due Process clauses and the Ex Post Facto Clause and were not reasonably related to rehabilitation.

Issue	Plaintiff's Argument (Phillips)	Defendant's Argument (State)	Held
Whether 12-month imprisonment was excessive	Sentence excessive given limited criminal history	Sentence within statutory limits and justified by failure to comply with SORA and prior sexual-assault conviction	Court affirmed: within statutory range and not an abuse of discretion
Whether postrelease supervision and conditions were authorized	Some conditions unconstitutional (1st, 4th, Ex Post Facto, Due Process)	Postrelease supervision authorized by statute; conditions imposed per statute and rules; Phillips waived preserved challenge by not specifying objections	Court: supervision and conditions were lawfully imposed; Phillips waived specific challenges by failing to articulate objections at sentencing

State v. Dixon, 286 Neb. 334 (discussing appellate review of sentences)
State v. Dominguez, 290 Neb. 477 (postrelease supervision factors and standards)
State v. Marrs, 272 Neb. 573 (waiver principles related to sentencing challenges)
State v. Loding, 296 Neb. 670 (sentencing factors and review standards)