State v. King, 88 So. 3d 1147

Defendant Denord King was indicted for second degree murder under LSA-R.S. 14:30.1 and obstruction of justice by tampering with evidence under LSA-R.S. 14:130.1.
Jury convicted King on both counts after March 29–30, 2011 trial; sentenced to life without parole on murder, and 20 years on obstruction, to run concurrently.
June 16, 2010, Williams was killed; on June 15–16, 2010, multiple witnesses observed events at Chateau Ames, including defendant firing at Williams.
King gave statements to police and testified at trial; he claimed self-defense and defense-related motives.
State presented eyewitness testimony and physical evidence indicating King fired approximately thirteen shots at Williams; defense argued self-defense and lack of intent.
Trial court denied King’s post-trial motions; defense appealed challenging sufficiency of evidence, juror sleeping during trial, jury note handling, sentencing instructions, and alleged prosecutorial disclosures and witness deal issues.
Appellate court affirmed convictions and sentences, but remanded to correct a discrepancy between transcript and commitment/minute entry regarding sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for second degree murder	King argues insufficiency to prove intent to kill.	King contends self-defense negates intent.	Sufficient evidence supported intent and negated self-defense.
Effect of a sleeping juror on verdict	State relied on juror’s presence; no prejudice shown.	Defense claimed sleeping juror tainted deliberations.	No reversible error; no substantial showing juror was incapacitated.
Handling of jury note regarding verdict differences	State and defense agreed; instructions properly furnished.	Court failed to address note adequately.	Proper, no error.
Failure to inform jury of penalty ranges for certain offenses	Penalty ranges should have been explained for manslaughter/negligent homicide.	Only mandatory penalty for second-degree murder needed; ranges not required.	No error; penalty ranges not required for manslaughter/negligent homicide.
Pro se challenges re prosecutorial disclosures and witness deal	Notice of exculpatory evidence and perceived deals misled defense.	Issues not preserved; no clear deal shown.	No merit; issues not properly preserved or unsupported.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for criminal evidence (beyond reasonable doubt))
State v. Patterson, 63 So.3d 140 (La. App. 5 Cir. 2011) (circumstantial and direct evidence sufficiency reviewed under Jackson)
State v. Gonzalez, 975 So.2d 3 (La. App. 5 Cir. 2007) (inference of intent from use of deadly weapon)
State v. Knight, 34 So.3d 307 (La. App. 5 Cir. 2010) (intent to kill inferred from circumstances and injuries)
State v. Theriot, 963 So.2d 1012 (La. App. 5 Cir. 2007) (two-fold test for self-defense: imminent danger and necessity; aggressor rules)
State v. Deal, 802 So.2d 1254 (La. 2001) (mitigating factors for manslaughter; preponderance standard)
State v. Lawson, 1 So.3d 516 (La. App. 5 Cir. 2008) (review of mitigation on appellate sufficiency)
State v. Cass, 356 So.2d 396 (La. 1977) (sleeping juror and alternates; evidentiary impact)
State v. Johnson, 463 So.2d 620 (La. App. 1 Cir. 1984) (no error denying sleeping jurors without record evidence)
State ex rel. Roland v. State, 937 So.2d 846 (La. 2006) (procedural guidance on commitment/minute corrections)