State v. Valdez

CourtNew Mexico Supreme Court
DecidedFebruary 5, 2026
StatusUnpublished

This text of State v. Valdez (State v. Valdez) is published on Counsel Stack Legal Research, covering New Mexico Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Valdez, (N.M. 2026).

Opinion

The slip opinion is the first version of an opinion released by the Chief Clerk of the Supreme Court. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Chief Clerk for compliance with Rule 23- 112 NMRA, authenticated and formally published. The slip opinion may contain deviations from the formal authenticated opinion.

1 IN THE SUPREME COURT OF THE STATE OF NEW MEXICO

2 Opinion Number:

3 Filing Date: February 5, 2026

4 NO. S-1-SC-40228

5 STATE OF NEW MEXICO,

6 Plaintiff-Appellee,

7 v.

8 STEVEN P. VALDEZ,

9 Defendant-Appellant.

10 APPEAL FROM THE DISTRICT COURT OF DOÑA ANA COUNTY 11 Richard M. Jacquez, District Judge

12 Bennett J. Baur, Chief Public Defender 13 Kimberly M. Chavez Cook, Appellate Defender 14 Santa Fe, NM 15 Luz C. Valverde, Assistant Appellate Defender 16 Albuquerque, NM

17 for Appellant

18 Raúl Torrez, Attorney General 19 Santa Fe, NM 20 Tyler M. Sciara, Assistant Solicitor General 21 Albuquerque, NM

22 for Appellee 1 OPINION

2 VIGIL, Justice.

3 {1} Defendant, Steven Valdez, appeals directly to this Court from his convictions

4 of first-degree willful and deliberate murder, aggravated battery with a deadly

5 weapon, aggravated assault with a deadly weapon, and aggravated fleeing from a

6 law enforcement officer. He raises two issues. First, he claims the district court

7 erroneously admitted evidence of Defendant’s prior bad acts committed against

8 Victim, Brittney Skaggs. And second, he claims the district court erroneously denied

9 Defendant’s motions to substitute appointed counsel. Because we reject Defendant’s

10 arguments, we affirm his convictions.

11 I. BACKGROUND

12 {2} On the morning of February 23, 2023, Victim visited the home of a friend,

13 Marie Saenz, whose testimony at Defendant’s jury trial recounted details of the day’s

14 crimes. Victim had a bruise on her face that was the result of Defendant hitting her

15 with a gun the day prior.

16 {3} Defendant arrived with a gun about thirty minutes after Victim arrived and

17 broke into the house by breaking the door jamb. He insisted that Victim leave with

18 him. Victim refused, stating that she was waiting for her mother. Defendant refused

19 to leave. Saenz threatened to call the police if Defendant did not leave. In response, 1 Defendant queried, “‘Who are you going to call?’” and called Saenz a “‘bitch’” and

2 hit her in the face with a gun.

3 {4} Stunned, Saenz retreated to her bedroom and called 911. Defendant then

4 punched Victim in the face in the kitchen. Victim and Saenz hid in the bathroom.

5 Defendant told Victim to get out of the bathroom. When she did, testified Saenz,

6 Defendant “punched her and shot her, punched her and shot her . . . five times.”

7 However, when cross-examined, Saenz could not explain how he executed the

8 maneuver; the crime scene technician recovered only a single fired cartridge from

9 the scene, and Victim had only two gunshot wounds, which may have been caused

10 by a single bullet.

11 {5} Defendant then dragged Victim out of the house by her hair. Once outside,

12 Defendant stopped a car, explaining that Victim was injured in a drive-by shooting

13 gone wrong. Defendant helped load Victim into the backseat. Saenz testified that

14 Defendant wanted Victim brought to the hospital in the car.

15 {6} A police officer responding to the 911 call intercepted the car. Defendant was

16 disorderly: he threatened to call the police on the police officer and tried to climb

17 back into the car to leave. In the end, Defendant ran away, and the officer began life-

18 saving measures on Victim, whose breathing was agonal and almost nonexistent. 1 The fire department took over Victim’s treatment upon arrival, but Victim died from

2 her injuries.

3 {7} Another officer responded to a call that Defendant fled the scene on his

4 motorcycle. The officer encountered Defendant about a mile away from the

5 shooting. Defendant accelerated to about eighty-five miles per hour, ran multiple red

6 lights, and drove into oncoming traffic. Defendant eventually crashed and was

7 arrested. The officer found an empty pistol magazine, a lighter, and two pipes on

8 Defendant’s person.

9 {8} Defendant’s later indictment and trial by a jury resulted in his convictions for

10 the first-degree willful and deliberate murder of Victim, NMSA 1978, § 30-2-

11 1(A)(1) (1994); aggravated battery with a deadly weapon against Saenz, NMSA

12 1978, § 30-3-5(C) (1969); aggravated assault with a deadly weapon against Saenz,

13 NMSA 1978, § 30-3-2(A) (1963); and aggravated fleeing from a law enforcement

14 officer, NMSA 1978, § 30-22-1.1 (2003, amended 2022). The district court directed

15 a verdict of acquittal on a charge of tampering with evidence, NMSA 1978, § 30-

16 22-5 (2003). Defendant was sentenced to life in prison plus thirteen years. Defendant

17 appeals directly to this Court pursuant to Article VI, Section 2 of the New Mexico

18 Constitution. See id. (“Appeals from a judgment of the district court imposing a

19 sentence of . . . life imprisonment shall be taken directly to the supreme court.”). 1 {9} Additional facts will be provided as necessary.

2 II. DISCUSSION

3 A. The District Court Properly Admitted the Prior Acts Evidence 4 Challenged by Defendant

5 {10} Defendant challenges the admission of testimony about his prior acts of

6 domestic violence against Victim. Defendant does not challenge the district court’s

7 admission of this evidence pursuant to Rule 11-404(B)(2) NMRA. See id. (providing

8 that evidence of a crime, wrong, or other act may be used for a purpose other than

9 propensity, such as motive or intent). Nor does Defendant challenge the district

10 court’s admission of this evidence pursuant to Rule 11-804(B)(5) NMRA—

11 sometimes called the forfeiture-by-wrongdoing exception 1—which provides a

12 hearsay exception for statements “offered against a party who wrongfully caused the

13 declarant’s unavailability.” Defendant only argues that the district court should have

14 excluded evidence of Defendant’s prior bad acts pursuant to Rule 11-403 NMRA,

15 which provides that a court may exclude otherwise admissible evidence “if its

16 probative value is substantially outweighed by a danger of . . . unfair prejudice,

1 As we explained in State v. Farrington, 2020-NMSC-022, ¶¶ 13, 15, 476 P.3d 1231, there is a constitutional dimension to the Rule 11-804(B)(5) hearsay exception in that a defendant who wrongfully causes a witness’s absence can forfeit their confrontation rights. Hence arises the term “forfeiture-by-wrongdoing.” See id. ¶¶ 1, 13 (using the term with reference to the 11-804(B)(5) hearsay exception). 1 confusing the issues, misleading the jury, undue delay, wasting time, or needlessly

2 presenting cumulative evidence.”

3 {11} We review the district court’s admission of evidence for an abuse of

4 discretion, and we cannot conclude the district court abused its discretion unless “the

5 ruling is clearly against the logic and effect of the facts and circumstances of the

6 case,” that is, “clearly untenable or not justified by reason.” State v. Otto, 2007-

7 NMSC-012, ¶¶ 9, 14, 141 N.M. 443, 157 P.3d 8 (internal quotation marks and

8 citation omitted).

9 {12} Defendant argues that the district court erroneously admitted the following

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Bluebook (online)
State v. Valdez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-valdez-nm-2026.