When sentencing an offender who participated in a joint criminal enterprise, the sentencing judge must independently assess the offender's own criminality and not permit the objective seriousness of the principal offender's conduct to confuse or confound that assessment. An offender who was placed without notice in circumstances they had no opportunity to anticipate, and whose participation was limited and unplanned, is entitled to have those matters reflected in a significantly lower sentence than would be appropriate for the principal offender.
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