Departure reasonableness & proportionality; People v Steanhouse; Consecutive sentencing for CSC I; MCL 750.520b(3); People v Norfleet

The court held that the resentenced terms above the mandatory minimum and the consecutive-sentencing decision were reasonable and proportionate, and it affirmed. A jury convicted defendant of multiple counts of CSC I and CSC II against two young relatives. On prior appeal the case was remanded for fuller reasoning. At resentencing the trial court imposed 30 to 60 years on four CSC I counts, 25 to 50 years on a fifth CSC I, and 10 to 15 years on two CSC II counts, with the fifth CSC I and the CSC II sentences to run consecutive to the others. The court explained that it was adding 5 years above the 25-year minimum due to “all the incidents,” the continuing nature of the abuse, and the harm to the victims and family. On appeal, the court held that the trial court addressed offense seriousness and offender factors and articulated why the chosen sentences were more proportionate than a lesser term. The court further held that consecutive sentencing was authorized for offenses arising from the same transaction and that the trial court articulated specific reasons, including the victims’ ages, simultaneous acts, threats to silence disclosures, the physical injury described, probationary status at the time of the offenses, and absconding, all of which supported the exercise of discretion.