The New Mexico Supreme Court affirmed the convictions of Steven Valdez for first-degree willful and deliberate murder, aggravated battery with a deadly weapon, aggravated assault with a deadly weapon, and aggravated fleeing from a law enforcement officer in an opinion filed Feb. 5, 2026.
Valdez appealed directly to the state's highest court from his convictions in Doña Ana County District Court, raising two primary challenges to his trial proceedings. The court rejected both arguments and affirmed the lower court's judgment.
The case stems from events that occurred on Feb. 23, 2023, when Valdez committed violent crimes against victim Brittney Skaggs. According to trial testimony from Marie Saenz, a friend of the victim, Skaggs visited Saenz's home that morning bearing a facial bruise that resulted from Valdez hitting her with a gun the previous day.
Approximately 30 minutes after Skaggs arrived at the residence, Valdez appeared armed with a gun and broke into the house by damaging the door jamb. He demanded that Skaggs leave with him, but she refused, stating she was waiting for her mother. When Valdez refused to leave the premises, Saenz threatened to call police.
The prosecution successfully convinced a jury that Valdez committed first-degree willful and deliberate murder along with the additional felony charges. The case proceeded directly to the Supreme Court under the state's appellate procedures for capital cases.
Valdez's first argument on appeal centered on his claim that the district court erroneously admitted evidence of his prior bad acts committed against Skaggs. This type of evidence, often referred to as "prior bad acts" evidence, is generally inadmissible under standard evidentiary rules unless it meets specific exceptions. Defense attorneys frequently challenge such evidence as overly prejudicial and argue it should be excluded from trial.
The admission of prior bad acts evidence is governed by strict legal standards designed to prevent unfair prejudice against defendants while allowing relevant evidence that helps establish elements of the charged crimes. Courts must balance the probative value of such evidence against its potential to inflame the jury or create unfair bias.
In this case, the evidence included testimony about Valdez hitting Skaggs with a gun the day before the fatal incident, which left her with facial bruising visible when she arrived at Saenz's home. The prosecution likely argued this evidence was relevant to establish the relationship between the parties, Valdez's state of mind, and the context surrounding the charged crimes.
Valdez's second argument challenged the district court's denial of his motions to substitute appointed counsel. The right to counsel is fundamental in criminal proceedings, and defendants may seek to replace their appointed attorneys under certain circumstances. However, courts typically grant such motions only when there is good cause, such as an irreconcilable conflict between attorney and client or inadequate representation.
The Supreme Court's opinion, authored by Justice Vigil, systematically addressed both of Valdez's appellate arguments. The court found that the district court properly admitted the prior bad acts evidence, determining it met the legal standards for admission and that any potential prejudice did not outweigh its probative value.
Regarding the substitution of counsel issue, the court concluded that the district court acted within its discretion when it denied Valdez's motions. The appellate court found no abuse of discretion or violation of Valdez's constitutional right to effective assistance of counsel.
The case was prosecuted by the New Mexico Attorney General's Office, with Attorney General Raúl Torrez overseeing the prosecution and Assistant Solicitor General Tyler Sciara handling the appellate proceedings. Valdez was represented by the Chief Public Defender's Office, with Chief Public Defender Bennett Baur, Appellate Defender Kimberly Chavez Cook, and Assistant Appellate Defender Luz Valverde providing his defense.
The original trial took place in Doña Ana County District Court under Judge Richard Jacquez. The case proceeded through the standard criminal justice process, from arraignment through trial and sentencing, before reaching the Supreme Court on direct appeal.
The Supreme Court's affirmation of Valdez's convictions closes this chapter of the criminal proceedings, though the defendant may still have options for post-conviction relief through other legal mechanisms. The decision reinforces established precedent regarding the admission of prior bad acts evidence and the standards for substituting appointed counsel in criminal cases.
This case demonstrates the careful balance courts must strike between ensuring fair trials for defendants while allowing prosecutors to present relevant evidence to prove their cases. The Supreme Court's detailed review of both evidentiary and procedural issues provides guidance for future criminal cases involving similar legal questions.