State v. Francois, 242 So. 3d 806

Defendant Gary M. Francois was indicted for second-degree murder (shooting James Vaughn in Foot Locker on Dec. 24, 2014); convicted by jury and sentenced to life at hard labor without benefits.
Competency proceedings: court initially found defendant incompetent, remanded for treatment; later found competent after restoration; competency was re-evaluated multiple times before trial.
Defense pleaded not guilty by reason of insanity and presented extensive lay and expert testimony (Dr. Deland) that defendant suffered schizophrenia, auditory hallucinations, and was unable to distinguish right from wrong at the time of the shooting.
State presented psychiatric testimony (Drs. Richoux and Salcedo) acknowledging mental illness but opining defendant could distinguish right from wrong; surveillance video and defendant’s post-offense flight/disposal of weapon were emphasized.
Jury rejected insanity defense; appellate court reviewed sufficiency of evidence under Jackson v. Virginia and affirmed conviction and life sentence, but remanded to correct a clerical error in the Uniform Commitment Order (UCO).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence on insanity defense	State: evidence supports conviction; defendant failed to prove insanity by preponderance	Francois: expert and lay testimony show schizophrenia and delusions that prevented distinguishing right from wrong	Affirmed — any rational juror could find defendant failed to prove insanity; jury credited State experts and conduct (video, flight, disposal of weapon) supported sanity finding
Sentencing / failure to consider mitigating factors (Dorthey)	State: mandatory life for 2nd-degree murder is constitutional and presumptively proper	Francois: age, education, no violent history, and mental illness warranted downward departure or consideration under La. C.Cr.P. art. 894.1 and Dorthey	Affirmed — defendant did not preserve mitigation argument by motion to reconsider and failed to prove "exceptional" circumstances to overcome presumption of constitutionality
Errors patent / clerical error in judgment	State: none affecting substantive sentence	Francois: noted discrepancy between oral sentence and UCO	Remanded — correct UCO to reflect life sentence imposed (clerical correction ordered)

State v. Abbott, 97 So.3d 1066 (La. App. 5 Cir.) (insanity burden and evaluation of evidence)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency review)
State v. Williams, 22 So.3d 867 (La.) (deference to jury view of evidence)
State v. Dorthey, 623 So.2d 1276 (La. 1993) (review of mandatory sentences and "exceptional" circumstances)
State v. Johnson, 709 So.2d 672 (La.) (criteria to rebut presumption of constitutionality for mandatory sentences)
State v. Pettaway, 450 So.2d 1345 (La. App. 2 Cir.) (post-offense flight and disposal of weapon as indicia of awareness of wrongdoing)
State v. Milton, 142 So.3d 157 (La. App. 5 Cir.) (rejecting insanity defense where conduct post-offense indicates awareness of wrong)
State v. Smith, 839 So.2d 1 (La.) (Eighth Amendment/excessiveness framework)