The totality principle does not require reduction of cumulative sentences merely because the aggregate is crushing in its effect; where the offending is sufficiently serious and the offender has demonstrated a determination to continue offending, the aggregate may be a just and appropriate measure of the total criminality even if it exceeds the offender's life expectancy. An offender who escaped detection for decades cannot claim the same leniency on account of age as one who was promptly convicted. However, White J's dissent provides a framework for arguing that deferred cumulative sentences should account for the deterrent and rehabilitative effect of sentences already being served.
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