In R. v. Clarke (Ont CA, 2026) the Ontario Court of Appeal considered sentencing for armed robbery:
[19] Moreover, in our view, the fresh evidence filed does not impact the fitness of the sentence, which was on the lower end for an armed robbery conviction: R. v. Sithravel, 2023 ONCA 748; R. v. Treleaven, 2019 ONCA 593, R. v. Wolynec, 2015 ONCA 656, 330 C.C.C. (3d) 541. A seven-year sentence is the minimum sentence for a second or subsequent armed robbery pursuant to s. 344(1)(a)(ii) of the Criminal Code. This was Mr. Clarke’s eighth robbery and several of his prior convictions were armed robberies. He was on parole when he committed these offences. He was not deterred by his last sentence of eight years for armed robbery. Any reduction to account for the appellant’s pre-sentence custody conditions in the circumstances of this case would render the appellant’s sentence unfit.
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