State v. Lisboa
85 A.3d 1244
Conn. App. Ct.2014Background
- Defendant Christopher Lisboa was tried by a three-judge panel and convicted of murder under §53a-54a and assault in the first degree under §53a-59(a)(1).
- Panel found, unanimously, that Lisboa acted with the intent to cause Rios's death and that his stabbing caused the death.
- Evidence showed a history of animosity, prior fights, and a plan to lure Rios to Lisboa’s apartment.
- Lisboa’s belongings had been stolen prior to the incident; he later placed a $2000 bounty for Rios to exact revenge.
- A hunting knife was found and testified to as the weapon used; witnesses described the luring and ambush setup orchestrated by Lisboa and Jennifer Stewart.
- Lisboa challenged the sufficiency of the evidence on intent; the court affirmed the conviction and merged the murder and assault convictions, imposing a 48-year sentence with 25 years to serve and 10 years of special parole.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence suffices to prove Lisboa intended to kill Rios | Lisboa | Lisboa | Yes, sufficient to infer intent to kill |
| What standard governs sufficiency review in this case | State | Lisboa | Two-part test; view most favorable to sustaining verdict; cannot substitute own judgment |
| Whether post-attack conduct supports intent | State | Lisboa | Yes; conscious-ness of guilt inferred from conduct and false home-invasion narrative |
| Whether circumstantial evidence and weapon use support intent | State | Lisboa | Yes; circumstantial evidence and weapon use support intent to kill |
Key Cases Cited
- State v. Sadowski, 146 Conn. App. 693 (2013) (affords framework for sufficiency review and appellate standard of review)
- State v. Andrews, 114 Conn. App. 738 (2009) (intent and circumstantial evidence may be inferred from surrounding facts)
- State v. Salaman, 97 Conn. App. 670 (2006) (circumstantial evidence may establish intent; natural consequences inference allowed)
- State v. LaSalle, 95 Conn. App. 263 (2006) (consciousness of guilt shown by actions after crime (washing knife))
