State Of Louisiana v. Jaylon K. Brown, 380 So.3d 18

Jaylon K. Brown was indicted on two counts of second-degree murder; convicted of second-degree murder for killing Dararius Evans and of manslaughter for killing Aleysia Maynor; sentenced to life without parole (murder) and 40 years concurrent (manslaughter).
December 28, 2019: victims found shot in Evans’s car near LSU Ag Center; Maynor was dead at scene; Evans later died.
Defendant initially denied involvement, then in a third statement admitted shooting Evans (claimed self‑defense) and said Maynor was accidentally shot; he admitted disposing of the gun in a Baton Rouge storm drain.
Forensic evidence: ballistics linked eight casings and the fatal bullet to the recovered firearm; trajectory and autopsy evidence supported shots from the back/middle seat and a close-range wound to Maynor.
Cell‑site and surveillance data placed Evans, Maynor, and Brown together shortly before the shooting; Brown’s phone left the area shortly after the 911 call and later pinged near where the weapon was found.
Brown appealed, raising (1) insufficiency of the evidence (self‑defense/accident/identity) and (2) constitutional error from removing a juror who appeared to be sleeping.

Issue	State's Argument	Brown's Argument	Held
Sufficiency of evidence to support convictions (Evans: 2d‑deg murder; Maynor: manslaughter)	Evidence (confession, ballistics, trajectories, autopsy, phone/location, flight/inconsistent statements) proves Brown fired the weapon, had intent as to Evans, and caused Maynor’s death.	Claimed self‑defense as to Evans; claimed Maynor’s death was accidental; argued lack of specific intent and that gun wasn’t his.	Affirmed. Jury reasonably rejected self‑defense and accidental theories; physical and circumstantial evidence supported intent and causation.
Removal of juror for alleged sleeping	Trial court and State observed repeated instances of the juror’s sleeping/snoring and unsuccessful attempts to awaken her; she was unable to perform duties and was properly replaced by an alternate.	Objected that juror said she was listening, removal occurred outside defendant’s presence without on‑the‑record inquiry or hearing, and deprived Brown of right to be tried by the empaneled jurors.	Majority affirmed removal as within trial court discretion given chronic, documented sleeping and warnings; dissent would reverse for lack of on‑the‑record inquiry and defendant’s absence during disqualification.

Jackson v. Virginia, 443 U.S. 307 (1979) (establishes the beyond‑a‑reasonable‑doubt sufficiency standard on appellate review)
State v. Cass, 356 So.2d 396 (La. 1977) (removal of sworn juror for sleeping requires careful on‑record inquiry; wrongful removal prejudicial)
State v. Oliphant, 133 So.3d 1255 (La. 2014) (circumstantial evidence must exclude every reasonable hypothesis of innocence)
State v. Mire, 269 So.3d 698 (La. 2016) (appellate courts must not reweigh evidence or reassess witness credibility)
State v. Ordodi, 946 So.2d 654 (La. 2006) (deference to the factfinder when jury reasonably rejects defense hypotheses)
State v. Welch, 297 So.3d 23 (La. App. 1st Cir. 2020) (specific intent may be inferred from deliberate close‑range shooting)