State v. Craft, 162 So. 3d 539

Defendant Elton Craft pled guilty to two counts of indecent behavior with juveniles (victims aged 8 and 9) after aggravated-incest charges were dismissed in exchange for the pleas.
Prosecutor’s factual basis: Craft, more than two years older than each victim and their grandfather, committed lewd acts intended to arouse or gratify sexual desires; he threatened to kill the children and family if they disclosed the abuse.
Additional undisputed, graphic facts and victim impact testimony were placed on the record; the defendant admitted the factual basis.
At sentencing the court noted Craft’s extensive criminal history (including prior sexual-assault and child-abuse convictions), status as a third-felony offender, and his use of kinship and threats to facilitate crimes.
The trial court imposed consecutive 20-year hard-labor terms (each with 10 years to be served without benefits); the court recommended mental-health treatment and noted sex-offender registration requirements.
Defendant moved to reconsider as excessive; motion denied. He appealed asserting excessiveness and that shorter incarceration plus treatment would meet societal goals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 20-year consecutive sentences (with 10 years without benefits each) are excessive	State: sentence justified by the gravity of offenses, threats, use of kinship, extensive criminal history, and benefit from dismissal of aggravated-incest counts	Craft: age, health problems, alcoholism, need for treatment, and sex-offender registration mean shorter incarceration with treatment would suffice	Affirmed: trial court complied with La. C. Cr. P. art. 894.1; sentences not grossly disproportionate or constitutionally excessive
Whether consecutive sentences were an abuse of discretion	State: consecutive terms appropriate given separate, permanent injury to each victim and offender’s record	Craft: consecutive terms result in excessive total punishment given his circumstances	Affirmed: court adequately considered factors for consecutive sentences and justification supports consecutive terms

Boykin v. Alabama, 395 U.S. 238 (guilty plea voluntary-admission standard)
State v. Smith, 433 So.2d 688 (La. 1983) (appellate review — sentencing must show consideration of La. C.Cr.P. art. 894.1 factors)
State v. Jones, 398 So.2d 1049 (La. 1981) (elements to consider in sentencing: personal history, prior record, seriousness, rehabilitation)
State v. Dorthey, 623 So.2d 1276 (La. 1993) (sentence unconstitutional if grossly disproportionate)
State v. Bonanno, 384 So.2d 355 (La. 1980) (excessive-sentence principles)
State v. Black, 669 So.2d 667 (La. App. 2d Cir.) (broad trial court discretion within statutory limits)
State v. Slocum, 26 So.3d 926 (La. App. 2d Cir.) (maximum/near-maximum reserved for most serious offenders)
State v. Ortego, 382 So.2d 921 (La. App.) (criminal history relevant to consecutive sentences)
State v. Jett, 419 So.2d 844 (La. App.) (danger to public considered for consecutive terms)