The totality principle requires that when a defendant is sentenced for multiple crimes, the total sentence must be proportionate to the total criminality, and as a guide, the greater the length of the total sentences imposed, the more likely it is that the totality principle will require a reduction or a degree of concurrency. A combined starting point of 16 years for two counts of trafficking in 5.7 kg and 12.6 kg of cannabis by an intermediary was held disproportionate. When differential guilty plea discounts apply, totality adjustments are preferably made by reduction of individual sentences rather than partial concurrency.
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