State of Louisiana Versus Wayne Norman, 310 So.3d 287

Defendant Wayne Norman was charged with armed robbery (count 1), illegal possession of stolen things valued $5,000–$24,999 (count 2), and aggravated flight from an officer (count 3) after a stolen 2002 Ford Escape was pursued and crashed during a high‑speed chase; defendant fled on foot and was later found hiding in a closet.
Officers recovered clothing, shoes matching the victim’s missing shoes, and a handgun in nearby yards; items were collected from a shed and yard of residences where the suspect had been present.
A 12‑person jury convicted Norman on counts 1 and 3; on count 2 the jury initially reported a 9‑3 division and, after further deliberation, returned a verdict convicting him of the lesser included misdemeanor (possession of stolen things valued under $1,000).
The trial court sentenced him (count 1 upgraded by habitual offender adjudication), and Norman appealed, challenging the validity of the 9‑3 jury verdict on count 2.
The Fifth Circuit held it had appellate jurisdiction (count 2 was joined with hard‑labor offenses), reviewed the sufficiency of the evidence as to count 2, and reversed and rendered a judgment of acquittal on count 2 for failure to prove the value element; convictions on counts 1 and 3 were affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction to appeal misdemeanor conviction (count 2)	State: appealable because count 2 was charged in same information with hard‑labor offenses and was triable by a 12‑person jury	Norman: (implicitly) appealable challenge to verdict validity; defendant sought review	Court: Appellate court has jurisdiction because count 2 was joined with offenses requiring a 12‑juror trial
Validity/sufficiency of 9‑3 jury verdict and evidence of value (count 2)	State: owner testified vehicle was worth over $5,000; verdict ultimately recorded as misdemeanor conviction and sentence imposed	Norman: 9‑3 split made verdict infirm and State failed to prove the value element beyond a reasonable doubt	Court: Regardless of jury split issue, State failed to prove value of stolen vehicle at time of theft; conviction on count 2 reversed and judgment of acquittal entered; counts 1 and 3 affirmed

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for appellate review of sufficiency of the evidence)
State v. Raymo, 419 So.2d 858 (La. 1982) (appellate reversal required when record lacks proof of essential element, even if defendant does not raise issue)
State v. Stock, 212 So.3d 1268 (La. App. 5 Cir. 2017) (owner’s uncontradicted testimony can establish value of stolen property)
State v. Armant, 839 So.2d 271 (La. App. 5 Cir. 2003) (misdemeanor conviction may be appealed where joined with felony triable by jury)
State v. Chess, 762 So.2d 1286 (La. App. 5 Cir. 2000) (same: appellate jurisdiction over misdemeanor when originally charged/triable as a jury felony)