State of Idaho v. Chance Steve Richard Worosz
CourtIdaho Court of Appeals
Date FiledJuly 31, 2026
Docket52402
StatusPublished
📰 News Coverage: Read the LAWS.com news report on this case
Full Opinion
IN THE COURT OF APPEALS OF THE STATE OF IDAHO
Docket No. 52402
STATE OF IDAHO, )
) Filed: July 31, 2026
Plaintiff-Respondent, )
) Melanie Gagnepain, Clerk
v. )
) THIS IS AN UNPUBLISHED
CHANCE STEVE RICHARD ) OPINION AND SHALL NOT
WOROSZ, ) BE CITED AS AUTHORITY
)
Defendant-Appellant. )
)
Appeal from the District Court of the Fourth Judicial District, State of Idaho, Ada
County. Hon. Peter G. Barton, District Judge.
Judgment of conviction for possession of a controlled substance, affirmed.
Erik R. Lehtinen, State Appellate Public Defender; Sally J. Cooley, Deputy
Appellate Public Defender, Boise, for appellant. Sally J. Cooley argued.
Hon. Raúl R. Labrador, Attorney General; Jaden Steeves, Deputy Attorney
General, Boise, for respondent. Jaden Steeves argued.
________________________________________________
LORELLO, Judge
Chance Steve Richard Worosz appeals from his judgment of conviction for possession of
a controlled substance. We affirm.
I.
FACTUAL AND PROCEDURAL BACKGROUND
In the early morning hours, an officer woke Worosz as he slept in a park. The officer
arrested Worosz for remaining in the park after hours and searched him incident to the arrest. The
search yielded more than fifty unused syringes, along with a used syringe containing a dried, white
residue. The used syringe field-tested positive for methamphetamine. When questioned by the
officer, Worosz indicated he participated in a needle exchange program at the park and that the
1
items found in his possession were from the program. The State charged Worosz with possession
of a controlled substance, possession of drug paraphernalia, and a sentencing enhancement for
prior controlled substance violations.1
Worosz filed a motion in which he argued his arrest was unlawful because his conduct and
possession of the syringes were protected under the Syringe and Needle Exchange Act (SNEA).2
Worosz also asserted the SNEA conflicted with Idaho law criminalizing the possession of
controlled substances and drug paraphernalia. The district court held a hearing on the motion, at
which the officer and Worosz testified. Ultimately, the district court denied the motion, finding
that the arrest and resulting search were lawful. Thereafter, Worosz entered a conditional guilty
plea to possession of a controlled substance, I.C. § 37-2732(c)(1), reserving his right to appeal the
denial of his motion. In exchange for his guilty plea, the State dismissed the possession of drug
paraphernalia charge and the sentencing enhancement. Worosz appeals.
II.
STANDARD OF REVIEW
This Court applies an abuse of discretion standard when it reviews a trial court’s decision
on a motion to dismiss. State v. Eversole, 160 Idaho 239, 244, 371 P.3d 293, 298 (2016). When
a trial court’s discretionary decision is reviewed on appeal, the appellate court conducts a
multi-tiered inquiry to determine whether the trial court: (1) correctly perceived the issue as one
of discretion; (2) acted within the boundaries of such discretion; (3) acted consistently with any
legal standards applicable to the specific choices before it; and (4) reached its decision by an
exercise of reason. State v. Herrera, 164 Idaho 261, 270, 429 P.3d 149, 158 (2018).
1
The State initially charged Worosz with an additional possession of a controlled substance
violation but later dismissed the charge.
2
The record shows that Worosz filed a motion to suppress the evidence found during the
search. The district court recognized, however, that because Worosz sought immunity under the
SNEA, a favorable ruling would result in dismissal of the drug paraphernalia charge. The district
court therefore treated Worosz’s motion as one to dismiss. This Court will do the same.
2
III.
ANALYSIS
Worosz asserts the district court abused its discretion by denying his motion “because his
conduct was protected” by the SNEA. The State responds that “any immunity conferred by” the
SNEA “only protected entities operating and supplying exchange programs.” We hold that
Worosz has failed to show the district court erred in denying his motion to dismiss.
In 2019, Idaho enacted the SNEA. I.C. §§ 37-3401 to 37-3407.3 The purpose of the SNEA
was to prevent the transmission of disease and to reduce morbidity and mortality among
individuals who inject drugs. I.C. § 37-3402. To that end, the legislature authorized the creation
of syringe and needle exchange programs, which allowed entities to facilitate the exchange of used
syringes or needles for new syringes or needles in sealed sterile packaging. I.C. § 37-3404(2)(a).
Entities operating these exchange programs were required to comply with the SNEA’s provisions,
as well as the rules promulgated by the Idaho Department of Health and Welfare. I.C.
§ 37-3404(1)(a). Under the SNEA, entities operating exchange programs were required to provide
the recipient of new syringes or needles with verbal and written instructions on how to prevent the
transmission of blood-borne diseases. I.C. § 37-3404(2)(b)(i). Entities were also required to
provide recipients with options for obtaining services to treat substance use disorder, testing for
blood-borne disease, and an opioid antagonist. I.C. § 37-3404(2)(b)(ii). Additionally, the entities
were required to report annually to the Department the number of individuals participating in the
exchanges, the number of used syringes or needles exchanged, and the number of new syringes or
needles provided. I.C. § 37-3404(3). In turn, the Department was required to report to the
legislature on the activities and outcomes of the exchange programs; whether the programs
promoted illicit drug use; and whether the programs (in the director’s opinion) should be
continued, continued with modifications, or terminated. I.C. § 37-3405.
In his motion, Worosz argued his arrest was unlawful because the “statutory scheme
around” the SNEA created a situation where individuals looking to “participate in the exchange of
dirty syringes” must also break the law. This was so, Worosz maintained, because the SNEA
3
Although the SNEA was repealed in 2024, it remained in effect at the time of Worosz’s
arrest.
3
conflicted with statutes prohibiting the possession of controlled substances and drug paraphernalia,
thereby putting individuals like Worosz “between a rock and a hard place.” The district court
recognized that Worosz sought to derive “a sort of immunity” under the SNEA. However, the
district court was unpersuaded and concluded that Worosz’s immunity claim failed for three
reasons. First, the district court found that the rights and privileges of the SNEA were conferred
“to an entity” and did not “create any immunity for a defendant.” Second, the district court
concluded that the SNEA did not “change the criminality” of statutes prohibiting the possession
of controlled substances or drug paraphernalia. The district court acknowledged that the SNEA
could permit officers to “exercise discretion” to not “arrest someone . . . standing in line” at an
active needle exchange program. However, absent “explicit text [from the legislature] to do so,”
the district court found that the SNEA did not make Worosz immune from prosecution. As a
result, the district court determined that Worosz was “in exactly the same position” with or without
the SNEA because his possession of controlled substances and drug paraphernalia as an individual
remained illegal. Finally, the district court found that Worosz was not “participating in the
program at the time” of his arrest because he was not “going to the facility” or “standing in line”
at an exchange program. Instead, Worosz possessed the drugs and paraphernalia in the park after
hours when the program was not open. As a result, the district court denied Worosz’s immunity
claim and concluded that the “officer’s arrest was lawful and the resulting search incident to arrest
was not unreasonable.”
On appeal, Worosz argues the district court abused its discretion in denying his motion
because the SNEA gave him “a defense or immunity.” Worosz asserts “proper application” of the
SNEA would have protected “his conduct in possessing used syringes and even those still
containing drug residue.” According to Worosz, “the district court’s interpretation limiting the
protections offered by [the SNEA] to ‘entities’ is contrary to the plain language of the text and
erroneously dilutes the ‘potency’ of the statute.” Worosz’s argument is belied by the plain
language of the SNEA.
The SNEA provided that, “notwithstanding any provision of law to the contrary,” an “entity
may operate a syringe and needle exchange program if such entity complies with the provisions of
this section and with rules promulgated by the [D]epartment.” I.C. § 37-3404(1)(a). The SNEA
defined an “entity” as the department, a “government entity,” or “a private organization, whether
4
for profit or nonprofit.” I.C. § 37-3403(3). Worosz does not contend he fell within the definition
of an “entity.” We agree with the district court’s conclusion that the rights and privileges of the
SNEA only applied to entities and did not “create any immunity for a defendant.” Worosz also
argues that the district court’s finding that he was not participating in a needle exchange program
at the time of his arrest “does not negate his protection under the statute” because he “was a
participant in the program during the week.” That Worosz attended a needle exchange program
prior to being arrested and searched does not mean he was eligible for the protections offered to
entities by the SNEA.
Worosz further contends the SNEA conflicted with statutes criminalizing the possession
of controlled substances and drug paraphernalia. Worosz maintains that the “legislature has placed
individuals in jeopardy of criminal charges while trying to participate in an activity it has
designated as lawful” and that the district court abused its discretion “by failing to analyze the two
statutes in accordance with legal authority governing statutory interpretation.” According to
Worosz, the statutes and the SNEA conflicted because, “to be a participant in the needle exchange
program,” the “participants would need to, at least briefly, possess used and clean syringes.”
However, as stated above, the SNEA protects entities operating exchange programs--protections
that did not extend to individuals.
Finally, Worosz argues the district court erred when it determined that, even if it granted
his motion, the result would be a dismissal of the drug paraphernalia charge but not the possession
of a controlled substance charge. “Such a holding”--Worosz contends--“negated the purpose of”
the SNEA because “a participant could be charged with unlawful possession of a controlled
substance for conduct encouraged by the plain text of the statute.” Worosz’s argument fails for at
least two reasons. First, Worosz does not cite the “plain text” from the SNEA which he contends
authorized the possession of controlled substances or drug paraphernalia. Moreover, the plain
language of the SNEA shows that it did not encourage the possession of controlled substances or
drug paraphernalia--it did the opposite. Specifically, the SNEA authorized the creation of
exchange programs to prevent the transmission of disease and to reduce morbidity and mortality
among individuals who inject drugs. I.C. § 37-3402. The SNEA also required the Department to
report to the legislature on whether the programs promote illicit drug use. I.C. § 37-3405. Thus,
the plain text of the SNEA contradicts Worosz’s arguments on appeal. Because we conclude that
5
the SNEA did not offer individuals possessing controlled substances or drug paraphernalia
immunity or conflict with other statutes criminalizing the possession of controlled substances and
drug paraphernalia, Worosz’s claim that the district court erred in denying his motion to dismiss
fails.
IV.
CONCLUSION
The SNEA did not provide Worosz immunity from prosecution for possessing controlled
substances. Worosz has therefore failed to show the district court erred in denying his motion to
dismiss. Accordingly, Worosz’ judgment of conviction for possession of a controlled substance
is affirmed.
Chief Judge TRIBE and Judge Pro Tem MELANSON, CONCUR.
6