We address whether the elastic strain-energy theory (minimizing the Gibbs energy of a stressed crystal) of McKenzie and co-workers [D. R. McKenzie and M. M. M. Bilek, J. Vac. Sci. Technol. A 16, 2733 (1998)] adequately explains the preferred orientation observed in carbon and BN films. In the formalism, the Gibbs energy of the cubic materials diamond and cubic boron includes the strain that occurs when the phases form, through specific structural transformations, from graphitic precursors. This treatment violates the requirement of thermodynamics that the Gibbs energy be a path-independent, state function. If the cubic phases are treated using the same (path-independent) formalism applied to the graphitic materials, the crystallographic orientation of lowest Gibbs energy is not that observed experimentally. For graphitic (hexagonal) carbon and BN, an elastic strain approach seems inappropriate because the compressive stresses in energetically deposited films are orders of magnitude higher than the elastic limit of the materials. Furthermore, using the known elastic constants of either ordered or disordered graphitic materials, the theory does not predict the orientation observed by experiment.