Differences in role and culpability between co-offenders in a drug importation enterprise — particularly the distinction between a financier role and subordinate delivery/assistance roles — can justify significant differential sentences without breaching the parity principle. An appellate court should be cautious about finding manifest disparity where an experienced judge has sentenced multiple co-offenders in the same enterprise. Even where arguable disparity exists on an individual charge, leave to appeal may be refused where no reduction in total effective sentence would result.
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