A claim that a sentence is 'crushing' is relevant to the determination of whether a sentence is manifestly excessive but is not a standalone requirement when applying the totality principle. Where one act of criminal negligence causes multiple deaths, the proper application of the totality principle will invariably mean that an offender serves less time for the criminality pertaining to each count than would be the case had there been only one victim. The question of whether most purposes of sentencing are met by the first sentence in such cases was expressly left open. For vehicular manslaughter based on gross criminal negligence (not intent), indicative sentences must reflect that the mental element is negligence, and comparison with other vehicular manslaughter cases is permissible even where the number of victims is unprecedented.
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