State of Idaho v. Gannon Manuelito

CourtIdaho Supreme Court
DecidedMay 7, 2026
Docket51595
StatusPublished

This text of State of Idaho v. Gannon Manuelito (State of Idaho v. Gannon Manuelito) is published on Counsel Stack Legal Research, covering Idaho Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Idaho v. Gannon Manuelito, (Idaho 2026).

Opinion

IN THE SUPREME COURT OF THE STATE OF IDAHO Docket No. 51595

STATE OF IDAHO, ) ) Plaintiff-Appellant, ) Boise, January 2026 Term ) v. ) Opinion Filed: May 7, 2026 ) GANNON MANUELITO, ) Melanie Gagnepain, Clerk ) Defendant-Respondent. )

Appeal from the District Court of the Fourth Judicial District, State of Idaho, Ada County. Derrick J. O’Neill, District Judge. Michael McLennan, Magistrate Judge.

The order of the district court is reversed, and the case is remanded.

Raúl R. Labrador, Idaho Attorney General, Boise, for Appellant State of Idaho. Allison C. Jaros argued.

Erik R. Lehtinen, State Appellate Public Defender, Boise, for Respondent Gannon Manuelito. Jacob L. Westerfield argued. _____________________

MEYER, Justice. The State appeals the district court’s order dismissing criminal charges against Gannon Manuelito. Manuelito was initially charged with possession of a controlled substance, possession of marijuana in excess of three ounces, possession of drug paraphernalia, and driving under the influence. Following Manuelito’s motion to dismiss, the district court determined that Idaho’s overdose immunity statute, Idaho Code section 37-2739C, applied to Manuelito, thereby granting him immunity from prosecution for the possession offenses. We reverse the district court’s order because the record contains no showing that Manuelito either experienced a drug-related medical emergency or was in need of medical assistance. I. FACTUAL AND PROCEDURAL BACKGROUND On May 7, 2023, a Flying-J truck stop manager was informed by a customer that a person, later identified as Manuelito, “may be . . . in distress in [the] parking lot.” The manager observed Manuelito apparently “unconscious” in the driver’s seat of a running vehicle. The manager attempted to rouse Manuelito by “shout[ing] into the vehicle more than once” through the open rear window. He eventually opened the driver’s side door and turned off the car. The manager

1 heard Manuelito make “gurgling” sounds and likened it to “drooling,” which “seemed like the byproduct of a short cough.” Manuelito’s breathing was “shallow at best.” Believing Manuelito was suffering from an “overdose or pass[ed] out from alcohol consumption or other drug use[,]” the manager called 911. Ada County Dispatch considered the call a “medical emergency” and dispatched Emergency Medical Services (EMS) paramedics before sending law enforcement. Shortly after, Officer Jaramillo of the Boise Police Department responded to “an EMS assist call.” Emergency dispatch logged the call as a “Priority 2,” which means that law enforcement responds “quicker . . . while keeping the laws of the streets.” Once on the scene, a paramedic informed Officer Jaramillo that “they had located a bong in the back seat.” Officer Jaramillo testified that the bong “was in plain view . . . . It was sitting in the back seat behind the driver’s seat on the floorboard.” Before contacting Manuelito, the officer “allow[ed] EMS to consult and triage [Manuelito] for [his] well-being . . . .” Upon contact, Officer Jaramillo “could smell a strong odor of alcohol coming from inside the vehicle.” When the officer spoke with Manuelito, “[h]e had slow slurred speech, and . . . [h]e had trouble answering a simple line of questions.” Officer Jaramillo conducted a DUI investigation. Manuelito provided two breath samples, which showed that his blood alcohol content (BAC) was nearly twice the legal limit. Officer Jaramillo also searched Manuelito’s vehicle and discovered drug paraphernalia, including a grinder with marijuana residue, a smoking bowl with burnt marijuana residue, and an empty THC cartridge. In the back seat, the officer found a cooler containing a bag of marijuana weighing approximately 12.29 ounces. Inside the cooler was a backpack with more marijuana and a bag that contained the hallucinogen dimethyltryptamine (DMT). The officer also discovered a THC vape pen in Manuelito’s pocket. The State charged Manuelito with possession of marijuana in excess of three ounces, possession of a controlled substance (DMT), and possession of drug paraphernalia, in violation of Idaho Code sections 37-2732(e), 37-2732(c)(3), and 37-2734A, respectively, as well as operating a vehicle while under the influence, under Idaho Code section 18-8004. At the preliminary hearing, the State called Officer Jaramillo to testify. Manuelito called two witnesses: the Flying J manager and an Ada County Sheriff’s Office dispatch supervisor. Manuelito raised an oral motion to dismiss the drug-related charges alleged against him, based on

2 a lack of jurisdiction. The magistrate court denied the motion and bound the case over to the district court after determining that the State “met its burden by a probable cause standard establishing that a crime did occur, and they did establish all of the elements.” The magistrate court did not “find that there’s any significant evidence that it was a drug-related medical emergency.” Manuelito pleaded not guilty at his arraignment in the district court. He then filed a motion to dismiss under Idaho Code section 19-815A, which provides that a criminal defendant may file a motion to dismiss to challenge the sufficiency of evidence adduced at a preliminary hearing. I.C. § 19-815A. Manuelito argued that “there was no probable cause to bring forward the current charge” because prosecution is barred under Idaho’s overdose immunity statute, Idaho Code section 37-2739C. He contended that immunity under section 37-2739C(2) applies when a third party (the manager) calls 911 to request medical assistance for a stranger (Manuelito) who was experiencing a medical emergency. Manuelito concurrently filed a motion to take judicial notice of the audio recording of the preliminary hearing and the dispatch audio admitted as evidence at the preliminary hearing. The district court denied both motions because the court needed “a record to render an appealable decision.” After Manuelito obtained an expedited preliminary hearing transcript, he renewed his motion to dismiss under Idaho Code section 19-815A, which incorporated his previous arguments. The district court denied the motion, explaining that it was “unable to conclude” that the magistrate court held Manuelito “to answer without reasonable or probable cause.” The court declined Manuelito’s request for the district court to “substitute its judgment for that of the magistrate [court] as to the weight of the evidence.” Manuelito subsequently filed a motion to dismiss under Idaho Code section 37-2739C(2), asking the district court to dismiss counts one through three (the possession of controlled substances and paraphernalia charges). Manuelito contended that prosecution of the possession charges was barred because people experiencing a drug-related medical emergency cannot be prosecuted for drug or paraphernalia possession or use if evidence is obtained as a result of seeking medical assistance. Manuelito asserted that the statute was unambiguous and that its purpose was to encourage emergency calls without fear of prosecution. Manuelito claimed that the facts of his case are “the exact scenario the legislature intended to cover.” Opposing the motion, the State argued that for the protections of Idaho Code section 37- 2739C(2) to apply, a defendant must actually experience a drug-related medical emergency and

3 require medical assistance. The State contended that the statute offers immunity only to those in genuine emergencies, not to those acting solely on another person’s good-faith belief. The State argued that the statute was unambiguous, and it relied on principles of statutory interpretation and public policy to support its position that cases in which the defendant was simply intoxicated and did not receive medical aid are not immune from prosecution.

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State of Idaho v. Gannon Manuelito, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-idaho-v-gannon-manuelito-idaho-2026.