Sanders v. State

Facts

In 1985, W.D. and Elma Crawford were attacked in their home. While W.D. was cooking breakfast, someone shot him in the back with a shotgun and then killed him by bludgeoning him in the back of the head with a hammer. After killing W.D., the attacker proceeded to the bedroom and shot Elma with a shotgun while she was lying in bed. The attacker fled the scene in the couple's car. Later that night, police were alerted to a problem. Officer Kemp discovered that the door was ajar, and he heard a voice coming from inside. He discovered Elma lying on the couch, covered in blood. Elma told him that her grandson, D, had shot her and W.D. The phone had been pulled from the wall. Elma had been shot in the bedroom. After D had shot her, she had crawled down a small flight of steps and had written 'K D shotgun' on the floor using her own blood. W.D. was found face down on the floor of the kitchen. The hammer that D had used to beat him was found in a trash can in the house. Neither the shotgun nor the couple's car was found at the scene. Elma spent several weeks in the intensive care unit. She suffered a shotgun blast to her breast and right upper. W.D.'s car was parked in a motel parking lot in Memphis, Tennessee. From January 6, 1986, until December 2005 D simply vanished. San Antonio Police apprehended D. D had used six different aliases since 1990. D was indicted for the murder of W.D., and the murder of Elma. D was indicted for the murder of W.D., and the murder of Elma. D presented the testimony of his mother, Jannie, and stepfather, Gerald Hadley. He also called two experts to testify - Dr. John McCoy and Dr. Mark Webb. D was diagnosed with schizophrenia at the age of eight or nine, and he changed when he was a teenager. D quit school, refused to look in mirrors, screamed, heard things, and sat by himself for hours. D was sent away for treatment. D was indicted for the murder of W.D., and the murder of Elma. D presented the testimony of his mother, Jannie, and stepfather, Gerald Hadley. He also called two experts to testify - Dr. John McCoy and Dr. Mark Webb. D would spin around in his room and beat his head against the wall. D was bounced out of at least 3 treatment programs until he ran away and moved back in with his grandparents. Dr. McCoy stated D was the most mentally ill of all the patients in the hospital. Dr. McCoy diagnosed D as suffering from a schizoaffective disorder; a combination of schizophrenia and bipolar disorder. Dr. McCoy's opinion was that D never should have been discharged from Mid-South. At the time Sanders killed his grandparents, he was 'laboring under a defect of reason from a disease of the mind.' Dr. McCoy believed that Sanders understood the nature and quality of his actions, but that Sanders did not know that what he did was wrong. Dr. Webb agreed that, while D understood the nature and quality of his actions, he did not know that his actions were wrong. Dr. Webb noted D's possible history of aggressive and manipulative behavior, but he characterized D as more paranoid than aggressive. Dr. Lott noted the extended periods of time that D was able to function successfully in society while not on any medications, and he also noted that D had been off any medication for at least four years at the time of the examination. Dr. Lott testified that Sanders looked fine and that he did not appear to be psychotic. D also exhibited normal to above-average intelligence. Dr. Lott noted evidence of manipulative behavior and possible extensive drug use. D had a history of impulsive, aggressive behavior. He believed D was spoiled as a result of being indulged. Dr. Lott also noted that the reports of Dr. Mona Carlyle, who had treated D and D showed no signs of psychosis. However, Dr. Carlyle's final report on D from October 15, 1984, diagnosed atypical psychosis. Dr. Lott concluded that D did understand the nature and quality of his actions. Dr. Lott found that D understood that what he did was wrong. During the murders, D's actions were well-reasoned and well-intended. D had unplugged the phone, wrapped the cord around it, and hid it under the sofa. D took his grandparents' car and immediately fled to Memphis, hiding the car in a busy parking lot. D made the trip to Texas and successfully avoided capture by adopting six different aliases over the next twenty years. D did not testify. The jury returned a verdict of not guilty on the murder of W.D., by reason of insanity, and found that D had not been restored to his sanity and was dangerous to the community. On the murder of Elma, the jury found D guilty. The Court of Appeals affirmed and D appealed.

Issues

Rule of Law

Holding and Decision

Legal Analysis

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