In cases of culpable driving causing multiple deaths from a single course of driving, cumulation of only a minimal portion of the sentence on the second count may be manifestly inadequate even where the totality principle applies. The Court endorsed cumulation of 3 years (half the head sentence) on the second count as appropriate where two deaths resulted. Culpable driving causing death is a species of involuntary manslaughter and must be sentenced accordingly, with both specific and general deterrence looming large. A sentencing judge's finding that specific deterrence is unnecessary because the offender has insight into the consequences of their actions may constitute error.
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