Where interstate sentences are punctuated by a lengthy period of home detention rather than continuous custody, the cumulative impact is less harsh and the totality principle is less likely to require reduction. Offending in different states that is not of the same nature and cannot be construed as a single course of criminal conduct does not justify any element of concurrence. A sentencing judge's factual errors regarding uncharged conduct may constitute a De Simoni process error, but the appellate court may nonetheless decline to impose a different sentence if satisfied the same sentence is appropriate.
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