Keeping Up Is Hard to Do:
A Trial Judge’s Reading Blog

R. v. McKnight, 2023 ABCA 72, March 1, 2023, at paragraph 35:

Where consecutive sentences are imposed, the trial judge is obliged to look at the total sentence to ensure that it is not unduly long or harsh: s. 718.2(c). That does not mean, however, that all consecutive sentences must be reduced for totality; the totality principle does not call for an automatic “scrolling down” whenever consecutive sentences are imposed: R. v Parranto2019 ABCA 457 at para. 67, 98 Alta LR (6th) 114, affirmed on other grounds R. v Parranto2021 SCC 46, 31 Alta LR (7th) 213. Totality is a manifestation of the principle of proportionality, and at the end of the day the total sentence should be proportionate to the gravity of the multiple offences and the moral responsibility of the offender: R. v May2012 ABCA 213 at para. 7, 75 Alta LR (5th) 135. Totality also engages the principle of restraint, and must also have regard to the prospect of rehabilitation, balanced against leaving the impression the accused got a “free ride” on the subsequent offences in the series: Parranto at para. 67. Where all these factors are considered, the conclusion may be that the total consecutive sentences are in fact proportionate, and no downward reduction is required.