In Galindo v. State, 481 P.3d 686 (Alaska Ct. App. 2021), the court held that Special Conditions of Probation need to be supported by the record and if there are less restrictive alternatives those should be considered by the trial court. (Id. at 690–94). Galindo was convicted of first-degree sexual assault and second-degree criminal trespass and appealed the conviction and the sentence. (Id. at 688). Galindo argued that the state failed to prove that the sexual assault was without consent, that the sentence was excessive, and that multiple Special Conditions of Probation should be overturned. (Id. at 688). The court of appeals upheld the conviction as well as the sentence. (Id. at 688–90). However, the court reversed one Special Condition of Probation for failing to set a maximum term for the residential treatment program it required Galindo to enroll in. (Id. at 690). It remanded multiple other Conditions for failing to have adequate evidence in the record to support the Condition. (Id. at 691–93). Further, it discussed how two of the conditions, which limited Galindo from possessing sexually explicit materials and adopted a definition of sexually explicit material from a statute that involved minors, implicated concerns about constitutional rights that the trial court needed to consider when reviewing the Condition. (Id. at 693–94). The court of appeals remanded the case, holding that Special Conditions of Probation need to be supported by the record and if there are less restrictive alternatives those should be considered by the trial court. (Id. at 690–94).