RCW 9.94a.535(2)(I) Interpretation
In State v. Fisher, 108 Wn.2d 419, 427-29, 739 P.2d 683 (1987), the Court held that it is appropriate to rely on RCW 9.94A.535(2)(i) for an exceptional sentence "when there is some extraordinarily serious harm or culpability resulting from multiple offenses which would not otherwise be accounted for in determining the presumptive sentencing range".
The interpretation of RCW 9.94A.535(2)(i) in Fisher is based on the premise that the legislature wished to punish multiple convictions arising out of same criminal conduct as one, except in unusual or egregious cases.
The purpose of RCW 9.94A.535(2)(i) was to give courts discretion to increase the sentence in those egregious cases. See DAVID BOERNER, SENTENCING IN WASHINGTON 9.13(e), at 9-44 (1985) ("The addition of the limiting qualification 'clearly' to the term 'lenient' is evidence of the Sentencing Guidelines Commission's belief that such situations ought to be rare.").