The New Mexico Supreme Court has remanded a case challenging indeterminate sex-offender parole terms back to the district court for reconsideration in light of a recent precedent-setting decision. In *Caruth v. State of New Mexico*, filed Nov. 20, 2025, the high court vacated an abeyance order and directed the lower court to review petitioner David Caruth's habeas corpus claims under new legal standards established in *Aragon v. Martinez*.
Caruth, representing himself pro se from Chaparral, New Mexico, had petitioned for release from indeterminate sex-offender parole, arguing that the state failed to hold timely duration review hearings as required under New Mexico Statutes Annotated Section 31-21-10.1(C). The Second Judicial District Court initially denied his request for release, prompting Caruth to seek certiorari review from the state's highest court.
The case represents part of ongoing litigation surrounding New Mexico's sex-offender supervision statutes and procedural requirements for parole duration reviews. Under NMSA 31-21-10.1(C), enacted in 2007, certain procedural safeguards govern how long individuals can remain on indeterminate parole supervision. Caruth's petition specifically challenged whether his continued detention violated these statutory requirements when the state allegedly failed to conduct mandated hearings within prescribed timeframes.
Rather than immediately ruling on the merits, the Supreme Court placed *Caruth* in abeyance pending its decision in the related case *Aragon v. Martinez*. This procedural move reflected the court's recognition that legal issues in *Aragon* would directly impact how *Caruth's* claims should be evaluated. The *Aragon* decision, issued July 14, 2025, with mandate filed Aug. 18, 2025, established new precedent regarding habeas corpus relief for individuals challenging sex-offender parole terms.
In its dispositional order, Justice Michael E. Vigil wrote that the *Aragon* opinion "addresses and significantly affects the issue of law presented in this case." The court specifically directed the district court to reconsider Caruth's right to habeas relief "in accordance with Aragon, paragraph 42," suggesting that particular section of the *Aragon* decision contains the relevant legal standard for evaluating such claims.
The Supreme Court chose to resolve *Caruth* through a nonprecedential dispositional order rather than a full published opinion, exercising discretion under Rule 12-405(B)(1) of the New Mexico Rules of Appellate Procedure. This approach allows the court to efficiently dispose of cases where established precedent provides clear guidance without creating additional binding authority.
Attorney General Raúl Torrez's office represented the state respondents, including Hector Rios, identified as the warden in the case. The involvement of a warden as a named respondent suggests Caruth may have been incarcerated or under institutional supervision during the proceedings, though the order does not specify his exact custody status.
The case highlights ongoing challenges in New Mexico's sex-offender supervision system, particularly regarding compliance with statutory timing requirements for parole review hearings. The *Aragon* precedent appears to have established more favorable standards for individuals seeking habeas relief in these circumstances, prompting the Supreme Court to ensure lower courts apply the updated legal framework.
District Judge Bruce C. Fox of the Second Judicial District will now reconsider Caruth's petition under the *Aragon* standards. The remand order suggests that application of the new precedent could potentially lead to a different outcome than the district court's initial denial of relief.
The unanimous five-justice decision was joined by Chief Justice David K. Thomson and Justices C. Shannon Bacon, Julie J. Vargas, and Briana H. Zamora. The court's quick resolution following the *Aragon* mandate demonstrates judicial efficiency in applying new precedent to pending cases with similar legal issues.
For individuals challenging sex-offender parole terms in New Mexico, the *Caruth* remand signals that courts must now evaluate habeas claims under the framework established in *Aragon*. While the specific details of that precedent are not elaborated in the *Caruth* order, the remand suggests it may provide more robust procedural protections or clearer standards for when statutory violations warrant relief.
The case will now return to the district court level, where Judge Fox must apply the *Aragon* precedent to determine whether Caruth's allegations of untimely duration review hearings entitle him to release from indeterminate parole supervision. The outcome could have implications for similar challenges throughout New Mexico's correctional and supervision system.
As an unpublished decision under Rule 12-405, the *Caruth* order has limited precedential value but demonstrates how the Supreme Court efficiently handles cases affected by intervening legal developments through its abeyance and remand procedures.