People v. Williams — Colorado appeals court vacates drug convictions under overdose-reporting immunity

Case
The People of the State of Colorado v. Jordyn M. Williams
Court
Colorado Court of Appeals
Judge
Judge Yun; Judge Fox; Justice Martinez
Date Decided
October 29, 2026
Docket No.
24CA0157
Topics
drug-overdose immunity; statutory interpretation; controlled substances; criminal procedure
Source
Read the full opinion

Background

Jordyn Williams called 911 after her roommate swallowed an unknown quantity of sleeping pills and cut his wrists. She stayed on the phone with dispatch for more than eighteen minutes, provided information and monitored the roommate’s breathing, and remained when police and paramedics arrived.

Williams told an officer that she was the person who called 911 and described what happened, but declined to provide her name. Police later learned her identity, discovered outstanding warrants, searched her, and found controlled substances. A jury convicted her of possessing fentanyl, methamphetamine, and cocaine. The district court had denied her pretrial claim for immunity under Colorado’s 911 Good Samaritan Law because she did not give officers her name.

The Court’s Holding

The Colorado Court of Appeals held that the statute’s requirement that an overdose reporter “identif[y] himself or herself” does not require disclosure of the reporter’s name. Rather, a person satisfies that condition by identifying herself as the person who reported the overdose or sought aid for the overdose victim.

The court found the wording ambiguous, then relied on the statute’s purpose of encouraging prompt overdose reports without fear of prosecution and on a related underage-immunity statute that expressly requires a caller to provide a name. Because Williams met the statutory conditions for immunity, the court vacated her convictions and remanded with directions to dismiss the charges.

Key Takeaways

  • Colorado’s 911 Good Samaritan Law does not require an overdose reporter to disclose her legal name to claim immunity.
  • A reporter must identify herself as the person who called for help or otherwise sought aid for the overdose victim.
  • When statutory immunity applies, it bars prosecution for covered possession offenses arising from the same course of events.

Why It Matters

The decision gives Colorado’s overdose-reporting immunity statute a life-saving construction: people may seek emergency help without having to disclose their names solely to obtain the statute’s protection. It also distinguishes the statute from related provisions in which the General Assembly expressly required a caller’s name.

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