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the inference that the appellant's crime and sentence are grossly disproportionate.” Carley dissents on each point. Pascarella v. State, 294 Ga.App. 414, 669 S.E.2d 216 (November 6, 2008). Defendant’s sentence for conspiracy to commit armed robbery wasn’t cruel and unusual. “‘A presumption arises when a defendant is sentenced within the statutory limits set by the legislature that such sentence does not violate the Eighth Amendment's guarantee against cruel and unusual punishment. Such presumption remains until a defendant sets forth a factual predicate showing that such legislatively authorized punishment was so overly severe or excessive in proportion to the offense as to shock the conscience. Burgos v. State, 233 Ga.App. 897, 902 n. 2(3), 505 S.E.2d 543 (1998) (citation omitted). Pascarella's ten-year sentence fell within the statutory limits set by the legislature for conspiracy to commit armed robbery.” Fact that defendant was 15 years old not factored into Court of Appeals’ rationale. Accord, Windhom v. State , 326 Ga.App. 212, 756 S.E.2d 296 (March 13, 2014); Taylor v. State , 331 Ga.App. 577, 771 S.E.2d 224 (March 26, 2015). Bennett v. State, 292 Ga.App. 382, 665 S.E.2d 365 (June 18, 2008). Defendant’s sentence for sexual exploitation of children was not cruel and unusual punishment, despite defendant’s assertion “that, as a duplicator of child pornography, he should not be sentenced as harshly as one who creates it.” “Georgia’s law governing the sexual exploitation of children was adopted by our Legislature and codified in OCGA § 16-12-100. That statute provides that ‘[i]t is unlawful for any person knowingly to create [or] reproduce ... any visual medium which depicts a minor or a portion of a minor’s body engaged in any sexually explicit conduct.’ OCGA § 16-12-100(b)(5). The statute represents the state’s compelling interest ‘in safeguarding the physical and psychological well-being’ of minor children by protecting them from being subjects of pornography, which is obviously ‘harmful to [their] psychological, emotional, and mental health.’ Aman v. State, 261 Ga. 669, 670(1)(b) (409 S.E.2d 645) (1991). The Legislature intended for the statute to decrease the production of child pornography not only by penalizing those who make it, but also those who possess and view it. Id. Consequently, any violation of the statute is punishable by a prison sentence ranging from 5 to 20 years. OCGA § 16-12-100(g)(1). … It is irrelevant under the terms of the statute whether he created or merely duplicated the images.” Separate count for each of 24 photos also was authorized by statute. “We simply reject Bennett’s assertion that his crimes should ‘be deemed a single impulse.’” Armour v. State, 292 Ga.App. 111, 663 S.E.2d 367 (May 8, 2008). Defendant’s sentence of ten years’ incarceration for attempted burglary was not excessive, although it was her first conviction and her two co-defendants were arguably more culpable. “‘This court will not disturb a sentence within the statutory limits.’ Scott v. State, 240 Ga.App. 586, 588(3) (524 S.E.2d 287) (1999).” Howell v. State, 283 Ga. 24, 656 S.E.2d 511 (January 28, 2008). Adopts new test for civil forfeitures , based on von Hofe v. United States, 492 F.3d 175, 186 (2d Cir., 2007) ( which is in turn based on United States v. Bajakajian, 524 U.S. 321, 334 (118 S.Ct. 2028, 141 L.Ed.2d 314) (1998) (“a punitive forfeiture violates the Excessive Fines Clause if it is grossly disproportional to the gravity of a defendant's offense.”): “We ... frame our excessiveness inquiry in terms of the following considerations: (1) the harshness, or gross disproportionality, of the forfeiture in comparison to the gravity of the offense, giving due regard to (a) the offense committed and its relation to other criminal activity, (b) whether the claimant falls within the class of persons for whom the statute was designed, (c) the punishments available, and (d) the harm caused by the claimant’s conduct; (2) the nexus between the property and the criminal offenses, including the deliberate nature of the use and the temporal and spatial extent of the use; and (3) the culpability of each claimant.” Here, Howell owned property where a repeat drug offender was growing over 80 marijuana plants. Trial court properly found that the forfeiture of the property, valued at $39,000 was not disproportionate, based on the seriousness of the crime committed; and Howell’s “willful blindness” to the offense being committed on her property; the fact that Howell is not otherwise subject to any penalty for her wrongful conduct. Further, fact that the grower deeded the property to Howell by gift, but still controlled the property, “supported the trial court’s finding that Howell held the property for Pounds, the person whose conduct gave rise to the forfeiture. Salem v. State, 232 Ga.App. 886(1) (503 S.E.2d 62) (1998).” Supersedes prior three-factor test set out in Thorp v. State , 264 Ga. 712(1), 450 S.E.2d 416 (1994), which the Court here says is “not inconsistent … but is not as complete.” Humphrey v. Wilson, 282 Ga. 520, 652 S.E.2d 501 (October 26, 2007). Habeas court properly ruled that defendant’s sentence for aggravated child molestation (consensual oral sex with another teenager) was cruel and unusual, in light of subsequent statutory change reducing the charge from a felony with minimum 10 year sentence to a misdemeanor. “At the time of Wilson’s trial, the minimum sentence for a conviction of aggravated child molestation was ten years in prison with no possibility of probation or parole; the maximum sentence was thirty years in prison. [fn] The trial court sentenced Wilson to eleven years, ten to serve and one year on probation. In addition to the foregoing