Sentences of 10 years (after trial) and 8 years (on guilty plea) for trafficking in approximately 860 grams of heroin were upheld as within the appropriate range. The Court recognised an inflation in custodial sentences for drug trafficking, noting that sentences at this level which a decade earlier might have been regarded as excessive are now within range due to hardening community attitudes. Responsible conduct of a trial with concessions is at least relevant to sentencing even where a not guilty plea is entered.
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