On October 25, 2014, 18-year-old Venancio Cisneros and his 13-year-old girlfriend, Anamarie Ojeda, were found shot to death on East Ramada Way in Santa Fe, New Mexico. The Santa Fe County Sheriff’s Office identified Ricardo Martinez as the suspect; he was located in Colorado and taken into custody.

At trial a witness testified they saw Martinez walking away from Cisneros’ car and had identified him from a photographic array, despite saying earlier that they did not have good eyesight. The New Mexico Supreme Court later reviewed the case, upheld Martinez’s convictions for two counts of first-degree murder, and affirmed two consecutive life terms. The court’s decision also announced a new per se exclusionary rule for eyewitness identifications obtained through unnecessarily suggestive police procedures, requiring suppression of both initial and subsequent identifications that stem from such procedures.