R. v. Knauff, 2023 BCCA 174, April 19, 2023, at paragraph 27:
It is an error in principle to treat post-offence convictions as an aggravating factor warranting the imposition of a harsher sentence: R. v. Pete, 2019 BCCA 244 at para. 40. It is, however, permissible for a sentencing judge to have regard to an offender’s post-offence conduct for the limited purpose of assessing their rehabilitative prospects, and determining whether a community-based disposition would not endanger the safety of the public and be consistent with the fundamental purpose and principles of sentencing set out in the Code: R. v. Wilson, 2020 ONCA 3 at para. 67; R. v. M.(R.), 2020 ONCA 231 at paras. 35–37.