SANTA FE – The state Supreme Court today upheld the convictions of a Las Cruces man for murdering his girlfriend and related crimes in 2022.
In a unanimous opinion written by Justice Michael E. Vigil, the Court rejected arguments by Steven Valdez that the trial court wrongly admitted evidence about previous instances of domestic violence against the victim, Brittney Skaggs, and improperly denied his requests to replace his appointed defense lawyer.
Valdez was sentenced to life in prison and an additional 13 years for convictions of first-degree murder, aggravated fleeing from a law enforcement officer, aggravated battery with a deadly weapon against Marie Saenz, a friend of Skaggs, and aggravated assault with a deadly weapon against Saenz. In New Mexico, a life sentence requires a person to serve at least 30 years in prison before becoming eligible for parole.
The killing occurred at Saenz's home after Valdez broke into her home and demanded Skaggs leave with him. Skaggs had arrived earlier with a bruise on her face from Valdez hitting her with a gun the previous day. Valdez hit Saenz in the face with a gun after she threatened to call police. She retreated to a bedroom and called 911. Valdez punched Skaggs in the face in the kitchen. She and Saenz then hid in a bathroom. When Skaggs came out at the urging of Valdez, he repeatedly punched and shot her, according to Saenz's testimony at the trial.
Valdez dragged Skaggs out of the house by her hair and put her in a car that he stopped, telling the motorist that the victim was injured in a drive-by shooting. A police officer arrived and Valdez fled. He was arrested after crashing his motorcycle during a high-speed chase with police in which he ran multiple red lights and drove into oncoming traffic.
The Court rejected arguments by Valdez that certain evidence about his prior "bad acts" against Skaggs should have been excluded from the trial. Valdez contended that the risk the evidence prejudiced the jury outweighed its value to prove facts in the case. The justices concluded that the trial court acted within its discretion under judicial rules governing what evidence is admissible. The district court excluded evidence about sexual assaults by Valdez against his girlfriend but allowed other testimony by the girlfriend's friends about previous domestic violence, including the defendant attempting to drown Skaggs in her bathtub and hitting her in the face with a baseball bat.
In his appeal, Valdez also argued that he was denied effective legal representation because of a breakdown in communication and lack of trust in his attorney, Michael Rosenfield.
"In our view, the district court allowed ample, sometimes extensive, opportunity for Defendant to explain the reasons he wanted to change appointed counsel," the Court wrote. "Accordingly, we do not conclude that the district court abused its discretion for failure to make an adequate inquiry into whether the communication issues between Defendant and Mr. Rosenfield effectively denied Defendant the assistance of counsel."
