Sanders v. State
63 So. 3d 497
| Miss. | 2011Background
- Murder of W.D. Crawford and Elma Crawford; Sanders arrested decades later and tried in Mississippi with venue changes (Tishomingo to Lafayette to Lee County).
- Sanders found not guilty by reason of insanity on Count I (murder of W.D.) but jury found he remained insane and dangerous; Count II (murder of Elma) guilty, life sentence as habitual offender.
- Confinement ordered to Mississippi State Hospital for Count I with suspension until release on Count II; Count II sentence runs life imprisonment with no reduction or parole.
- Jury asked whether insanity acquittal with danger would ever allow free walking; court did not explicitly answer; verdict on II consistent with habitual-offender sentencing.
- Three issues on certiorari: (I) weight of the evidence; (II) flight jury instruction; (III) sequencing of confinement vs. hospitalization under statutes.
- Mississippi Supreme Court affirming Court of Appeals and circuit court on all issues; held no merit in Sanders’s challenges.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight of the evidence supporting Count II | Sanders argued verdict against overwhelming weight of evidence. | Sanders contends insanity defense should negate Count II. | No, verdict not against weight of evidence. |
| Flight instruction to jury | State instruction on flight inappropriate because defense presented independent reason. | Flight instruction proper given flight evidence. | Instruction upheld; error if any was harmless. |
| Confinement order vs. hospitalization | Suspension/ordering conflict in statutes; humane disposition. | Statutes conflict; mandatory confinement should be overridden. | Proper to require Count II life sentence before Count I confinement. |
Key Cases Cited
- United States v. Powell, 469 U.S. 57 (U.S. 1984) (consistency not required across counts; each count treated separately)
- Laney v. State, 486 So.2d 1242 (Miss. 1986) (jury's insanity verdict reviewed for sufficiency of evidence)
- Yarbrough v. State, 528 So.2d 1130 (Miss. 1988) (insanity issue for jury; verdict accorded deference)
- Hunter v. State, 489 So.2d 1086 (Miss. 1986) (insanity defense; jury verdict on sanity essentially conclusive)
- Hawthorne v. State, 883 So.2d 86 (Miss. 2004) (insanity evidence and sanity determination reviewed)