State v. Schaaf, 308 P.3d 160

Defendant convicted in a bench trial of negligent child abuse by endangerment and possession of drug paraphernalia.
An anonymous tip prompted a field visit by probation and law enforcement to Defendant’s home.
Four children resided at the home: a 15-year-old stepson and three five-year-old triplets.
Officers found drugs (methamphetamine) and drug paraphernalia, firearms, and a filthy, cluttered living environment.
Defendant admitted methamphetamine use in the home and that there were unsecured firearms amid the hazards.
The State asserted the conditions created a substantial and foreseeable risk of harm to the children, justifying endangerment liability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State proved a substantial and foreseeable risk of harm	State showed dangerous conditions	No empirical link to exposure; insufficient proof	Yes; evidence showed exposure risk and ongoing danger
Whether weaponry and meth use support endangerment without expert testimony	Circumstances themselves show risk	Need expert testimony per Chavez	Sufficient without expert testimony
Whether Chavez requiring empirical proof applies given circumstances	Court may infer risk from combined hazards	Empirical evidence required	Court allowed inference; not all evidence needed to be scientific

State v. Chavez, 146 N.M. 434, 211 P.3d 891 (2009-NMSC-035) (establishes substantial and foreseeable risk standard and factors for endangerment)
State v. Trossman, 146 N.M. 462, 212 P.3d 350 (2009-NMSC-034) (presence of hazards over time relevant to endangerment; actual presence of child at home in danger context)
State v. Graham, 137 N.M. 197, 109 P.3d 285 (2005-NMSC-004) (avoid parsing evidence; view the whole record for risk to child)