State v. Chadwick-McNally, 414 P.3d 326

Background

Shanah Chadwick-McNally was charged with first-degree murder (a capital felony) and related offenses; the charging document alleged two statutory aggravators that, if found, mandate life without possibility of release or parole (LWOP).
The death penalty had been abolished in New Mexico for crimes committed on or after July 1, 2009; LWOP replaced death as the maximum sentence for capital felonies committed after that date.
The 2009 amendments repealed most procedural provisions that had applied when the death penalty existed (including mandatory bifurcation and weighing of mitigating factors).
The State sought clarification whether death-penalty procedures and Rule 5-704 (designed for death cases) apply where the State seeks LWOP; some districts had been using those procedures in LWOP cases.
The district court held Rule 5-704 and Ogden hearings do not apply to LWOP cases and precluded presentation of mitigating evidence; defendant appealed interlocutorily and the Supreme Court granted review.

Issues

Issue	State's Argument	Chadwick-McNally's Argument	Held
Applicability of Rule 5-704	Rule 5-704 applies only to death-penalty cases, not LWOP.	Rule 5-704 (death procedures) should apply when LWOP is sought because the penalties are similarly grave.	Rule 5-704 applies only to death cases; it does not extend to LWOP.
Right to Ogden probable-cause hearing on aggravators	Ogden hearings are specific to death-penalty prosecutions and thus not required for LWOP.	If Rule 5-704 doesn't apply, at minimum Ogden-style probable-cause hearings must be available to test alleged aggravators.	Ogden hearings are not required when State seeks LWOP; Ogden was premised on unique burdens of death cases.
Bifurcated guilt/sentencing proceedings	The Act (post-2009) is silent on procedure; State contends no mandatory bifurcation.	Defendant argues bifurcation should be allowed or available to reserve aggravators until after guilt phase.	Court declines to require or forbid bifurcation as a matter of course; parties may seek bifurcation under the Rules of Criminal Procedure on a case-by-case basis.
Admission of mitigating evidence at sentencing	Statute mandates LWOP if jury finds an aggravator; sentencing discretion is statutory and mitigation is precluded.	Defendant contends the Act does not bar mitigating evidence and that excluding it violates federal/state constitutions.	The Act precludes presenting mitigating evidence for sentencing when an aggravator is found; exclusion does not violate Eighth Amendment for adult offenders.

Key Cases Cited

State v. Ogden, 118 N.M. 234, 880 P.2d 845 (N.M. 1994) (authorized limited pretrial probable-cause hearing to test aggravating circumstances in death cases)
State v. Martinez, 132 N.M. 32, 43 P.3d 1042 (N.M. 2002) (explains heightened scrutiny required for death penalty imposition)
Harmelin v. Michigan, 501 U.S. 957 (1991) (upheld mandatory adult LWOP without individualized consideration of mitigating factors under Eighth Amendment)
Miller v. Alabama, 567 U.S. 460 (2012) (mandatory LWOP for juveniles violates Eighth Amendment; distinguishes juveniles from adults)
State v. Cabezuela, 350 P.3d 1145 (N.M. 2015) (states that mandatory life sentences for capital felonies are not subject to mitigation)