The New Mexico Supreme Court has upheld the convictions of Steven Valdez, a Las Cruces resident, for the 2022 murder of his girlfriend, Brittney Skaggs, and other related offenses. The decision was delivered in a unanimous opinion authored by Justice Michael E. Vigil.
Valdez challenged his convictions on several grounds, including the admission of evidence regarding previous domestic violence incidents involving Skaggs and the denial of his requests to replace his court-appointed defense attorney. The Supreme Court found no error in the trial court’s decisions on these matters.
According to testimony presented at trial, Valdez broke into the home of Marie Saenz, a friend of Skaggs. He demanded that Skaggs leave with him after she arrived at Saenz’s home with visible injuries from an earlier assault by Valdez. During the incident, Valdez assaulted both women before fatally shooting Skaggs. He then attempted to flee but was apprehended following a high-speed chase that ended when he crashed his motorcycle.
Valdez received a life sentence plus an additional 13 years for first-degree murder, aggravated fleeing from law enforcement, aggravated battery with a deadly weapon against Saenz, and aggravated assault with a deadly weapon against Saenz. Under New Mexico law, individuals sentenced to life imprisonment must serve at least 30 years before becoming eligible for parole.
In addressing Valdez’s appeal regarding evidence admissibility, the justices concluded that “the trial court acted within its discretion under judicial rules governing what evidence is admissible.” While evidence about sexual assaults was excluded by the district court, testimony from friends about prior acts of domestic violence—including attempts to drown Skaggs and striking her with a baseball bat—was permitted.
On the issue of legal representation, Valdez argued there had been a breakdown in communication and trust between himself and his attorney Michael Rosenfield. The Supreme Court stated: “In our view, the district court allowed ample, sometimes extensive, opportunity for Defendant to explain the reasons he wanted to change appointed counsel,” adding that they did not find any abuse of discretion by the lower court in handling this matter.
The full opinion in State v. Valdez (No. S-1-SC-40228) can be accessed through the New Mexico Compilation Commission’s website at https://nmonesource.com/nmos/nmsc/en/item/537835/index.do
