Voluntariness of statements made to police; Mincey v Arizona; People v Cipriano; Sentencing; People v Lockridge; Reasonableness & proportionality; People v Dixon-Bey; Requirement that the trial court provide reasoning for a departure sentence; People v Steanhouse; Consecutive sentencing for CSC I convictions; MCL 750.520b(3); People v Norfleet

Holding that defendant’s confession was voluntarily made, the court affirmed her five CSC convictions. However, it remanded for the trial court to either articulate its rationale for imposing consecutive sentences or to resentence her. Her convictions arose out of her involvement in acts of sexual abuse that her husband committed against their three-year-old daughter. On appeal, the court rejected her argument that the trial court improperly admitted statements she made during her interview with the detectives because, “under the totality of the circumstances, her statements were involuntary.” Considering the “totality of the circumstances surrounding her interview, and the statements she made during the interview,” the court held that her statements to the detectives were voluntarily made. However, it agreed with defendant, and the prosecution conceded, that the trial court abused its discretion by imposing a departure sentence and consecutive sentences. “The trial court here gave no explanation for why it imposed consecutive sentences, which precludes this [c]ourt from reviewing whether consecutive sentencing was proper.”