State v. Tillitt, 552 S.W.3d 571

Defendant Ms. Tillitt was convicted of six child-sex offenses (five counts of first-degree statutory sodomy; one count of first-degree child molestation) based largely on victims' disclosures and a written statement she made after a police interview.
At trial Tillitt renewed a motion to suppress her written statement, objecting on Fifth Amendment self-incrimination grounds but not explicitly re-raising earlier involuntariness or due-process arguments on the record.
A forensic interviewer (Ms. Wemhoff) testified generally about the process of disclosure in child sexual-abuse cases (delayed disclosure, testing the waters, recantation), without opining about the victims specifically.
The trial court admitted Tillitt’s written statement and Wemhoff’s general testimony; Tillitt appealed those evidentiary rulings and also challenged the sentencing decision to impose consecutive terms for each count.
The appellate court affirmed the convictions, finding Tillitt’s written confession voluntary and Wemhoff’s generalized disclosure testimony admissible, but reversed and remanded for resentencing because the trial court believed (mistakenly) it was required by statute to impose consecutive sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of written statement	Tillitt argued Fifth Amendment self-incrimination and involuntariness (coercion/due process)	State argued statement was voluntary and admissible; officer’s approach was noncoercive	Court held statement was voluntary and admissible; admission affirmed
Admissibility of expert testimony on disclosure process	Tillitt argued testimony was more prejudicial than probative and improperly bolstered victims’ credibility	State argued testimony was general, educational, and within trial court discretion	Court held testimony was general (not particularized) and admissible; admission affirmed
Standard for overturning voluntariness ruling	Tillitt contended involuntariness should be reviewed on merits despite limited trial record	State relied on trial court’s findings and substantial-evidence standard	Court reviewed merits and found voluntariness supported by substantial evidence
Sentencing—consecutive terms required?	Tillitt argued court erred by treating statute as mandating consecutive sentences; resulted in plain error	Trial court, prosecutor, and defense believed statute required consecutive terms	Court held trial court mistakenly thought it had no discretion; remanded for resentencing

State v. Churchill, 98 S.W.3d 536 (Mo. banc 2003) (distinguishes general vs. particularized expert testimony in child sexual-abuse cases)
Williams v. State, 800 S.W.2d 739 (Mo. banc 1990) (statute ambiguous on consecutive sentencing; ambiguity resolved to maximize trial court discretion)
State v. Collins, 962 S.W.2d 421 (Mo. App. W.D. 1998) (trial court has broad discretion over evidence admissibility)
Barriner v. State, 210 S.W.3d 299 (discussing standard for overturning voluntariness determinations)
State v. Benedict, 319 S.W.3d 483 (Mo. App. S.D. 2010) (abuse-of-discretion standard explained)