Administrative Office of the Courts
FOR IMMEDIATE RELEASE
July 9, 2026
SANTA FE – The state Supreme Court today reversed a Santa Fe youth’s first-degree murder conviction and ordered the case back to the trial court with directions to enter a judgment of second-degree murder.
In a unanimous opinion, the Court ruled that state prosecutors had failed to prove that Judah Elijah Trujillo had the necessary criminal intent for a conviction of willful and deliberate first-degree murder in the shooting death of Samuel Cordero at a park in Santa Fe in 2022.
“We hold that the State failed to provide sufficient evidence that Judah acted with deliberate intent. Instead, the jury was left to speculate as to Judah’s mental state leading up to the single shot that killed Samuel,” the Court stated in an opinion written by Justice David K. Thomson.
The Court explained that “because the jury was instructed on and found all of the essential elements of second-degree murder, we conclude that the interests of justice are best served by direct remand for entry of second-degree murder.” A new trial will not be held.
Trujillo was 15 years old at the time of the killing. He met Cordero, who was 60 years old, at a park. Trujillo testified that Cordero became angry after he refused the man’s suggestion to go to nearby baseball dugouts. Trujillo claimed he was afraid that Cordero would rape him if they went to that secluded area. Cordero allegedly grabbed Trujillo’s wrist twice and punched his cheek. Trujillo testified that he stumbled, fired one shot over his shoulder while he was on the ground and left the park without knowing whether Cordero had been hit. He took Cordero’s cell phone, which had been dropped near him, and later threw it away.
A jury convicted Trujillo of first-degree murder and evidence tampering for taking and disposing of the victim’s phone. Trujillo appealed.
In today’s opinion, the Court clarified “the relationship between consciousness-of-guilt evidence and deliberate intent.” State prosecutors contended that evidence supported an inference of deliberate intent, including that Trujillo took Cordero’s phone and told a friend after the shooting that he “did something bad.”
“These are all pieces of evidence that demonstrate consciousness of guilt, but which are not probative of deliberation in this case,” the Court reasoned.
Evidence of consciousness of guilt, “must be closely scrutinized and is insufficient absent other evidence of deliberate intent or specific facts making the conduct highly probative of deliberation,” the justices stated.
The State also maintained that an inference of deliberate intent was supported by Trujillo taking a gun to his meeting with Cordero. The Court disagreed.
“We decline to adopt a rule that taking a firearm encounter, alone, supports an inference of deliberate intent to kill absent corroborating evidence of actual deliberation,” the Court wrote.
The justices further explained, “The jury heard virtually no evidence regarding the events leading up to the encounter outside of Judah’s own testimony, which was devoid of any indication that he deliberated before firing the gun.”
In challenging his murder conviction and asking for a new trial, Trujillo argued that the district court erred in instructing the jury on motive. The Court agreed the instruction should not have been given, but concluded that “our reversal of Judah’s first-degree murder conviction ameliorates any unfairness underlying his conviction potentially caused by the motive instruction.”
Court rules that provide uniform jury instructions specifically state that no instruction shall be given on the subject of motive. The state does not have to prove motive to obtain a criminal conviction.
The Court affirmed Trujillo’s conviction for evidence tampering. When the case returns to the trial court for entry of a new judgment and sentence, the justices ordered a presentence confinement credit be granted as required by state law for the time that Trujillo spent in a juvenile detention facility. The trial court had denied such a credit and originally sentenced Trujillo to 25 years in prison for murder and three years for evidence tampering, with the sentences to run concurrently. On appeal, the State agreed that a presentence confinement credit should be granted. Trujillo contended he was entitled to 495 days of credit.
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To read the decision in State v. Trujillo, No. S-1-SC-40328, please visit the New Mexico Compilation Commission’s website using the following link: https://nmonesource.com/nmos/nmsc/en/item/538390/index.do
