Muldoon v R [2026] NSWCCA 158

Muldoon v R [2026] NSWCCA 158. The Court of Criminal Appeal allowed a sentence appeal concerning three offences of recklessly dealing with proceeds of crime, with four further offences taken into account. Muldoon was already serving overlapping State and federal sentences. The key issue was totality: although the District Court’s two-year sentence did not extend his total effective term, it unintentionally delayed parole eligibility by seven months. The Court found a miscalculation of the orders’ practical effect, rather than a misunderstanding of totality. It quashed the sentence and imposed two years’ imprisonment with a non-parole period expiring on 18 September 2026. The remaining grounds were not determined.