State v. Webb, 296 P.3d 1247

Webb signed Nicole’s Release Form authorizing a tongue piercing without confirming with Nicole’s parent.
Nicole fainted at the tattoo parlor and sustained dental injuries; there was no immediate medical treatment or 911 call.
Webb transported Nicole home and did not inform Nicole’s mother or seek medical attention after the accident.
The State charged Webb with abandonment resulting in great bodily harm, forgery, and contributing to the delinquency of a minor; forgery was later nolle prossed.
The jury convicted Webb of contributing to the delinquency of a minor and of child abuse by endangerment; Chavez changed the endangerment standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence proves substantial and foreseeable risk to the child	State argued signing the Release Form created risk	Webb contends piercing itself did not create serious risk	Insufficient evidence to prove substantial risk of harm
Whether the evidence supports contributing to the delinquency of a minor	State asserts Webb caused Nicole to deceive her mother	Webb did not actively encourage deception	Sufficient evidence to support CDM

State v. Chavez, 146 N.M. 434 (2009) (endangerment standard requires substantial and foreseeable risk)
State v. Graham, 137 N.M. 197 (2005) (delineated risk approach prior to Chavez)
State v. Gonzales, 150 N.M. 494 (2011) (factors for endangerment: gravity of risk, statutory violation, likelihood of harm)
State v. Dietrich, 145 N.M. 733 (2009) (CDM sufficiency; causation of delinquency through minor’s acts)
State v. Romero, 128 N.M. 806 (2000) (jury determines CDM in context of reasonable command/permission)
State v. Pitts, 103 N.M. 778 (1986) (broadened protection to children under CDM)
State v. Trevino, 116 N.M. 528 (1993) (jurisprudence on determining CDM based on acts leading to delinquency)