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Florida’s End of the Year Medical Marijuana Update

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Florida’s End of the Year Medical Marijuana Update

Since November 8th much action has happened in Florida’s Medical Cannabis Industry. The rapid pace at which the state and cities have been reacting to the passing of Amendment 2 is a great indication of how receptive the overall government is to the new industry. In mid December the state health officials acknowledged a 7th cannabis license had been awarded. After a year of litigation, McCrory’s Sunny Hill Nursery had proved their point that they qualified for the cannabis licensure. Such license allows the licensee to grow, process, and dispense non-euphoric medical cannabis in the state of Florida to patients that fall under a very limited number of illnesses.

The next question for the 7 nurseries awarded cannabis licenses is whether they will be automatically grandfathered in under the new medical cannabis laws. Arguably they would have to re-apply since the new cannabis laws surrounds a much different type of cannabis plant, which contains high THC, the component of the medical plant that gives a psychoactive effect. However, do note, the state recently added that “full strength cannabis,” was allowed to be cultivated and distributed to terminally ill patients by the 7 license holders. The term “full strength” has yet to be qualified, illustrating the lack of knowledge of the Florida legislators regarding medical cannabis. Moreover, terminally ill patients are only allowed to order less than a week worth of cannabis due to the shortage of supply, illustrating the inadequacy of the current cannabis license holders, who have been in operation since the middle of 2016. At the moment, Trulieve and Surterra received distribution authorization in July. Modern Health Concepts received their authorization in September and the state’s Health Department gave Knox Medical authorization in early December.

Another tremendous leap in the right direction happened when the Florida Senate held a Health Committee meeting regarding the issue of medical cannabis on December 13, 2016. The Committee hosted a panel of “industry experts,” and allowed industry activist to speak on the record at the end of the Committee meeting. Topics ranged from concepts such as child safety measures to the manner in which the State will disseminate licenses, either integrated or separated. What was interesting about the Committee panel of “industry experts,” was that they were not really industry experts! One panelist was a representative from Trulieve, one of the 7 cannabis license holders from Tallahassee. Unfortunately, the only expert opinions given by the company representative were statements that benefited their company, and not the patients or industry as a whole. Trulieve is documented to have lobbyist currently working to push their agenda, which is to maintaining the status quo, in efforts to monopolize the market. One article by Daniel Ducassi wrote, “Nick Iarossi, lobbyist for Trulieve, argues for a more conservative, ‘cautious’ approach that ‘preserves the culture of Florida’.” Meaning, do not issue any more licenses, as they will eat away at the market share that we currently intend to hoard.

Additionally, during a recent zoning and planning board meeting for the city of Fort Lauderdale, representatives from Costa Farms, D/B/A Modern Health Concepts, were also pushing their agenda by trying to get the city moratorium removed or at the very least shortened. This move was clearly with the intent to have first choice over the city’s prime location for one of their dispensaries. Modern Health Concept knows that if the moratorium extends for six months, they run the risk of being outcompeted for a prime location for their dispensary.

Under the Compassionate Use Act, the licensees can only cultivate and process from their region, but can open as many dispensaries as they please and anywhere in the state. A clear advantage the license holders want to exploit before other licenses are awarded. The intent of these companies is understandable from a business point of view, but distasteful and disgusting to the patients and public at large. They speak on the record and promote that their efforts are for the patients, but obviously their words are a pretext to mask their greedy financial endeavors. The licensee’s claim its for the patient in need and that no more licenses need to be issued since they can cover the supply demand, but they cannot even produce enough to provide for the very limited existing patients, as a current shortage of supply exist.

These companies need to focus on becoming operation, and then they can worry about maintaining the status quo and finding prime locations. Statistically, dispensaries in the city make great financial gains, but dispensaries in rural areas barely make enough to cut even on the books. The public and patients are aware of this and will likely not use products from these companies once other licenses are awarded. We take this notion from the events that transpired in Ohio in 2015, where the public voted “yes” for a medical cannabis industry, but voted “no” the monopoly that the state intended to structure. The consensus is clear, the public does not like industry monopolies and actual unite to ban against it. Here in Florida will be no different. If these companies continue to promote their selfish ways, it could be a very short run for them in the industry.

On a final note, many cities’ are currently in the process of writing language to implement into there zoning codes, despite their implementation of a moratorium. Such as the city of Fort Lauderdale, who currently has their representative writing the first draft. In the event the audience wants the inside scoop of the first draft, please feel free to contact GreenAcre Consulting Team. The city of Hollywood has also given GreenAcre the inside scoop on where they intend to allow the cultivation sites in their city. Dade County has already posted their zoning requirements. Broward County filed a motion to direct the County Attorney to draft an ordinance amending Chapter 39 of the zoning code. The new provisions will regulate medical marijuana, as it pertains to cultivation, processing, and dispensing. Further, Parkland in Broward County gave the initial approval to regulate medical cannabis dispensaries. City Attorney Andrew Maurodis is behind the new regulation and stated that the city is adhering the request of the constituents. They pronounced that they are going to allow the sites to open in the industrial areas, but currently no industrial areas exist. The city will have to zone an industrial area or change the zoning district.

The Florida government has made great efforts to move the cannabis industry along in just under two months. Illustrating that they welcome the industry with open arms, but doing so in such a subtle manner that does not offend the opposition.

Rolando Vazquez, Esq. 

President 

GreenAcre Consulting Team

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Another City in Florida denies patients access to Medical Marijuana

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Another City in Florida denies patients access to Medical Marijuana

Coral Springs adds its name to the list of cities in the State of Florida that placed “moratorium” laws for Medical Cannabis.

        Floridians approved Amendment 2 with 71% of votes.  Yet, cities and counties are now placing “moratoriums” to “analyze the impact of cannabis” in their communities and allowing themselves time to organize appropriately.  The city of Coral Springs placed a moratorium for a period of 180 days regarding cannabis laws.  According with the city’s memorandum released, the period of 180 days is necessary to analyze the impact on the city’s regular activities (welfare, economic, community, crime and services.)  

        The reasons provided not only by Coral Springs, but also by Deerfield Beach, Delray, Boca Raton and Hallandale Beach, seem to be reasonable. However, it cannot be denied that these “moratoriums” give an objective perception that Medical Cannabis patients are going to be affected directly and imminently.  In fact, the community and patients are concerned and panicking over these moratoriums. According with the text and spirit of “Amendment 2,” the Department of Health has until June 3rd of 2017, to publish the regulations for access to Medical Cannabis.  Even when the laws are promulgated, it will take months before cannabis ventures receive state approved licenses and those same ventures will take even more time to become operational. As such, Medical Cannabis supporters must take into account that Florida will not have a fully operational Medical Cannabis Industry until mid-2018.  Moreover, another angle to consider is that some of the moratoriums placed by the cities mentioned above will end before June 3rd, 2017. The others will end before the commencement of 2018. Therefore, at the moment these moratoriums are not really affecting the advancement of the Florida Medical Cannabis Industry.  

        The government must respect that over 6.4 million of Floridians voted in favor of Medical Cannabis.  These same constituents will not allow the state and local government to deny them access to it. The community will stay involved and informed on the issue, since citizens have control over their government, which is the true nature of a democracy.  

        Again, do not forget that Amendment 2 was a request by the citizens of Florida. The state and local government will ultimately have no choice but to offer some sort of access to the medicine.  State and local government will also have to succumb to the reality that Floridians will vote in favor of “Adult Use” in 2018.  This assertion is supported by the fact that no other state has legalized Medical Cannabis by such a large margin of votes.  In sum, Floridians love and need their Cannabis, and will not be denied safe and reliable access to it! 

 

Rolando Vazquez, Esq.
GreenAcre Consulting Team

 

 

 

 

Sources:

Coral Springs puts moratorium on medical marijuana centers

In this Sept. 15, 2015 file photo, marijuana plants are seen nearly ready for harvest at the Ataraxia medical marijuana cultivation center in Albion, Ill. Dr. Bodo Schneider, a physician accused of charging patients for marijuana recommendations without a legitimate doctor-patient relationship, could lose his license in a case critics say highlights the state's strict enforcement. His case came before an administrative law judge Tuesday, Dec. 1, 2015, in Chicago. (AP Photo/Seth Perlman, File)

After Amendment 2: How to Choose a Cannabis Consultant


After Amendment 2: How to Choose a Cannabis Consultant

Amendment 2 passed in Florida, more than 6.000.000.00 constituents voted YES ON 2.  This is the beginning of the journey in Florida.  Many investors are ready, calling and searching for “cannabis consultants” and “cannabis lawyers,” everybody wants to be part of this industry, everybody is talking about “Medical Cannabis.”

It is important for investors to understand the Cannabis Industry is not an industry for everyone, there is a lot of competition.  The application will be assessed on a merit based system, meaning that only the best applications with the best resumes and business plan will get approved.  If you are an investor ready to invest in this industry you also need to be ready to invest in the best Cannabis Consultants.

How do you know who is the best Cannabis Consultant?

Do your research, find out who they are and how well they are known in the industry. Every one can claim to be a consultant but only few can called themselves true “Cannabis Consultants.”  GreenAcre Consulting Team specializes in the Cannabis Industry, this is what we do.  We have the connections and relations with the most qualified professionals in the industry.  Be aware, this is a new industry that attracts questionable people to take advantage of investors.  Do your due diligence, if your consultant is also an attorney look it up online, you can have access to every Bar Association in the United States.  The same applies if your consultant is a professional in another area.  GreenAcre Consulting Team acts as your “project manager,” we specialized in every aspect of the process, such as; application assistance, business plans, compliance with state and local rules, local marketing, cultivation techniques, master growers, bud-tenders, realtors, surveyors, commercial real estate attorneys, planning and zoning attorneys, architects, and many more.  You need attorneys to orient you on the legal aspects, but you also need consultants.  For that reason GreenAcre is the best alternative because we are both.  The president is also a licensed attorney, and although GreenAcre is solely a consulting company, all clients with legal needs will be referred to Rolando Vazquez, PA., which a completely separate business entity.  GreenAcre will never asked to have ownership in your business like many consulting companies do and will.  We only seek to get your license approved, make your venture operational and keep you in compliance.   All our clientele is kept strictly confidential and if any conflict of interest arises, we will disclose it to our client. Your privacy is our priority.  GreenAcre is one of the only Cannabis Consulting Company with international recognition, we have educated the governments of Belize and Guyana on how to regulate their markets in the area of Hemp and Medical Marijuana. No other consulting company in the industry has our resume. We are the ultimate Cannabis Consultants.

Why a Cannabis Consultant is necessary?

A Cannabis consultant is not only necessary but fundamental for your business venture.  Numerous barriers and pit-falls exist in the industry, you need the guidance and support of knowledgeable professionals in the industry.  As consultants, GreenAcre’s Team has  dedicated years educating, networking and researching the Cannabis Industry. 

Is Florida a “Good Market”? 

Florida is expected to be the second biggest market in the United States of America.  Also, consider the fact that Florida has over 20 million constituents and welcomes over a 120 million visitors per year.  The Port of Miami known as the “Cruise Capital of the World” and the “Cargo Gateway of the Americas” has an economic annual impact in Miami of 18 billion.  Further, Floridians passed the medical marijuana initiative with 71% of the voters in favor of the industry, meaning Adult Use is just around the corner.  Need we say more?  

What about all the cities that recently have placed bans for the Medical Cannabis businesses? 

Investors DO NOT BE DISCOURAGED, Pompano, Boca Raton, Deerfield Beach and Delray ARE PLACING TEMPORARY BANS FOR THE MEDICAL CANNABIS INDUSTRY.  The temporary bans will allow these cities to have time to properly enact the relevant zoning laws.  

 

Rolando Vazquez, Esq. 

Signature Rolando Vazquez copy

 

Sources

South Florida cities push pause on expansion of medical marijuana industry

Medical Marijuana Bans Are Popping Up In Florida

Miami Beach Considers Six-Month Medical Marijuana Ban

 

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GreenMail #9: November 8, when 8 states became part of the Cannabis Movement in the United States of America

GreenMail #9: November 8, when 8 states became part of the Cannabis Movement in the United States of America.


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California [Adult Use]

Proposition 64 was approved with 4,963,501 of the constituents votes, in total 55.8% of the voters approval. Proposition 64 legalizes adult use of marijuana for individuals over the age of 21. Consumption of cannabis would be allowed in private properties or at locations licensed for consumption on site.


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Maine [Adult Use]

Question 1 passed with 51% of voters approval. The act allows individuals older than 21 to possess, transport, and use up to 2.5 ounces of marijuana as well as possess, grow, cultivate, process, or transport up to six marijuana plants. The act protects employees by prohibiting employers from refusing to employ a person solely” because that person consumed marijuana.


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Nevada [Adult Use]

Question 2 passed with 54% of the voters approval. The act legalizes the possession, use, and cultivation of one ounce of adult use of marijuana by individuals older than 21. The impact will be noticed on the tourism industry. In 2015, 42 million tourists visited “Sin City.” Nevada is a great market to invest. GreenAcre Consulting Team can help you with the application for license in Nevada.


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Massachusetts [Adult Use]

Question 4 passed with 53% of voters approval. The act allows individuals who are at least 21 years old to grow, use, and possess marijuana. Individuals are allowed to posses up to 10 ounces of marijuana in their private property. Individuals are allowed to posses one ounce of marijuana in public.


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Montana [Medical Use] 

Initiative 182 passed with 56.9% of voters approval. Initiative 182 repeals the three-patient limit for providers and state review of physicians who prescribe marijuana to numerous patients. The Initiative expands the range of conditions for which marijuana can be prescribed to include chronic pain and post-traumatic stress disorder.


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North Dakota [Medical Use]

Measure 5 passed with 64% of voters approval. The Act provides for the use of medical marijuana for serious medical conditions. It also requires medical marijuana patients and caregivers to carry identification cards and certificates of registration.


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Arkansas [Medical Use] 

Issue 6 passed with 53% of voters approval. Medical Marijuana was approved for 17 qualifying medical conditions. Issue 6 contains a nondiscrimination provision that prohibits employers from discriminating against an individual solely based on the individual’s condition as a patient. A Medicinal Marijuana Commission would be created, with tax revenue being allocated to technical institutes, vocational schools, and the General Trust Fund.


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Florida [Medical Use] 

Amendment 2 passed with 71% of voters approval. Florida set a record for constituents approval. In recent years not any other state has approved medical use of cannabis with more than 70% of electors approval. The Act allows for medical use of marijuana by individuals with debilitating medical conditions, and expands upon the state’s current, and more limited, medical marijuana program. The Act allows the use of a stronger form of marijuana. The Act’s language expands the use of cannabis to “other debilitating medical conditions of the same kind or class as or comparable to those enumerated.”

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“Medical Marijuana Investors Meet-Up” Las Vegas, NV

On November 1st, 2016, GreenAcre’s President, Rolando Vazquez, Esq., accepted the invitation to attend to “Local Investors Meet-Up” in Las Vegas, NV. The event was organized by The Arcview Group, the legal cannabis industry premier hub for investment, data and progress.  Rolando Vazquez attended the investors meeting reaching great success, networking with industry activist, investors and leading companies in the industry.  Rolando and the other attendees were strategizing on how to approach the Florida Market.

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In the Picture: From left to right, GreenAcre’s President, Rolando Vazquez, Esq., Scot Rutledge and Joe Brezny both from Coalition to Regulate Marijuana Like Alcohol in Nevada.

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GanjaCon Eugene, OR

On November 6th, 2016, GreenAcre’s President Rolando Vazquez, Esq., accepted the invitation to GanjaCon in Eugene, Oregon.  During the convention Rolando got to see the different strains offered by Oregon’s Finest Medical Marijuana Farmers. New lines of products were launched during the convention. GreenAcre expanded its network with farmers and industry experts in the Oregon MMJ Market. At the convention the attendees were excited about the Florida and Nevada market. The convention offered free samples, joint-rolling contest and live music.

 

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Amendment 2 Passed in Florida

Amendment 2 passed in Florida with 71% of constituents approval, 6,496,157 people voted YES ON 2. 

The complete legislation for the regulation of medical cannabis has not been published.  After November 8th, 2016, medical marijuana is still illegal in the State of Florida.  According with Florida’s State Constitution Article XI Section5,  the approved amendment 2 will become effective on January 3rd 2017.  Patients in need will have to obtain (1) letter of certification from a physician and (2) a valid state-issued MMJ card.  Florida’s Department of Health is required to submitted the regulations by June 3rd 2017.  Patients should be expecting to get their MMJ cards by September 3rd 2017.

Rolando Vazquez, Esq.

 

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MMTA

The First Failure to Regulate Medical Marijuana

The Marihuana Tax Act as the First Failure of the Government to Regulate

            In 1937, the Congress, under the pressure of the nylon and paper production lobbyist, enacted Marihuana Tax Act. The act imposed taxes on the entire genome of cannabis, both the medical marijuana and hemp industry. The taxes extended to doctors, producers, manufacturers, importers and any other player involved in the industry.  The Act had two main components: the first regulated imposition of taxes on marijuana transfers, and the other imposed occupational taxes on those involved in marijuana business. The violation of the act was punishable by $2,000 fine or 5 years in prison, or both. This meant that any black market transaction would subject a person to a very cruel punishment, unless a transferee of an illegal transaction paid $100 on each ounce of marijuana obtained. Essentially, the Congress was trying to make money out of each black market transaction, if any.

Who is Timothy Leary?

            On December 20, 1965, Dr. Timothy Leary set on a car trip from New York to Yucatan, Mexico. In two days he reached the Mexican border but was denied entry. He was stopped at the US customs for inspection. The customs agent saw an item on the car floor, which looked like a marijuana seeds. After receiving permission to search the car, he found a small amount of marijuana and three partially smoked marijuana cigarettes. Accordingly, Leary was arrested.

How his case proceeded? 

           He was indicted and tried on three counts under the Marihuana Act. One of the counts was dropped, however the jury found him guilty on the other two. The District Court sentenced him to 5 years prison term. The Fifth Circuit Court affirmed the sentence. Leary appealed to the Supreme Court, and the certiorari was granted. Leary vs. US, 89 S.Ct. 1532 marked the end of the Government’s attempt to regulate cannabis through Marihuana Act and set the foundation for Controlled Substance Act that is still in place today.

What was the main legal argument? 

           The Defendant’s main argument was that the Marihuana Act violated his Fifth Amendment right against self-incrimination. At that time, the Congress on a regular basis imposed taxes on activities such as illegally weapons, or wagering, or imposing an excise tax on proceeds from wagering. In other words, even though you are involved in the illegal activity, you still had to pay taxes on it—note that Al Pacino was arrested for tax evasion.

There is always a wrinkle.

           The Marihuana Tax act was no different, as mentioned above. However, there was one more wrinkle to it. A person dealing with marijuana had to obtain a written order form from the government to make a marijuana transfer. Such order would have the name and address regardless if a person was registered or not. A transferee also had to obtain the order form. So, whether you obtain marijuana legally or not you had to obtain the order form from the government where you provided your name and address. Then this information was transferred to IRS and could be accessible to law enforcement agencies, state and federal, under the provisions of the Act.

          All 50 States at a time had harsh marijuana criminal laws. As such, a person who illegally obtained marijuana through a required order form would subject himself to those criminal acts. As such the government allowed illegal transaction in marijuana, taxed it, and then could go after the person who was involved in such transaction. This did not make any sense.

What was the outcome?

         Leary won the argument on this basis. The US Supreme Court repealed the Marihuana Tax Act. The Congress in response enacted the Controlled Substance Act in 1970 putting marijuana in Schedule 1 along with LSD, Heroin, and ecstasy. It has been 46 years since then with no changes.

Conclusion.

        The first attempt of the US government to control and tax marijuana failed flat. Nowadays, the States take this responsibility in violation of the Federal Law. The question remains open: will the Government attempt to federally regulate marijuana at some point of time or will it leave this to the States with no interference?

Rolando Vazquez, Esq.

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GreenMail Weekly #8: Medical Marijuana Business and Legal Digest

MARYLAND.

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Over a thousand applications were submitted to the State in an attempt to receive medical marijuana licenses. Recently The State issued its first 30 licenses. It came as a surprise for the public to learn that none of the lucky ones belonged to minority applicants. The issue was brought to the attention of government officials, and a caucus was held. The state law requires racial diversity. The State promised to seek diversity when analyzing the other 800 pending applications.  

 

WHEN CAN I INVEST IN OHIO MMJ?

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Last week we reported that Ohio’s medical marijuana program started. When can I apply for a medical marijuana license, is now the logical question? According to Ohio law, by October 8, 2016, the governor and leaders from the lawmaking body should appoint 14 members in the new medical marijuana advisory committee. By May 6, 2017, the Department of Commerce should have rules and regulations on cultivation in place, including the number of licenses.   By September 8, 2017, rules must be enacted for dispensaries and State registry system.   Finally, by September 8, 2018, the program should be fully operational. It is very likely, that the State will expedite the program, and the dates may move back, making way for the industry to become fully operational by September of 2017.

 

WHEN WILL I INVEST IN PENNSYLVANIA?

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In April of 2016, Governor Wolf signed a bill establishing the medical marijuana program in PA. The program is set to be fully operational in early 2018. However, there are a few questions to be answered before an investor will want to bid on one of the few very lucrative licenses in PA.

First, do you want to dispense (sell) or cultivate and process (grow and extract). There will be an initial 50 licenses available for dispensaries. Each license may have up to three (locations). Applicant must submit the application with an initial $5,000 non-refundable fee. Permit fee of $30,000 must be paid if the license is granted. Last, but not least, applicant must have proof of $150,000 in available capital. The application form will be released in the second quarter of 2017.

Further, if it is a growing or processing license, the requirements are getting tougher. Initial non-refundable of $10,000 should be paid upon submission of the application. Another $200,000 should be paid for the permit when the license is issued. Moreover, proof of $2 million should be submitted, with $500,000 on the account. The State will release the applications at the end of this year (2016).

From these requirements, it is not hard to conclude that PA purposely created very business oriented laws. No more moms and pops shops. Only serious investors are welcome. Moreover, PA is the first State that opened up the doors for out-of-state investors, allowing publicly traded companies to bid. Another innovation is that owners of the cultivation licenses will be able to transfer them freely, just like taxi medallions in NY. PA’s laws also require 10% of the issued licenses to be allocated to minorities and women.

 

 

MASSACHUSETTS

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Massachusetts released very interesting data on its medical marijuana program. In 2012, the residents voted for MMJ to be legalized and regulated. Two and a half years later, in July of 2015, the first dispensary opened up. In the same month, over 1,200 patients registered with the State and 624 purchased the product. In January of 2016, about 25,000 patients had access to the medicine with 5,698 actively buying it. In August of 2016, over 35,000 MMJ card have been issued and over 15,000 patients were actively buying the medicine.

The residents of Massachusetts will vote on November 8, 2016, to allow adult use for medical marijuana. The polls show overwhelming support for the initiative.

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Federal Court vs. Medical Marijuana

The Federal Appellate Court Makes you choose between MMJ and your weapons.

The Ninth Circuit Court of Appeals ruled on a lawsuit filed in Nevada in 2011. The lawsuit was filed in a hope to deem the ban on buying weapons and ammo for MMJ cardholders unconstitutional. A solid argument rooted in the Second Amendment was denied by the court ruling 3-0 that a person who possesses medical marijuana card cannot buy a gun. The court stated that medical marijuana “raises the risk of irrational or unpredictable behavior with which gun use should not be associated” and that MMJ patients are likely “to experience altered or impaired mental states that affect their judgment and that can lead to irrational or unpredictable behavior.”

In other words, the Court ruled that people who drink alcohol and become aggressive and violent as a result may freely access the Second Amendment rights, as opposed to medical marijuana cancer patient who uses the medicine to get the needed relief from the conditions. In the light of the latest scientific researches, such conclusions are questionable. However, we understand that the issue is rooted into the Controlled Substance Act of 1970 that places MMJ in the first category of dangerous drugs.

The ruling of the Court spreads across the nine States across the Western US, including Nevada, California and Oregon. The Court relied on the letter that ATF issued in 2011 (!) that specifically required banning weapons and ammunition sales to medical marijuana cardholders. The Court said that the Appellant could have bought the weapons before acquiring the MMJ card or forfeit the card and buy the weapon.

Interesting enough, what most people think is a loss of MMJ industry to the federal government is actually quite a win. The Federal Judge openly described a loophole in the law for MMJ cardholders to use. More specifically, acquire the gun and ammo before you get MMJ card, as keeping the weapon alongside with MMJ card is legal, but buying is not. Or if you already have a MMJ card, cancel it and buy a gun. Once you have a gun, get the MMJ card again. Genius!

Also, it is worth mentioning that the Appellant’s lawyer have not proposed the recent studies on MMJ to challenge the conclusions and the methodology of the studies the government used. It is quite important in such cases to have a team of lawyers that possess profound legal and scientific knowledge in the cannabis industry. The type of expertise and knowledge that GreenAcre lawyers possess.

Nevertheless, to heal the disease, one has to kill the cause and not the symptoms.   The federal regulations should change to adopt a new trend in the State laws. Outdated laws of 1970 and 2011 do not reflect the needs of our society at the moment.