State v. Cristobal
2014 UT App 55
| Utah Ct. App. | 2014Background
- Cristobal was convicted of first degree felony aggravated robbery for participating in a Springville convenience-store robbery in November 2010.
- At trial, Cristobal moved for a directed verdict after the State rested, arguing the evidence lacked a sufficient nexus tying him to the crime.
- The trial court denied the motion, and a jury convicted Cristobal; he received an indeterminate prison term of five years to life.
- The State’s evidence included clerk testimony that two masked men threatened him with a knife and demanded cash, establishing a robbery and use of a dangerous weapon.
- Surveillance video and investigating officers corroborated the robbery and knife threat, and DNA analysis linked blood spatters to Cristobal.
- The court applied the standard that a directed verdict is proper only if the evidence fails to establish a prima facie case, and held that the evidence supported the jury’s conclusion beyond a reasonable doubt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the evidence legally sufficient for aggravated robbery? | State asserts sufficient evidence linking Cristobal to the robbery via DNA, blood spatter, and procedural testimony. | Cristobal contends the State failed to establish a nexus tying him to the crime. | Yes; evidence supports the elements beyond a reasonable doubt. |
| Are the inferences from circumstantial evidence reasonable and sufficient? | Inferences from血 evidence and surveillance reasonably connect Cristobal to the robbery. | Inferences are speculative and insufficient to prove participation. | Yes; inferences are logical, probable, and not speculative. |
Key Cases Cited
- State v. Montoya, 2004 UT 5 (Utah) (directed verdict standard; evidence need only support a prima facie case)
- State v. Emmett, 839 P.2d 781 (Utah 1992) (prima facie case requires evidence of all elements)
- United States v. Jones, 49 F.3d 628 (10th Cir. 1995) (circumstantial evidence requires reasonable inferences)
- State v. Cristobal, 2010 UT App 228, 238 P.3d 1096 (Utah App. 2010) (circumstantial evidence and reasonable inferences allowed)
- State v. Workman, 852 P.2d 981 (Utah 1993) (reasonable inferences must be logical and probabilistic)
- Sunward Corp. v. Dun & Bradstreet, Inc., 811 F.2d 511 (10th Cir. 1987) (reasonable inference standard for circumstantial evidence)