## Facts

- On December 29, 1985, Keir D. Sanders shot his grandfather, W.D. Crawford, and then shot his grandmother, Elma Crawford, at their home in Mississippi.
- Responding officers found W.D. dead and Elma severely wounded but alive; she identified Sanders as the shooter and reported that he pulled the telephone from the wall before fleeing.
- Elma survived for weeks but later died from complications of the gunshot wounds.
- Sanders fled the state, abandoned W.D.’s car, and avoided capture for about two decades by using multiple aliases.
- In December 2005, Sanders was located in Texas, arrested on the outstanding warrants, and returned to Mississippi for prosecution.
- Sanders was indicted for two counts of murder: Count I for W.D. and Count II for Elma.
- Before retrial, venue was transferred (ultimately to Lee County) after earlier proceedings included a mistrial.
- At trial, Sanders asserted an insanity defense supported by mental-health testimony describing a long history of severe mental illness and diagnosing schizoaffective disorder.
- Defense experts testified that, although Sanders understood the nature and quality of his acts, he did not know his actions were wrong at the time of the shootings.
- The State’s expert disagreed and opined that Sanders knew his conduct was wrong, relying in part on Sanders’s goal-directed behavior (disconnecting the phone, fleeing, and remaining a fugitive for years).
- The jury returned different verdicts on the two counts: not guilty by reason of insanity on Count I (W.D.) and guilty of murder on Count II (Elma).
- The trial court imposed the mandatory life sentence for the murder conviction on Count II and addressed the insanity acquittal on Count I by ordering commitment-related consequences, structured so that Sanders would first serve the life sentence before any indefinite confinement in a mental institution.

## Issues

1. Whether the guilty verdict on Count II was against the overwhelming weight of the evidence given the proof of mental illness and the jury’s not-guilty-by-reason-of-insanity verdict on Count I.
2. Whether the jury could lawfully return inconsistent insanity-related verdicts on two murder counts arising from the same episode.
3. Whether the trial court erred by requiring Sanders to serve his mandatory life sentence for Count II before any indefinite commitment associated with the insanity acquittal on Count I.

## Decision

- The Supreme Court of Mississippi affirmed Sanders’s conviction and mandatory life sentence for the murder of Elma Crawford (Count II).
- The court held that the jury’s differing insanity-related verdicts on separate counts did not require reversal, even though the offenses occurred close in time.
- The court concluded the verdict on Count II was not against the overwhelming weight of the evidence because the jury was entitled to resolve conflicting expert testimony and consider Sanders’s conduct before and after the shootings as evidence bearing on legal sanity.
- The court affirmed the trial court’s order structuring confinement so that Sanders would serve the life sentence on Count II before any indefinite mental-hospital confinement related to the insanity acquittal on Count I.

## Legal Principles

- Under Mississippi’s application of the M’Naghten standard, a defendant is legally insane if, because of a disease of the mind, the defendant either did not know the nature and quality of the act or did not know the act was wrong.
- When expert testimony on sanity conflicts, determining credibility and weight is for the jury; an appellate court does not reweigh that proof on appeal.
- Inconsistent verdicts across separate counts in an indictment are not, by themselves, a basis for reversal; each count is treated as if it were a separate indictment.
- A conviction will not be reversed as against the overwhelming weight of the evidence where the record contains evidence from which reasonable jurors could find the defendant legally sane under the governing standard.
- Trial courts have discretion in structuring the consequences of an insanity acquittal alongside a separate conviction and sentence, including sequencing a mandatory prison sentence before later mental-hospital confinement tied to the insanity verdict.

## Conclusion

Sanders v. State upheld a murder conviction for the grandmother’s death even though the jury found Sanders not guilty by reason of insanity for the grandfather’s murder from the same incident. The Mississippi Supreme Court ruled that inconsistent insanity-related verdicts on separate counts are permissible, that the jury could credit the State’s sanity evidence and Sanders’s flight as showing consciousness of wrongdoing, and that the trial court did not err by requiring Sanders to serve his mandatory life sentence before any later confinement in a mental institution related to the insanity acquittal.


Sanders v. State, 63 So. 3d 497 (2011)