Where an offender has served a sentence in another State for contemporaneous offending closely related in time and character, the sentencing court must apply the totality principle by asking what the effective head sentence would have been had all offences been committed in one jurisdiction and sentenced at one time. A combined effective sentence of approximately 9 years 3 months (including 2 years 3 months served in WA) for high-level drug importation and trafficking across two states was within the available range.
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