The principles in Hogarth and Meyers requiring increased sentences for aggravated burglary apply with full force to non-confrontational aggravated burglary involving forced entry at night into occupied premises with intent to steal. Such offending is not inherently less serious than confrontational home invasion. A sentence of 3 years' imprisonment for such an offence, committed by an offender with a prior aggravated burglary conviction and extensive criminal history, is lenient rather than excessive.
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