State v. Larkins, 243 So. 3d 1220

Anthony Larkins was indicted (2013) for aggravated rape of D.W. based on events in 2003 when D.W. was ~5–6 years old; Larkins elected a bench trial and represented himself.
Victim D.W. and his sister testified Larkins repeatedly forced D.W. to perform oral sex and at times forced the siblings to remove clothing or attempt intercourse.
The mother (K.W.) reported allegations to CPS earlier; a 2007 follow-up was closed after she declined to pursue charges because she planned to move.
In 2013 police were notified again; officers interviewed the children, obtained statements, and an arrest warrant issued.
The trial court found the child witnesses credible and convicted Larkins of aggravated rape (victim under 13). He was sentenced to life without benefit of parole, probation, or suspension.
Larkins filed a pro se motion to reconsider sentence that was not ruled on; the appellate court affirmed the conviction and remanded solely to provide required written sex-offender registration notice and minute entry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support aggravated rape conviction	State: child testimony and corroboration sufficient to prove rape of a victim under 13 beyond a reasonable doubt	Larkins: testimony inconsistent; insufficient to prove guilt beyond a reasonable doubt	Conviction affirmed — viewing evidence in light most favorable to prosecution, testimony was sufficient and factfinder credibility determinations control
Trial court's failure to rule on pro se motion to reconsider sentence	State: remand unnecessary because sentence not challenged on appeal	Larkins: court must rule on outstanding motion; remand for ruling	No reversible error; failure to rule does not bar appellate review and remand not required for that reason since Larkins did not raise excessiveness; assignment lacks merit
Sex-offender registration notification (error patent)	N/A	N/A	Remanded for written notice of registration requirements and entry in court minutes per statute

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for appellate review of sufficiency of the evidence)
State v. Tate, 851 So.2d 921 (La. 2003) (applies Jackson standard in Louisiana)
State v. Pigford, 922 So.2d 517 (La. 2006) (appellate court may not substitute its view for factfinder)
State v. Casey, 775 So.2d 1022 (La. 2000) (trial court credibility determinations given deference)
State v. Smith, 661 So.2d 442 (La. 1995) (appellate court cannot reweigh evidence)
State v. Jones, 794 So.2d 107 (La. App. 2001) (single witness testimony, if believed, can support conviction)
State v. Mickens, 731 So.2d 463 (La. App. 1999) (conviction may stand absent medical/physical evidence if testimony credible)
State v. Broome, 136 So.3d 979 (La. App. 2014) (application of Jackson standard to combined direct and circumstantial evidence)
State v. Carter, 974 So.2d 181 (La. App. 2008) (sufficiency review principles)
State v. Dotie, 1 So.3d 833 (La. App. 2009) (resolving conflicts in direct evidence in favor of prosecution)