## Facts

- A.L.J., a minor, attended a party in a gravel pit near Greybull, Wyoming, on November 22, 1989, with roughly forty to fifty attendees, most of them juveniles, where alcohol was being consumed.
- A.L.J. brought a .25 caliber semi-automatic pistol to the party.
- On four separate occasions, A.L.J. pointed the pistol at individuals at the party.
- Police learned of the incident several days later after the mother of one of the individuals told her child to report it.
- The State filed a juvenile petition alleging A.L.J. committed a delinquent act by recklessly endangering others, based on Wyo. Stat. § 6-2-504(b).
- A jury in the juvenile proceeding found the petition’s allegations true; the jury was not asked to decide whether the pistol was loaded.
- At disposition, the district court ordered an indeterminate commitment to the Wyoming Boys’ School, suspended that disposition, and placed A.L.J. on three years of probation.
- The probation terms included random chemical testing for alcohol, suspension of driving privileges with further revocation to occur automatically upon any probation violation or new traffic citation, cooperation by A.L.J.’s parents in residential checks at the probation officer’s discretion, and reimbursement of public defender costs.
- A.L.J. appealed both the delinquency adjudication and portions of the dispositional order.

## Issues

1. Does Wyo. Stat. § 6-2-504(b) require proof that the firearm was loaded (or that the victim was placed in actual danger), or is knowingly pointing a firearm at another sufficient even if the gun is unloaded?
2. Were the probation conditions improper insofar as they (a) authorized searches of A.L.J.’s person and home without a reasonable-suspicion requirement, (b) imposed automatic revocation of driving privileges for any probation violation, and (c) required reimbursement of appointed-counsel costs without an ability-to-pay inquiry?
3. May a juvenile court impose a three-year probation term even though an adult convicted of the same offense could receive no more than one year of probation?

## Decision

- The Wyoming Supreme Court affirmed the delinquency adjudication.
- The court held that Wyo. Stat. § 6-2-504(b) does not require proof the gun was loaded or that the victims were placed in an actual state of danger; the statute criminalizes knowingly pointing a firearm at or in the direction of another “whether or not the person believes the firearm is loaded.”
- The court affirmed the three-year probation term as within juvenile dispositional authority, even if adult probation for the same offense would be capped at one year.
- The court affirmed in part and vacated in part the dispositional order, concluding certain contested probation conditions were improper or too broad:
  - Search-related terms authorizing residential checks and related searches at the probation officer’s discretion, without limits tied to suspected violations, required modification.
  - A provision making further driver’s license revocation automatic upon any probation violation or new traffic citation was invalid in its automatic form and required modification.
  - A requirement that A.L.J. reimburse public defender costs could not be imposed without first determining ability to pay.
- The case was remanded for entry of a disposition consistent with the opinion.

## Legal Principles

- When statutory text is clear, courts apply it as written; under Wyo. Stat. § 6-2-504(b), knowingly pointing a firearm at another constitutes reckless endangering “whether or not” the actor believes it is loaded, and the State need not prove the weapon was loaded.
- Juvenile dispositions are governed by the juvenile code’s purposes and limits, not by adult sentencing caps; a longer probation term for a juvenile may be authorized even when an adult maximum is shorter.
- Probation conditions must be reasonably connected to supervision goals and may not grant unlimited discretion; search-related conditions must be constrained by workable standards rather than open-ended authority.
- Driver’s license sanctions imposed as probation conditions must be tailored; automatic revocation triggered by any violation or citation, without individualized consideration, is improper.
- Costs for appointed counsel may not be assessed without an inquiry into the juvenile’s (or responsible party’s) ability to pay.

## Conclusion

In the Matter of the Interests of A.L.J. upheld a juvenile delinquency adjudication for reckless endangering based on knowingly pointing a firearm at others, held that the statute does not require proof the gun was loaded, and approved a three-year juvenile probation term, but it vacated and remanded portions of the disposition that authorized overly broad search authority, imposed automatic license revocation for any violation or citation, and required repayment of public defender costs without an ability-to-pay determination.


In the Matter of the Interests of A.L.J., A Minor, 836 P.2d 307 (1992)