Page 42 - TPA Journal May June 2025

EVIDENCE – MIRANDA then drove with L.R. for three or four days to
Louisiana. Sanders stopped in a remote area that
Thomas Steven Sanders was convicted of kidnap- was not far from his childhood home, and he fatal-
ping and murdering a twelve-year-old child and ly shot L.R. four times in the head and chest
received two concurrent sentences of death. In this before slitting her throat. Sanders left L.R.’s body
direct criminal appeal, Sanders brings numerous in the woods. The record reflects that approxi-
challenges to his convictions and sentences. On mately a month later, hunters discovered L.R.’s
December 23, 2024, then-President Biden com- remains.
muted Sanders’s sentences to two terms of life In the meantime, Suellen’s family notified author-
imprisonment without the possibility of parole. ities that Suellen and L.R. were missing after they
That action did not necessarily moot the issues did not return home to Las Vegas. Subsequently,
Sanders has raised in his appeal. We now vacate on November 14, 2010, the authorities apprehend-
Sanders’s conviction and sentence under Count ed Sanders, and he confessed to killing both
Two of his indictment, which was based on 18 Suellen and L.R.
U.S.C. § 924(c) and (j), and we otherwise affirm Sanders was prosecuted by federal authorities
the district court’s judgment. under federal law. In 2014, after a four-day trial in
the Western District of Louisiana, a jury convict-
In 2010, Suellen Roberts and her twelve-year-old ed Sanders of kidnapping and murdering twelve-
daughter, L.R., moved in with Suellen’s mother, year-old L.R. After a seven-day penalty phase
who lived in a one-bedroom apartment in Las trial, the jury determined “by unanimous vote that
Vegas. Suellen rented a storage unit at Pacific a sentence of death shall be imposed” on both
Mini-Storage to store some of her belongings. counts. Pursuant to the jury’s verdict, the district
Sanders worked and lived at the Pacific Mini- court imposed two concurrent death sentences.
Storage facility, and it was there that Suellen met This direct appeal follows in which Sanders pre-
Sanders. During the summer of 2010, Suellen vis- sents several issues.
ited the storage facility two or three times a week.
Sanders and Suellen began dating and would often (Discussion of competency to stand trial is omit-
go out together. Late that summer, the two started ted. Ed.)
planning a Labor Day weekend trip to Arizona
with L.R. Shortly before the trip, Sanders pur- Sanders contends that the district court erred in
chased ammunition for a .22 caliber rifle. denying his motion to suppress the statements that
The three left Las Vegas in Suellen’s vehicle and he made during custodial interrogation following
visited various attractions in Arizona over the his arrest. He argues that the law enforcement
Labor Day weekend. officers should have stopped questioning him
On Monday, they began their trip home to Las when he invoked his right to counsel. Sanders’s
Vegas. In response to questioning, Sanders pro- briefing seems to focus on the penalty phase of his
vided the following account. En route, they were trial to the exclusion of the guilt/innocence phase.
driving “down the road and found a place to go The commutation of his death sentences would
shooting the gun.” Suellen was “learn[ing] how to seem to moot his complaints about the admission
shoot his .22” rifle. After Sanders and Suellen had of the evidence that is in contention. But, out of an
been shooting the rifle, Sanders fatally shot abundance of caution, because he did not clearly
Suellen in the head at close range and left her body forfeit or affirmatively waive the applicability of
where they had been shooting. his arguments to his convictions, as opposed to his
There is no evidence of an argument or altercation sentences, and because he affirmatively seeks to
prior to the shooting. L.R. witnessed Sanders have his convictions reversed, we proceed to
shoot her mother and “was in hysterics.” Sanders address the denial of his motion to suppress. In

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