The Alberta Court of Appeal has stressed in numerous cases in recent years that substantial thefts committed in breach of a position of trust, usually employment, should be met with sentences of incarceration, even for first offenders: see, e.g. R v Fulcher, 2007 ABCA 381, R v McKinnon, 2005 ABCA 8, R v Bracegirdle, 2004 ABCA 252. Many of the reported cases from our Court of Appeal in which these statements of principle have been stated most firmly deal with thefts in the hundreds of thousands of dollars. Fulcher involved thefts totalling almost $300,000; R v Zenari, 2012 ABCA 279 was a fraud resulting in losses of over $225,000. Bracegirdle was a theft of over $150,000. McKinnon involved a fraud of a smaller sum of about $61,000, but McKinnon was also a fourth-time offender. As a result, arguments in favour of conditional sentence orders for accused persons committing frauds in the tens of thousands are still frequently advanced by counsel before our courts. Two cases released recently by the Court of Appeal address breach-of-trust thefts that exceed $5,000, but don't reach into [...]