Imminent Danger Without Observable Impairment: Positive Methamphetamine UA and Ignoring Infant Car-Seat Instructions Suffice for Neglect in Wyoming

Imminent Danger Without Observable Impairment: Positive Methamphetamine UA and Ignoring Infant Car-Seat Instructions Suffice for Neglect in Wyoming

Introduction

In In the Interest of MC, Minor Child: CC v. The State of Wyoming, 2025 WY 95 (Wyo. Aug. 27, 2025), the Wyoming Supreme Court affirmed a juvenile court’s adjudication of neglect against a father (CC) for two independent but related reasons: (1) he provided care for and drove with his premature infant while methamphetamine was in his system, and (2) he knowingly transported the infant in a standard car seat contrary to medical instructions that she required a specialized lay-down seat until she passed a “car seat challenge.” The Court held that the State proved neglect by a preponderance of the evidence without needing to show actual harm or observable intoxication, because the conduct posed an “imminent danger” to the infant’s health and safety.

The decision further clarifies Wyoming’s “nexus” requirement between drug use and neglect: a positive methamphetamine test can satisfy the nexus when the evidence supports a reasonable inference that the caregiver had the drug in his system during periods of caregiving, even absent visible impairment, particularly where the child is an infant and professionals testify to associated risks. It also underscores that failure to follow medical transport directives for medically fragile infants can itself constitute neglect based on imminent danger.

Summary of the Judgment

  • The Court reviewed a single issue: whether sufficient evidence supported the juvenile court’s finding of neglect against the father.
  • Applying the deferential sufficiency-of-the-evidence standard, and viewing the record in the light most favorable to the State, the Court affirmed.
  • Key holdings:
    • Nexus and drug use: The State proved a nexus between the father’s positive methamphetamine test and neglect. Though he did not appear “obviously under the influence,” it was reasonable to infer he had methamphetamine in his system during caregiving and while driving his infant. That condition, coupled with evidence of risks (cross-contamination, impaired judgment, fatigue), created an “imminent danger” constituting neglect.
    • Medical transport directive: Independently, the father’s decision to transport a premature infant in a standard car seat—knowing she had not passed the car seat challenge and without consulting providers—posed an imminent danger, substantiated by the infant’s oxygen desaturations when placed in the standard seat.
  • Because neglect in Wyoming does not require proof of actual harm but can be established by imminent danger, the adjudication was supported by a preponderance of the evidence.

Case Background

MC, born premature in June 2024, required a lay-down car seat to prevent dangerous drops in oxygen saturation until she passed a medically supervised car seat challenge. After both parents entered treatment and the mother struggled to care for MC in-facility, the Department of Family Services (DFS) placed MC with her paternal grandmother. The father completed inpatient treatment on July 23, 2024, moved in with the grandmother, and began caregiving. He was subject to thrice-weekly urinalysis under an existing juvenile case concerning his other children.

On August 7, 2024, the father went to DFS with MC strapped into a standard car seat. He returned a presumptive positive UA for methamphetamine (later confirmed as a low-level positive). A DFS worker initially misapprehended the father’s comment that MC was “good” to mean that she had passed the car seat challenge. Another worker noticed that the infant appeared gray, and medical evaluation showed her oxygen dropped into the low 70s within minutes in the standard seat; the clinic confirmed MC had not passed a car seat challenge. The clinician took protective custody due to the endangerment from the improper car seat.

The State filed a neglect petition on August 8, 2024. The mother entered a consent decree; the father contested. After an adjudicatory hearing, the juvenile court found neglect based on (i) caring for and transporting MC with methamphetamine in his system and (ii) the car-seat incident. The father appealed on sufficiency grounds.

Analysis

Precedents and Authorities Cited

  • Definition of Neglect: Wyo. Stat. Ann. § 14-3-202(a)(vii) — neglect is the failure or refusal to provide adequate care, supervision, or other care necessary for the child’s well-being.
  • Burden of Proof: Wyo. Stat. Ann. § 14-3-425(a) — the State must prove neglect by a preponderance of the evidence at adjudicatory hearings; see In re AE, 2024 WY 28, ¶ 16, 544 P.3d 1113 (Wyo. 2024).
  • Imminent Danger / No Actual Harm Required:
    • In re CF, 2005 WY 52, ¶ 15, 110 P.3d 283 (Wyo. 2005) — neglect can rest on “imminent danger” without actual harm.
    • Wyo. Stat. Ann. § 14-3-202(a)(ii)(D) — “imminent danger” includes threatened harm presenting an immediate and substantial risk.
    • Wyo. Stat. Ann. § 14-3-402(a)(xii)(B) — neglect adjudication can be premised on imminent danger to the child’s health or welfare.
  • Nexus Requirement (drug use to neglect):
    • In re RTB, 2024 WY 75, ¶ 18, 552 P.3d 365 (Wyo. 2024) — a positive UA alone is insufficient; there must be a nexus to inadequate care.
    • In re MC, 2013 WY 43, ¶¶ 57–60, 299 P.3d 75 (Wyo. 2013) — reviewing whether drug use is linked to conditions placing children in danger.
  • Standard of Review (Sufficiency):
    • In re AE, 2024 WY 28, ¶ 15, 544 P.3d 1113 (Wyo. 2024) (quoting In re NP, 2017 WY 18, ¶ 12, 389 P.3d 787 (Wyo. 2017)) — appellate courts give strong deference to the trial court’s fact-finding, view the evidence in the State’s favor, and draw all reasonable inferences for the State.

These authorities collectively framed the Court’s analysis: a deferential review posture; a preponderance standard; a definition of neglect that embraces threatened harm; and a requirement to connect drug use to a failure of care—met here by reasonable inference and corroborating risk evidence.

Legal Reasoning

1) Nexus between positive methamphetamine UA and neglect

The father argued that, while his UA was positive, there was no evidence he was “under the influence” at a relevant time on August 7, and therefore no basis to find neglect tied to drug use. The Court accepted the governing principle from RTB and MC that a nexus is required, but it clarified what suffices to establish that link:

  • Temporal inference: It was undisputed that the father had recently completed inpatient treatment (July 23) and had been caring for MC since that date. The positive test on August 7 permitted a reasonable inference that he had methamphetamine in his system at times while providing care and while driving with the infant to DFS.
  • Risk evidence: The DFS caseworker testified (without contradiction) about concrete risks when a caregiver has methamphetamine in his system, including cross-contamination to an infant through skin contact, impaired observation and judgment, and post-use fatigue/inattentiveness. The juvenile court found this testimony “very compelling,” and the Supreme Court accepted that credibility determination.
  • Imminent danger standard: Under Wyoming law, actual harm is unnecessary; threatened harm that presents an immediate and substantial risk to an infant’s physical health suffices. An infant’s extreme vulnerability magnifies the immediacy and substantiality of risks tied to caregiver drug use.

Notably, the Court did not require observable intoxication. Instead, it held that caring for and transporting an infant while methamphetamine is in the caregiver’s system can constitute neglect where the record, viewed favorably to the State, supports reasonable inferences of imminent danger.

2) Disregard of medical transport directive (car seat challenge) as independent neglect ground

Separately, the Court held that the father’s decision to transport MC in a standard car seat—despite knowing she had not passed the car seat challenge and without consulting medical providers—posed an imminent danger. The medical evaluation showing oxygen saturations dropping into the 70s within minutes corroborated the risk. MC did not pass a car seat challenge until August 19.

Because the lay-down car seat was a prescribed safeguard necessary for this infant’s well-being, ignoring it fell squarely within “failure to provide ... any other care necessary for the child’s well-being” under § 14-3-202(a)(vii). The Court emphasized that the father’s belief that the infant was “too big” for the seat could not displace medical directives, particularly without consultation.

3) Standard of review controlled the outcome

The Court reiterated the highly deferential sufficiency review: it credited the State’s witnesses, disregarded conflicting defense inferences, and drew every fair inference in the State’s favor. Two evidentiary pillars—drug presence during caregiving and the car-seat violation—each supported an “imminent danger” finding by a preponderance. Together they made the adjudication unassailable on appeal.

Impact and Significance

  • Clarifies “nexus” in drug-related neglect: The Court confirms that the nexus between a positive UA and neglect can be proven by reasonable temporal inference that the caregiver had the substance in his system during caregiving, plus testimony describing risks to an infant. Observable intoxication or actual harm is not required.
  • Elevates compliance with medical directives for infants: Ignoring specialized medical instructions—here, the lay-down car seat pending a car seat challenge—can, by itself, constitute neglect based on imminent danger. Caregivers must consult medical providers before deviating from such directives.
  • Reinforces protective, risk-based adjudications: The opinion leans into Wyoming’s doctrine that imminent danger suffices, especially with medically fragile children. This may encourage early interventions and protective actions when risk indicators are credible and documented.
  • Practical effects for litigation:
    • For the State/DFS: Document timelines showing caregiving overlaps with positive tests; obtain confirmatory lab results; elicit concrete risk testimony (even from caseworkers, if unrebutted); preserve communications (texts) evidencing parental knowledge of medical requirements.
    • For defense counsel: To rebut nexus, develop evidence on timing of ingestion versus caregiving, negative or diluted confirmatory results, expert testimony challenging generalized risk claims (e.g., cross-contamination), and proof of compliance with medical directives (or provider-approved deviations).
    • For juvenile courts: The case supports findings of neglect where a preponderance shows drug presence during caregiving of an infant and/or deliberate deviation from medical safety protocols—even if the caregiver appears sober.
  • Boundary-setting on evidence: While the Court credited the caseworker’s testimony on meth-related risks, future challenges may test whether medical expert testimony is necessary in closer cases or with older children. Here, the infant’s vulnerability and corroborating clinical events made expert testimony unnecessary.

Complex Concepts Simplified

  • Preponderance of the evidence: The factfinder must be persuaded that something is more likely true than not (think 51% likely).
  • Imminent danger: A credible, immediate, substantial risk of harm. The law does not require that the harm has occurred—only that the risk is real and close at hand.
  • Nexus (drug use to neglect): A required connection between the caregiver’s substance use and a failure to provide adequate care or supervision that endangers the child. It is not enough that a parent used drugs; the use must relate to the child’s risk.
  • Car seat challenge: A medical test for premature or medically fragile infants to ensure they can safely tolerate a standard car seat without dangerous drops in oxygen levels. Until passing, they must use a lay-down seat.
  • Standard of review (sufficiency): On appeal, the court does not reweigh evidence; it looks only to whether a reasonable factfinder could reach the conclusion under the applicable burden when the evidence is viewed in the State’s favor.

Conclusion

CC v. State of Wyoming establishes a practical, protective rule in Wyoming juvenile law: when an infant’s caregiver has methamphetamine in his system during caregiving and credible risks are shown, a neglect finding can rest on imminent danger without evidence of visible intoxication or actual harm. Separately—and even more straightforwardly—knowingly ignoring medical transport directives designed to prevent hypoxia in a premature infant constitutes neglect. The decision refines the “nexus” requirement by allowing reasonable temporal inferences and affirms that the State’s burden is only a preponderance. Going forward, it will guide courts, agencies, and practitioners in addressing drug-related caregiving risks and enforcing medical safety requirements for medically fragile children.

Case Details

Year: 2025
Court: Supreme Court of Wyoming

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