The case confirms that citing two comparable cases where lesser sentences were imposed does not establish manifest excess, even where the sentencing judge found those cases 'of assistance'. A finding that comparable cases are 'of assistance' does not mean they set the standard against which other sentences must be judged. On parity, the threshold remains a 'marked' or 'clearly unjustifiable' disparity, and appellate courts will have regard to the qualitative and discretionary judgments required of the primary judge in drawing distinctions between co-offenders.
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