ARS 13-1201(A) Interpretation
In State v. Morgan, 128 Ariz. 362, 625 P.2d 951 (App. 1981), considering whether certain offenses, including endangerment, are lesser-included offenses of aggravated assault, this court stated that endangerment does not require a victim be aware of the actor's conduct, the very proposition for which the court cited this case. See Morgan, 128 Ariz. at 366-67, 625 P.2d at 955-56.
Merely because a victim is a necessary element of proof for endangerment does not mean that the name of the victim is a necessary element of the offense.
Indeed, 13-1201(A) provides: "A person commits endangerment by recklessly endangering another person with a substantial risk of imminent death or physical injury."
Thus, although the statute makes it clear the offense of endangerment is reckless behavior placing another person at risk, it does not require or imply that the name or exact identity of the victim is a necessary element of the offense. See, e.g., State v. Bell, 277 Mont. 482, 923 P.2d 524, 528 (Mont. 1996) (identification of particular victim not element of criminal endangerment); Scott v. Harris, 550 U.S. 372, 383, 127 S. Ct. 1769, 167 L. Ed. 2d 686 (2007) (noting flight by speeding automobile posed "extreme danger to human life").