Sanders v. State, 77 So. 3d 484

Hancock County jury convicted Edna Sanders of murdering Sherman Sanders; she received a life sentence.
Court of Appeals reversed, remanding for new trial due to trial court errors: no duty-to-retreat instruction and suppression of evidence.
Sanders argued that Sherman’s incriminating statements to first responders violated her Confrontation Clause rights.
Sherman burned severely by cooking oil; State alleged Sanders threw oil on him while he slept; Sanders claimed self-defense after Sherman attacked her.
Trial included a motion in limine to exclude the statements; the motion was denied.
Certiorari granted; Court of Appeals’ ultimate disposition affirmed, addressing Confrontation Clause and Castle Doctrine issues, with clarified holdings on presumption and confrontation rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
No duty to retreat vs. presumption issue	Sanders entitled to no-duty-to-retreat instruction	Court properly addressed the issue; misapplication of statutes	Error to deny instruction; but presumption not applicable when attacker is a lawful resident
Confrontation Clause—admission of first responders’ statements	Admission violated Sanders’s Sixth Amendment right	Statements non-testimonial; exigent-emergency context under Davis/Bryant	No Sixth Amendment violation; statements not testimonial given ongoing emergency
Presumption of reasonable fear in Castle Doctrine context	Court of Appeals implied presumption applicable; misapplication	Presumption limited; context matters	Presumption does not apply when the defender’s assailant is a lawful resident/owner of the dwelling

Davis v. Washington, 547 U.S. 813 (U.S. 2006) (testimonial vs. nontestimonial statements; ongoing emergency framework)
Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (confrontation rights; testimonial evidence restrictions)
Michigan v. Bryant, 131 S. Ct. 1143 (U.S. 2011) (primary purpose test for whether statements are testimonial; ongoing emergency)