The strength of the Crown case is not relevant to the utilitarian value of a guilty plea, and a sentencing judge who sets the discount at the lower end of the 10-25% range must give at least a brief, clear and simple explanation of the reasoning that led to that conclusion, particularly where the plea was entered at the earliest opportunity. Protective custody conditions, combined with rehabilitation efforts achieved under those difficult conditions, can constitute special circumstances warranting departure from the statutory ratio.
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