Where a sentencing judge reduces the total head sentence on account of the principle of totality but does not specify how the reduction is to be allocated to individual sentences, the appeal court may adjust the individual sentences to reflect the totality reduction while confirming the total sentence. The strength of the prosecution case remains a relevant factor in assessing the discount for a guilty plea. Where child pornography is produced in the course of sexual offending against the same victim, there is a strong argument for partial concurrency, but the ultimate question on appeal is whether the overall sentence is manifestly excessive.
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