People of Michigan v. Ronald Kenneth Norfleet, 321 Mich. App. 68

Defendant Ronald Norfleet convicted of seven drug offenses tied to heroin distribution; five convictions under MCL 333.7401 (which permits consecutive sentences).
At initial sentencing the trial court ordered multiple MCL 333.7401 sentences to run consecutively without individualized explanation.
This Court previously remanded, holding that the trial court must articulate on the record separate reasons for each consecutive sentence to allow meaningful appellate review (citing preference for concurrent sentences).
On remand the trial court amended the order: it made two of the MCL 333.7401 convictions consecutive to each other and made the remaining convictions concurrent, and it explained why Counts 1 and 2 should run consecutively.
The trial court justified consecutive sentences for Counts 1 and 2 based on defendant’s extensive and violent criminal history, repeated failures at rehabilitation, exploitation/manipulation of addicts and a young girlfriend in the drug operation, long-term heroin dealing, and financial gain.
The court also complied with this Court’s direction regarding Crosby (judicial factfinding affecting minimum terms) by stating it would have imposed the same minimum terms knowing the guidelines are advisory.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial courts must articulate separate, particularized reasons on the record for each consecutive sentence imposed under MCL 333.7401	State: Trial court’s original consecutive sentences were valid but remand required for articulation; on remand two consecutive sentences are supported by facts	Norfleet: Trial court’s original lump-sum consecutive sentencing was inadequate; challenges excessive consecutive terms	Court: Trial court required to state individualized reasons for each consecutive sentence; on remand it properly limited consecutives to Counts 1 and 2 with adequate reasons and made others concurrent — affirmed
Whether Crosby procedure and advisory-guidelines notice affected minimum terms imposed	State: Trial court’s stated minimums would remain the same even knowing guidelines are advisory	Norfleet: Judicial factfinding affected minimum terms requiring Crosby compliance/remand	Court: Trial court followed Crosby guidance on remand and confirmed it would have imposed same minimums; no relief warranted

People v Broden, 428 Mich 343 (1987) (trial court must articulate on the record reasons for a sentence to enable appellate review)
People v Chambers, 430 Mich 217 (1988) (Michigan favors concurrent sentencing; consecutive sentences are "strong medicine")
People v Milbourn, 435 Mich 630 (1990) (discretion in sentencing is a matter of degree; articulated principles for sentence reasonableness)