Sanders v. State
| Docket Number: | 2008-CT-01445-SCT Linked Case(s): 2008-KA-01445-COA2008-KA-01445-COA2008-CT-01445-SCT2008-CT-01445-SCT |
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| Oral Argument: | 12-07-2010 | |
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| Supreme Court: | Opinion Link Opinion Date: 04-07-2011 Opinion Author: Justice Pierce Holding: Affirmed. |
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| Additional Case Information: |
Topic: Murder - Weight of evidence - Legal sanity - M’Naghten Rule - Flight instruction - Sentence - Section 99-13-7 - Habitual offender statute Judge(s) Concurring: Waller, C.J., Carlson, P.J., Randolph and Lamar, JJ. Judge(s) Concurring Separately: Carlson, P.J., Specially Concurs With Separate Written Opinion. Joined by Waller, C.J., and Lamar, J.; Kitchens, J., Joins In Part. Non Participating Judge(s): King, J. Dissenting Author : Dickinson, P.J. With Separate Written Opinion Dissent Joined By : Kitchens and Chandler, JJ. Dissenting Author : Kitchens, J. With Separate Written Opinion Dissent Joined By : Dickinson, P.J., and Chandler, J. Procedural History: Jury Trial Nature of the Case: CRIMINAL - FELONY |
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| Trial Court: |
Date of Trial Judgment: 05-30-2008 Appealed from: Tishomingo County Circuit Court Judge: Thomas J. Gardner Disposition: Count I: Acquitted of murder by reason of insanity and ordered confinement in a State asylum for the insane; Count II: Convicted of murder and sentenced to life imprisonment, as a habitual offender, in the custody of the Mississippi Department of Corrections District Attorney: John Richard Young Case Number: CR05-078 |
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| Party Name: | Attorney Name: | Brief(s) Available: | ||
| Appellant: | Keir D. Sanders |
OFFICE OF INDIGENT APPEALS: HUNTER NOLAN AIKENS, LESLIE S. LEE |
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| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL: JEFFREY A. KLINGFUSS |
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Synopsis provided by:  If you are interested in subscribing to the weekly synopses of all Mississippi Supreme Court and Court of Appeals hand downs please contact Tammy Upton in the MLI Press office. |
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| Topic: | Murder - Weight of evidence - Legal sanity - M’Naghten Rule - Flight instruction - Sentence - Section 99-13-7 - Habitual offender statute |
| Summary of the Facts: | Keir Sanders was found not guilty of murder by reason of insanity on Count I, but the jury found that he remained insane and a danger to the community. On Count II, Sanders was found guilty of murder, and he was sentenced to life in prison as a habitual offender. The circuit court ordered him confined to the Mississippi State Hospital at Whitfield on Count I, and sentenced him to life in prison on Count II, with the confinement pursuant to Count I to be suspended until such time as Sanders is released on Count II. Sanders appealed, and the Court of Appeals affirmed. The Supreme Court granted certiorari. |
| Summary of Opinion Analysis: | Issue 1: Weight of evidence Sanders argues that his conviction on Count II, the murder of his grandmother, was against the overwhelming weight of the evidence. Sanders does not dispute his role in killing his grandparents, but, rather, the finding that he was legally sane when he did so. In insanity defense cases, perhaps more than any other, a jury’s verdict ought to be given great respect and deference. The record shows that the jury acted within its purview despite the apparent inconsistent result, as the jury was presented with count-specific options regarding the form of the verdict and was allowed to choose one form for Count I and another for Count II. The jury was properly instructed on the method for determining legal sanity. Mississippi follows the M’Naghten Rule for determining legal sanity. Under the M’Naghten Rule, a defendant may not be held criminally liable for his actions at the time of the alleged crime if he was laboring under such a defect of reason from disease of the mind that either he did not understand the nature and quality of his act, or if he did understand the nature and quality of his act, he did not appreciate that the act was wrong. In applying this rule, the accused is presumed sane; and therefore, the burden is initially on the defendant to introduce evidence creating a reasonable doubt of his sanity. However, once the defendant has overcome this initial burden, it is the State’s burden to present sufficient evidence to prove the defendant's sanity beyond a reasonable doubt. Expert opinions of psychiatrists are not conclusive upon the issue of insanity, which is, rather, a question to be resolved by the jury. The only question is whether the evidence preponderates heavily against the jury’s necessary determination that Sanders knew that the killing of his grandmother was wrong. On this point, there was conflicting evidence. The dying-declaration testimony of Elma was that her grandson had walked upstairs to her bedroom after killing her husband, had shot her, and then had hid the phone before leaving with the shotgun. Sanders then had eluded police for nearly twenty years. These facts and evidence suggest Sanders knew his conduct was wrong. The jury weighed the conflicting testimony of experts and Sanders’s history of mental illness against his seemingly calculated flight. After being properly instructed regarding the burden of proving whether or not Sanders was legally sane, the jury found him guilty. To do so, the jury necessarily had to make a judgment concerning one of the most difficult questions of fact -- legal sanity -- with which a jury may be presented. Sanders’s conviction was not against the overwhelming weight of the evidence. Issue 2: Flight instruction Sanders argues that the trial court erred when it granted the State’s instruction on flight. The Court of Appeals found no error in the giving of this instruction. The Court of Appeals conclusions of law are adopted on this issue. Issue 3: Sentence Sanders argues that the trial court erred in suspending his mandatory commitment to a state asylum for the insane under section 99-13-7 until completion of his sentence on Count II. The trial court is mandated to commit any person acquitted on the ground of insanity when the jury finds that the defendant has not been restored to reason and remains dangerous to the community. Because the jury found for Sanders on Count I (but also found that he remained insane and dangerous), the trial court was required to commit him. A person cannot be in two places at the same time. The “commitment” statute for the criminally insane and the “habitual offender” statute each mandate that the court confine Sanders in mutually exclusive manners. The latter, however, specifically prohibits the suspension of its mandate. The trial court’s order is in accord with the plain reading of these statutory provisions. When statutes are in pari materia, although apparently conflicting, they should, if possible, be construed in harmony with each other to give effect to each. The trial court’s disposition is the only disposition which logically could give effect to the express prohibition in the “habitual offender” statute against suspending or reducing the criminal sentence. |
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