State v. Williams, 76 So. 3d 90

Defendant Eric Williams, Sr. was charged with forcible rape, aggravated battery, and false imprisonment while armed with a dangerous weapon arising from a September 9, 2007 incident in Harvey, Louisiana.
Jury convicted him of aggravated battery and false imprisonment; the forcible rape count was deadlocked and not retried.
Defendant was sentenced to eight years at hard labor for aggravated battery and eight years for false imprisonment, to run consecutively.
The defense raised an insanity defense, presenting expert testimony that defendant suffered from delusional disorder and could not distinguish right from wrong.
The State presented rebuttal psychiatry testimony that defendant could distinguish right from wrong; the jury resolved the insanity issue in favor of the State.
On appeal, defendant challenges the sufficiency of the evidence supporting the verdicts and the excessiveness of the sentences; the court affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Insanity defense sufficiency	Williams contends insanity negated criminal responsibility by preponderance.	Williams argues the evidence proves he could not distinguish right from wrong at the time.	Insanity claim rejected; rational jury could find not proven by preponderance.
Consecutive sentencing	Consecutive terms were proper because offenses were separate incidents and grave risk to community existed.	Consecutive sentences were improper since offenses stemmed from one incident.	Consecutive sentences affirmed; court did not abuse discretion.

State v. Silman, 663 So.2d 27 (La. 1995) (presumption of sanity; insanity burden on defendant by preponderance)
State v. Branch, 759 So.2d 31 (La. 2000) (procedure for insanity determination after proving elements of offense)
State v. Walker, 799 So.2d 461 (La. 2001) (concurrent vs. consecutive sentencing discretion in same-transaction cases)
State v. Scott, 952 So.2d 60 (La. App. 1 Cir. 2006) (consecutive sentences warranted by grave risk to public when separate acts)
State v. Jones, 907 So.2d 139 (La. App. 1 Cir. 2005) (consecutive sentences justified by danger to community)