The 50-year-old was brought back to a secure unit at the Dame Phyllis Frost Centre in Melbourne's west on Monday after being sentenced in the Victorian Supreme Court.
She was jailed for life for murdering her former in-laws Don and Gail Patterson, 70, and Gail's sister Heather Wilkinson, 66, by serving them beef Wellingtons laced with death cap mushrooms.
Patterson also received a concurrent 25-year maximum sentence for the attempted murder of Heather's husband Ian Wilkinson, who fell seriously ill after the July 2023 lunch but survived.
But Justice Christopher Beale showed Patterson mercy in setting a 33-year non-parole period, noting the stringent conditions she would face in custody.
Patterson had a maximum security rating because she was at risk from other prisoners, the judge noted, meaning she was to be in her cell for at least 22 hours a day.
She also had limited contact with other prisoners and was unable to access the exercise yard and library facilities.
Given Patterson's notoriety and the extensive media attention on the case, it was likely she would remain in the protective unit for years to come, Justice Beale said.
"The harsh prison conditions that you have experienced already and the likely prospect of solitary confinement for the foreseeable future are important and weighty considerations," he said during the sentencing.
"In my view, the only scope for making them count is by the fixing of a non-parole period."
Patterson will be 82 years old before she is eligible to be released back into the community.
While prosecutors were pushing for life without parole, RMIT criminology associate professor Brianna Chesser said the sentence Patterson received was within range.
"Ms Patterson's conditions in prison weighed heavily on the 33-year non-parole period," she told AAP.
"It's closer to 30 (years) than 40 because of the conditions that Ms Patterson is currently facing and is likely to face."
Patterson has 28 days to lodge an appeal against sentence and conviction but Dr Chesser argued the process might not be straightforward for the jailed killer.
"I'm certainly never going to say never but she's limited in terms of what she can appeal," she said.
"The sentence was quite reasonable ... and I wasn't aware of any procedural irregularity or miscarriage of justice that occurred during the trial.
"There's certainly nothing glaring that stands out as an opportunity for an appeal."
Patterson's barrister Colin Mandy SC declined to comment when asked by reporters if his client planned to appeal.
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