Bruce Sanders v. State of Arkansas

2025 Ark. App. 205, 711 S.W.3d 160
CourtCourt of Appeals of Arkansas
DecidedApril 9, 2025
StatusPublished

This text of 2025 Ark. App. 205 (Bruce Sanders v. State of Arkansas) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bruce Sanders v. State of Arkansas, 2025 Ark. App. 205, 711 S.W.3d 160 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 205 ARKANSAS COURT OF APPEALS DIVISION I No. CR-24-441

BRUCE SANDERS Opinion Delivered April 9, 2025

APPELLANT APPEAL FROM THE UNION COUNTY CIRCUIT COURT V. [NO. 70CR-23-281]

STATE OF ARKANSAS HONORABLE SPENCER G. APPELLEE SINGLETON, JUDGE

AFFIRMED

ROBERT J. GLADWIN, Judge

This is an appeal from appellant Bruce Sanders’s conviction by a Union County jury

of first-degree battery and resulting sentence of twelve years’ imprisonment in the Arkansas

Division of Correction (“ADC”). Sanders argues on appeal that the circuit court erred by

denying his motion for a directed verdict because the circumstantial evidence was insufficient

to prove he acted with the purpose to cause injury. He also maintains that the evidence was

insufficient to convict him because there was an equally reasonable conclusion that he was

acting in self-defense. We affirm.

I. Background Facts

On May 14, 2023, Sanders was staying with Linda Kay Braggs and her minor son

(“MC”) at their trailer in El Dorado. Braggs left MC with Sanders at the residence while she

left to pick up some food. MC stated he believed Sanders was “drunk that night” and that at some point, Sanders picked up a knife and was pointing it at him. MC then called a

neighbor friend, who was also a minor (“MC2”), to come help, and once MC2 arrived,

Sanders began hitting them with a broom. James Golden was walking toward the trailer

when he heard the commotion. Golden testified that once he got to the porch of the trailer

he saw Sanders holding a knife and a “stick.” Golden said that he then grabbed Sanders in

an attempt to take the knife away and admittedly choked Sanders until he dropped the knife.

Golden proceeded to push Sanders out of the doorway and off the porch. Sanders got in

his car and drove away. While Golden was walking away from the trailer, Sanders pulled up

behind him in his vehicle, got out of the car, and shot Golden. Golden testified he was first

shot in his shoulder, then he was shot twice in his back and once in his leg. Sanders left in

his vehicle after the shooting. Golden was med-flighted to a hospital in Shreveport where

he remained a patient for two weeks.

Lieutenant Dallas Smith with the El Dorado Police Department was one of the

officers who responded to the call about the shooting. He testified that officers found a

knife in the front yard of Braggs’s residence and a knife inside the trailer. He also testified

that officers spoke to witnesses to get the shooter’s name, but they were only given the first

name “Bruce.” Sergeant Trey Phillips, a detective with the El Dorado Police Department,

testified he also responded to the shooting and that his primary role was to process the scene.

Phillips stated that a total of three .38-caliber shell casings were found, and there were

droplets of blood found in the kitchen of the residence. However, he explained that none

of the blood droplets were tested and neither of the knives were fingerprinted. A neighbor,

2 Shakeitha Gulley, saw part of the incident and testified that she saw Sanders leave in his car,

return five minutes later, fire three shots at Golden, and then drive off again.

Deputy Andre Lovett with the Union County Sheriff’s Department located Sanders

in an oil field the day after the shooting. Deputy Lovett testified that Sanders approached

him and stated he was probably the man they were looking for and that he had “shot a man.”

In Sanders’s vehicle, Lovett found a .38-caliber pistol that had some rounds left in the

chamber. The hollow-point bullets in the firearm retrieved from Sanders’s vehicle matched

the shell castings found at the scene of the shooting.

On July 13, 2023, Sanders was charged with one count of attempted capital murder

and one count of aggravated assault. Sanders was also charged with a firearm enhancement

and as a habitual offender. On January 8, 2024, Sanders’s charges were amended to one

count of first-degree battery with only the habitual-offender enhancement.

A jury trial was held on January 23, 2024. The State called to testify the officers and

the criminal investigator who responded to the shooting as well as the arresting officer. The

State also called MC1, MC2, Shakeitha Gulley, and Golden to testify. After the State rested

its case, Sanders moved for a directed verdict, arguing that the jury had only speculation and

conjecture to determine whether he acted with purpose to cause injury. The circuit court

denied Sanders’s motion, finding that his purpose to cause injury could be inferred by

Sanders’s action of firing multiple shots at Golden. The defense called only one witness—

Linda Kay Braggs—who testified that she had never known Sanders to be mean or abusive

toward MC1 or anyone else. She also testified that Golden turned around like he was going

3 toward Sanders when the shooting occurred. After the defense rested, Sanders renewed his

motion for directed verdict, which the circuit court denied.

The jury found Sanders guilty of first-degree battery; however, the jury could not reach

a decision on sentencing. The circuit court sentenced Sanders to twelve years’ imprisonment

in the ADC. Sanders filed a timely notice of appeal; this appeal followed.

II. Standard of Review

On appeal, this court treats a motion for directed verdict as a challenge to the

sufficiency of the evidence. Armstrong v. State, 2020 Ark. 309, 607 S.W.3d 491. In reviewing

a challenge to the sufficiency of the evidence, this court views the evidence in the light most

favorable to the State and considers only the evidence that supports the verdict. Price v. State,

2010 Ark. App. 111, 377 S.W.3d 324. This court will affirm a conviction if substantial

evidence exists to support it. Id. Substantial evidence is evidence that is of sufficient force

and character that it will, with reasonable certainty, compel a conclusion one way or the

other without resorting to speculation or conjecture. Id. The duty of resolving conflicting

testimony and determining the credibility of witnesses is left to the discretion of the jury.

Kelley v. State, 375 Ark. 483, 292 S.W.3d 297 (2009).

III. Discussion

Sanders’s sole argument on appeal is that the circuit court erred by denying his

motion for a directed verdict because the circumstantial evidence was insufficient to prove

that he acted with the purpose to cause injury. Specifically, Sanders maintains that the

evidence was insufficient to convict him because there was an equally reasonable conclusion

4 that he was acting in self-defense. In response, the State argues that Sanders failed to preserve

any argument that his actions were justified, and his intent argument is meritless. We agree

with the State.

Sanders’s argument on appeal centers on whether the State negated his justification

defense. However, a party is bound by the nature and scope of the objections and arguments

made at trial and may not enlarge or change those grounds on appeal. Daniels v. State, 2019

Ark. App. 507, 588 S.W.3d 407. In Sanders’s initial directed-verdict motion, his counsel

argued that the jury would have to rely on speculation and conjecture to determine that he

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Related

Kelley v. State
292 S.W.3d 297 (Supreme Court of Arkansas, 2009)
Taylor v. State
72 S.W.3d 882 (Court of Appeals of Arkansas, 2002)
Price v. State
377 S.W.3d 324 (Court of Appeals of Arkansas, 2010)
Rose v. State
558 S.W.3d 415 (Court of Appeals of Arkansas, 2018)
Derrick Nixon v. State of Arkansas
2024 Ark. App. 100 (Court of Appeals of Arkansas, 2024)
Courtney Daniels v. State of Arkansas
2019 Ark. App. 507 (Court of Appeals of Arkansas, 2019)
Matthew Armstrong v. State of Arkansas
2020 Ark. 309 (Supreme Court of Arkansas, 2020)

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2025 Ark. App. 205, 711 S.W.3d 160, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bruce-sanders-v-state-of-arkansas-arkctapp-2025.