State Ex Rel. Juvenile Department v. Garrett

Youth appeals an order of disposition that found that he had committed acts that, if committed by an adult, would constitute unlawful manufacturing of a destructive device. ORS 166.384. He challenges the sufficiency of the evidence, arguing that the state failed to prove beyond a reasonable doubt that he possessed a “destructive device.” According to youth, at best, he possessed a lawful firework, which is expressly excluded from the statutory definition of “destructive device.” On de novo review, ORS 419A.200(6)(b), we affirm.

The relevant facts are not in dispute. Youth, while an…