Sanders v. State
63 So. 3d 497 (2011)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Inconsistent verdicts on separate counts of an indictment are permissible, and a jury's finding of legal sanity will not be disturbed if supported by credible evidence, even when it conflicts with an insanity acquittal for a contemporaneous crime. When a defendant receives a mandatory, non-suspendable life sentence as a habitual offender and a mandatory commitment to a state hospital for an insanity acquittal, the prison sentence must be served first.
Facts:
- Keir Sanders had a documented history of severe mental illness, including a diagnosis of schizoaffective disorder and multiple psychiatric hospitalizations.
- On December 29, 1985, Sanders was at the home of his grandparents, W.D. and Elma Crawford.
- Sanders shot his grandfather, W.D. Crawford, with a shotgun and then bludgeoned him to death with a hammer in the kitchen.
- Immediately thereafter, Sanders went to the bedroom and shot his grandmother, Elma Crawford, with the same shotgun.
- Before fleeing, Sanders unplugged the telephone and wrapped the cord around it.
- Elma Crawford survived the initial attack long enough to identify Sanders as her attacker to police and write "K D shotgun" on the floor in her own blood; she died weeks later on March 4, 1986.
- Sanders fled the scene in his grandparents' car and successfully evaded capture for nearly twenty years, using at least six different aliases.
- In December 2005, Sanders was apprehended by police in San Antonio, Texas.
Procedural Posture:
- Keir Sanders was indicted by a grand jury in Tishomingo County for two counts of murder for the deaths of W.D. and Elma Crawford.
- Venue for the trial was changed to Lafayette County, which resulted in a mistrial.
- Venue was subsequently changed to Lee County for a second trial.
- The jury found Sanders not guilty of murder on Count I (W.D. Crawford) by reason of insanity, and also found that he remained insane and dangerous.
- The same jury found Sanders guilty of murder on Count II (Elma Crawford).
- The circuit court sentenced Sanders as a habitual offender to life in prison on Count II and ordered him committed to the state mental hospital on Count I, suspending the commitment until the completion of his prison sentence.
- Sanders filed a motion for a judgment notwithstanding the verdict or for a new trial, which the circuit court denied.
- Sanders, as appellant, appealed to the Mississippi Court of Appeals, which affirmed the trial court's judgment.
- The Mississippi Supreme Court granted Sanders's petition for a writ of certiorari to review the case.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a guilty verdict for one count of murder violate the overwhelming weight of the evidence when the jury, presented with the same evidence regarding the defendant's mental state, simultaneously acquits the defendant of a second, contemporaneous murder by reason of insanity?
Opinions:
Majority - Pierce, J.
No, the guilty verdict for one count of murder does not violate the overwhelming weight of the evidence. Consistency in jury verdicts is not necessary, as each count in an indictment is treated as a separate case. A jury’s finding on the issue of insanity is granted great deference and is essentially conclusive and unreviewable when there is conflicting expert testimony. Although the defense presented two experts who believed Sanders did not know his actions were wrong, the State presented an expert who disagreed and offered evidence of Sanders's calculated actions—unplugging the phone, fleeing the state, and evading capture for twenty years—which suggested he had a guilty conscience and knew his conduct was wrong. This conflicting evidence was sufficient for the jury to find him legally sane under the M'Naghten rule for the murder of Elma Crawford. The court also held that the trial court correctly prioritized the non-suspendable life sentence over the commitment to a mental hospital, as this was the only way to give effect to both conflicting mandatory statutes.
Concurring - Carlson, P.J.
This opinion agrees with the majority's judgment but writes separately to caution against the use of a flight instruction. While evidence of flight is admissible, providing a specific jury instruction on flight is 'dangerous' because it heightens the importance of that evidence in the jury's eyes and risks creating a reversible error. However, any potential error in giving the instruction in this case was harmless beyond a reasonable doubt because the overwhelming weight of the evidence supported the guilty verdict.
Dissenting - Dickinson, P.J.
Yes, the guilty verdict violates the overwhelming weight of the evidence. The verdict is irrational because there is absolutely no evidence to support the conclusion that Sanders was insane when he killed his grandfather but became sane moments later when he killed his grandmother. The evidence regarding his mental state was identical for both acts. The jury's written question about whether Sanders could 'ever walk as a free man' reveals that they improperly rendered a verdict based on fear and a desire to ensure his permanent confinement, rather than on the evidence presented. It is appalling to send a man who has been adjudicated insane to prison without treatment.
Dissenting - Kitchens, J.
Yes, the guilty verdict violates the overwhelming weight of the evidence. Because the proof regarding Sanders's mental condition was exactly the same for both killings, the jury's inconsistent verdicts are irreconcilable. Since the murders were charged in a single indictment as part of the 'same act or transaction,' it is illogical to conclude his sanity changed between the two acts. The jury's questions about sentencing make it clear they manipulated the verdict to guarantee that Sanders would be confined for life, which is an illegitimate basis for a verdict.
Analysis:
This decision solidifies the principle that inconsistent jury verdicts are permissible and reinforces the high degree of deference appellate courts give to a jury's determination of legal sanity. The ruling effectively insulates such verdicts from reversal as long as there is any conflicting evidence on the record for the jury to weigh. Furthermore, the case establishes a clear hierarchical rule for sentencing conflicts: a mandatory, non-suspendable sentence under a habitual offender statute takes precedence over a mandatory civil commitment following an insanity acquittal. This impacts future cases involving defendants with multiple charges and complex mental health and sentencing issues by prioritizing punitive incarceration over therapeutic commitment.
