Robert Owens was convicted of child molestation, attempted child molestation, enticing a child, and interference with custody after taking a fifteen-year-old from school and engaging in sexual conduct with her. He challenged the sufficiency of three interference-with-custody counts and his recidivist sentence. The Georgia Court of Appeals affirmed one interference conviction but reversed the other three because the evidence did not establish the statutory custody element for those counts. It also held that the sentence on the remaining interference count exceeded the statutory maximum and that the trial court failed to impose the required split sentences for the child-molestation and enticing convictions. The court vacated the affected sentences and remanded for resentencing consistent with Georgia’s sentencing statutes.