California, United States of America
The following excerpt is from People v. Fragoso, G050346 (Cal. App. 2015):
The trial court retains broad discretion in determining whether sentences are to run concurrently or consecutively. "[I]n the absence of a clear showing that its sentencing decision was arbitrary or irrational, a trial court should be presumed to have acted to achieve legitimate sentencing objectives and, accordingly, its discretionary determination to impose consecutive sentences ought not be set aside on review." (People v. Giminez (1975) 14 Cal.3d 68, 72.) In addition to the criteria articulated in California Rules of Court, rule 4.425, the trial court may consider "[a]ny circumstances in aggravation or mitigation . . . in deciding whether to impose consecutive rather than concurrent sentences." (Cal. Rules of Court, rule 4.425(b).) One of those aggravating factors is "[t]he manner in which the crime was carried out indicates planning, sophistication, or professionalism." (Cal. Rules of Court, rule 4.421(a)(8).)
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