R. v Drader, 2014 ABCA 69:
 In ascertaining what is a fit sentence, a sentencing court may make sentences concurrent or consecutive. Particularly where an accused is being sentenced for a number of offences at the same time, the principles of totality and proportionality will inform whether sentences should be consecutive or concurrent. However, as a general principle, where an accused is sentenced on separate days for completely separate events, typically the sentences should be consecutive. Otherwise, the result is that there is no effective sentence for the later offence.