Is the DEA wrong about marijuana’s medical value?

The Question Presented

I’ve been asked to explain the U.S. Drug Enforce­ment Admin­is­tra­tion (DEA) deci­sion on July 19, 2016, not to accept the Mar­i­jua­na Resched­ul­ing Peti­tion filed by the states of Wash­ing­ton and Rhode Island on Novem­ber 30, 2011.  See Page 53688 of the Fed­er­al Reg­is­ter, Vol. 81, No. 156, Fri­day, August 12, 2016.

My Background

I have spe­cial exper­tise because I was one of the peti­tion­ers in the Mar­i­jua­na Resched­ul­ing Peti­tion filed by the Nation­al Orga­ni­za­tion for the Reform of Mar­i­jua­na Laws (NORML) in 1972 (I joined that case in 1985 and my name is on the cov­er of the Admin­is­tra­tive Law Judge’s Rul­ing on Sep­tem­ber 6, 1988), and final­ly resolved in the U.S. Court of Appeals in 1994 (I did not par­tic­i­pate in that appeal).  Alliance for Cannabis Ther­a­peu­tics v. DEA, 930 F.2d 936 (D.C. Cir. 1991); Alliance for Cannabis Ther­a­peu­tics v. DEA, 15 F.3d 1131 (D.C. Cir. 1994).  I was also one of the orig­i­nal peti­tion­ers in the Mar­i­jua­na Resched­ul­ing Peti­tion filed by the Coali­tion for Cannabis Resched­ul­ing in 2002, and final­ly resolved in the U.S Court of Appeals in 2013 (I did par­tic­i­pate in that appeal, and I filed my own Peti­tion for Writ of Cer­tio­rari in the U.S. Supreme Court).  Amer­i­cans for Safe Access v. DEA, 706 F.3d 438 (D.C. Cir. 2013).  The five part test that was devel­oped in the first peti­tion and applied in the sec­ond is the same test that was just recent­ly applied again by the DEA in the most recent peti­tion filed by the states of Wash­ing­ton and Rhode Island.

Dividing the Question

So, there are two ques­tions we need to ask.  First, the ques­tion most peo­ple are ask­ing, did the DEA apply the five part test cor­rect­ly?  The sec­ond ques­tion is one you won’t hear from any­one but me, and that is whether the five part test is even valid.  I’m not going to address the first ques­tion, because I don’t think its rel­e­vant whether DEA applied the five part test cor­rect­ly.  I’m going to divide the sec­ond ques­tion fur­ther and ask whether the five part test was ever valid at all, and then, if it was valid, I’m going to ask if the five part test is still valid today.

The Five-Part Test

On Page 938, Alliance for Cannabis Ther­a­peu­tics, 930 F.2d 936 (D.C. Cir. 1991), the court explains the dif­fer­ence between sched­ule 1 and sched­ule 2, “is whether a drug has ‘no cur­rent­ly accept­ed med­ical use in treat­ment in the Unit­ed States.’  This case turns on the appro­pri­ate def­i­n­i­tion and appli­ca­tion of that phrase.”

On Page 938, the court goes on to explain, “In a pri­or pro­ceed­ing, the Admin­is­tra­tor had employed an addi­tion­al eight fac­tor test to fur­ther elab­o­rate the char­ac­ter­is­tics of a drug that he thought had a ‘cur­rent­ly accept­ed med­ical use’:”

  1. Sci­en­tif­i­cal­ly deter­mined and accept­ed knowl­edge of its chem­istry;
  2. The tox­i­col­o­gy and phar­ma­col­o­gy of the sub­stance in ani­mals;
  3. Estab­lish­ment of its effec­tive­ness in humans through sci­en­tif­i­cal­ly designed clin­i­cal tri­als;
  4. Gen­er­al avail­abil­i­ty of the sub­stance and infor­ma­tion regard­ing the sub­stance and its use;
  5. Recog­ni­tion of its clin­i­cal use in gen­er­al­ly accept­ed phar­ma­copeia, med­ical ref­er­ences, jour­nals or text­books;
  6. Spe­cif­ic indi­ca­tions for the treat­ment of rec­og­nized dis­or­ders;
  7. Recog­ni­tion of the use of the sub­stance by orga­ni­za­tions or asso­ci­a­tions of physi­cians; and
  8. Recog­ni­tion and use of the sub­stance by a sub­stan­tial seg­ment of the med­ical prac­ti­tion­ers in the Unit­ed States.

53 Fed. Reg. 5,156 (1988).

On Page 939, Alliance for Cannabis Ther­a­peu­tics v. DEA, 930 F.2d 936 (D.C. Cir. 1991), explains why the DEA is cre­at­ing tests for deter­min­ing “cur­rent­ly accept­ed med­ical use.”  “The dif­fi­cul­ty we find in peti­tion­ers’ argu­ment is that nei­ther the statute nor its leg­isla­tive his­to­ry pre­cise­ly defines the term ‘cur­rent­ly accept­ed med­ical use’; there­fore, we are oblig­ed to defer to the Administrator’s inter­pre­ta­tion of that phrase if rea­son­able.” So, the DEA is try­ing to define a term used in the statute that Con­gress did not define.

What is impor­tant to note is that the eight-part test was the result of a pre­vi­ous test that was found invalid.  In Grin­spoon v. DEA, 828 F.2d 881, 891 (1st Cir. 1987), the court found that the Admin­is­tra­tor applied an incor­rect stan­dard in deter­min­ing the mean­ing of the phrase “cur­rent­ly accept­ed med­ical use in treat­ment in the Unit­ed States.”  53 Fed. Reg. 5,156 (1988).  The DEA has had a dif­fi­cult time cre­at­ing a valid inter­pre­ta­tion of the lan­guage used in the statute.

In Alliance for Cannabis Ther­a­peu­tics v. DEA, 15 F.3d 1131, 1135 (D.C. Cir. 1994), the DEA’s “Final Order dis­cards the ear­li­er for­mu­la­tion and applies a new five-part test for deter­min­ing whether a drug is in ‘cur­rent­ly accept­ed med­ical use’:”

  1. The drug’s chem­istry must be known and repro­ducible;
  2. there must be ade­quate safe­ty stud­ies;
  3. there must be ade­quate and well-con­trolled stud­ies prov­ing effi­ca­cy;
  4. the drug must be accept­ed by qual­i­fied experts; and
  5. the sci­en­tif­ic evi­dence must be wide­ly avail­able.

57 Fed. Reg. 10,506 (1992).

So, the five-part test is the third time the DEA has tried to define a term that Con­gress did not define in the statute, “cur­rent­ly accept­ed med­ical use in treat­ment in the Unit­ed States.” We should be ask­ing our­selves if the DEA got it right on the third try.

Federalism

So, this brings us up to 1994 and the final rul­ing from the courts is that the five part test is a valid inter­pre­ta­tion of the lan­guage used in the statute. What hap­pens in 1996 is that Cal­i­for­nia becomes the first state to enact a law accept­ing the med­ical use of mar­i­jua­na. We now have a total of twen­ty-six (26) states that have accept­ed the med­ical use of mar­i­jua­na, and an addi­tion­al six­teen (16) states that have accept­ed the med­ical use of a mar­i­jua­na extract. Let’s do a lit­tle review here. In 1987, the DEA’s inter­pre­ta­tion of “cur­rent­ly accept­ed med­ical use in treat­ment in the Unit­ed States” was found to be invalid. In 1991, the DEA’s inter­pre­ta­tion of “cur­rent­ly accept­ed med­ical use” was found to be invalid. Notice how the words got trun­cat­ed to com­plete­ly ignore “in treat­ment in the Unit­ed States.” Then, in 1994, the DEA’s inter­pre­ta­tion of “cur­rent­ly accept­ed med­ical use” was found to be valid. So, why did the words “in treat­ment in the Unit­ed States” get left out? In 1994, there were no states that had accept­ed the med­ical use of mar­i­jua­na.

A cou­ple of graph­ics illus­trate the point.

States with Medical Marijuana laws (1994)

States with Medical Marijuana laws (2016)

Did the DEA apply the five-part test correctly?

Yes, under the five-part test, no plant could ever be approved for med­ical use by the DEA, which makes per­fect sense.  DEA has nev­er resched­uled a plant.  All the plants are in the same sched­ule Con­gress orig­i­nal­ly put them in.  Doc­tors are not writ­ing pre­scrip­tions for plants in sched­ule 2.  If opi­um plants and coca plants had to pass the DEA’s five-part test, they would fail the same way mar­i­jua­na does.  So, the test is being applied cor­rect­ly, the same way it would be applied to any oth­er plant.  Con­gress did not give the DEA any direc­tions on what to do if a plant is in the wrong sched­ule.  Because sched­ule 1 pre­vents their med­ical use, these plants will remain with­out med­ical use until Con­gress removes them from sched­ule 1.

Was the five-part test valid in 1994?

It’s hard to say whether a test for med­ical use of a plant in sched­ule 1 could ever be valid, because sched­ule 1 pre­vents them from being used for med­i­cine.  How­ev­er, the court did approve this test, so it was valid from that per­spec­tive.  The five-part test was not con­test­ed, so it was valid from that per­spec­tive.  In 1994, there were no states that had accept­ed the med­ical use of mar­i­jua­na, and there were no states that had accept­ed the med­ical use of mar­i­jua­na in 1970 when the law was writ­ten.  So, there wasn’t a bet­ter inter­pre­ta­tion of “cur­rent­ly accept­ed med­ical use” in 1994.  Appar­ent­ly, nobody want­ed to state the obvi­ous, a test for med­ical use of a plant in sched­ule 1 is an oxy­moron.  Accept­ed med­ical use in a state is a state deci­sion, but there were none in 1994 or in 1970.

Is the five-part test valid in August of 2016?

The prob­lem with the peti­tion filed by the states of Wash­ing­ton and Rhode Island is that it cedes state sov­er­eign­ty to a fed­er­al admin­is­tra­tive agency by accept­ing the DEA’s abil­i­ty to inter­pret the mean­ing of “accept­ed med­ical use in treat­ment in the Unit­ed States” with­out regard to state laws defin­ing mar­i­jua­na as med­i­cine  If the DEA is going to inter­pret the mean­ing of “accept­ed med­ical use in treat­ment in the Unit­ed States” with­out con­sid­er­ing state laws on the mat­ter then the five-part test is the only approved test for mak­ing that deter­mi­na­tion.  Both the states of Wash­ing­ton and Rhode Island clas­si­fy mar­i­jua­na as a sched­ule 1 sub­stance with no accept­ed med­ical use in treat­ment in the Unit­ed States in their own state drug laws, in clear vio­la­tion of the Full Faith and Cred­it Clause of the U.S. Con­sti­tu­tion.  Revised Code of Wash­ing­ton §§ 69.50.203(a)(2) and 69.50.204©(22) (2016); State of Rhode Island Gen­er­al Laws, §§ 21–28-2.03(2) and 21–28-2.08(d)(10) (2016).  The states of Wash­ing­ton and Rhode Island will not appeal from the DEA’s denial of their peti­tion, because they have no grounds on which to appeal (they have 30 days from the date of pub­li­ca­tion in the Fed­er­al Reg­is­ter to appeal), there­by prov­ing they knew they had no valid legal argu­ment when they filed their peti­tion.

So, the ques­tion is why the DEA is still being asked to inter­pret the mean­ing of “accept­ed med­ical use in treat­ment in the Unit­ed States” when we have forty-two states as of August of 2016 that have accept­ed it for med­ical use.  One expla­na­tion is that the states of Wash­ing­ton and Rhode Island have mar­i­jua­na clas­si­fied as hav­ing no accept­ed med­ical use in the Unit­ed States in their own state drug laws, despite the fact both states have defined mar­i­jua­na as med­i­cine in those same state drug laws.  How could a state act against its own inter­ests in this way?

Back to Federalism

Notice how the phrase “accept­ed med­ical use in treat­ment in the Unit­ed States” is inter­pret­ed by the court in Grin­spoon v. DEA, 828 F.2d 881, 886 (1st Cir. 1987):

We add, more­over, that the Administrator’s clever argu­ment con­ve­nient­ly omits any ref­er­ence to the fact that the per­ti­nent phrase in sec­tion 812(b)(1)(B) reads “in the Unit­ed States,” (empha­sis sup­plied).  We find this lan­guage to be fur­ther evi­dence that the Con­gress did not intend “accept­ed med­ical use in treat­ment in the Unit­ed States” to require a find­ing of rec­og­nized med­ical use in every state or, as the Admin­is­tra­tor con­tends, approval for inter­state mar­ket­ing of the sub­stance.

And, notice in that case the phrase is not trun­cat­ed to only say “cur­rent­ly accept­ed med­ical use.”  Grin­spoon v. DEA, 828 F.2d 881, 887 (1st Cir. 1987):

Unlike the CSA sched­ul­ing restric­tions, the FDCA inter­state mar­ket­ing pro­vi­sions do not apply to drugs man­u­fac­tured and mar­ket­ed whol­ly intrastate.  Com­pare 21 U.S.C. § 801(5) with 21 U.S.C. § 321 (b), 331, 355(a).  Thus, it is pos­si­ble that a sub­stance may have both an accept­ed med­ical use and safe­ty for use under med­ical super­vi­sion, even though no one has deemed it nec­es­sary to seek approval for inter­state mar­ket­ing.

So, the DEA’s five-part test, just like approval for inter­state mar­ket­ing, does not take into account indi­vid­ual states.  The five-part test is for “every state,” just like the approval for inter­state mar­ket­ing, because it would require a find­ing of rec­og­nized med­ical use in every state.  This leaves absolute­ly no doubt, the five-part test is no longer valid.

This is not the first time state offi­cials in states such as Wash­ing­ton and Rhode Island have act­ed against the inter­ests of the peo­ple who elect­ed them.  In New York v. Unit­ed States, 505 U.S. 144, 181–182 (1992), the U.S. Supreme Court asked, “How can a fed­er­al statute be found an uncon­sti­tu­tion­al infringe­ment of state sov­er­eign­ty when state offi­cials con­sent­ed to the statute’s enact­ment?”  The con­text was dif­fer­ent in that case, but the idea is the same as it is here.  State offi­cials in the states of Wash­ing­ton and Rhode Island have con­sent­ed to the DEA inter­pret­ing a statute in a man­ner that infringes on their own state sov­er­eign­ty.

What the states of Wash­ing­ton and Rhode Island should have done is tell the DEA it has no busi­ness inter­pret­ing a term Con­gress has not defined (“med­ical use”) when the state has a law that defines the “med­ical use” of mar­i­jua­na.  See, Gon­za­les v. Ore­gon, 546 U.S. 243 (2006), for an exam­ple of how this works.  Gon­za­les v. Ore­gon, 546 U.S. 243, 258 (2006):

The Attor­ney Gen­er­al has rule­mak­ing pow­er to ful­fill his duties under the CSA.  The spe­cif­ic respects in which he is autho­rized to make rules, how­ev­er, instruct us that he is not autho­rized to make a rule declar­ing ille­git­i­mate a med­ical stan­dard for care and treat­ment of patients that is specif­i­cal­ly autho­rized under state law.

DEA is the fed­er­al agency that acts for the U.S. Depart­ment of Jus­tice in mak­ing sched­ul­ing deci­sions.  In Gon­za­les v. Ore­gon, the Attor­ney Gen­er­al tried to tell the state of Ore­gon that the use of con­trolled sub­stances to assist in sui­cide was not a law­ful “med­ical use” of con­trolled sub­stances, but the court dis­agreed and said the state has the author­i­ty to decide what is “accept­ed for med­ical use” because Con­gress did not make those deci­sions in the fed­er­al statute.  The court said Con­gress could make deci­sion on “med­ical use,” but hasn’t.  Gon­za­les v. Ore­gon, 546 U.S. 243, 271–272 (2006):

Even though reg­u­la­tion of health and safe­ty is “pri­mar­i­ly, and his­tor­i­cal­ly, a mat­ter of local con­cern,” Hills­bor­ough Coun­ty v. Auto­mat­ed Med­ical Lab­o­ra­to­ries, Inc., 471 U.S. 707, 719, 105 S. Ct. 2371, 85 L. Ed. 2d 714 (1985), there is no ques­tion that the Fed­er­al Gov­ern­ment can set uni­form nation­al stan­dards in these areas.  See Raich, supra, at 9, 125 S. Ct. 2195, 162 L. Ed. 2d 1. In con­nec­tion to the CSA, how­ev­er, we find only one area in which Con­gress set gen­er­al, uni­form stan­dards of med­ical prac­tice.  Title I of the Com­pre­hen­sive Drug Abuse Pre­ven­tion and Con­trol Act of 1970, of which the CSA was Title II, pro­vides that

[The Sec­re­tary], after con­sul­ta­tion with the Attor­ney Gen­er­al and with nation­al orga­ni­za­tions rep­re­sen­ta­tive of per­sons with knowl­edge and expe­ri­ence in the treat­ment of nar­cot­ic addicts, shall deter­mine the appro­pri­ate meth­ods of pro­fes­sion­al prac­tice in the med­ical treat­ment of the nar­cot­ic addic­tion of var­i­ous class­es of nar­cot­ic addicts, and shall report there­on from time to time to the Con­gress.”  § 4, 84 Stat. 1241, cod­i­fied at 42 U.S.C. § 290bb-2a.

This pro­vi­sion strength­ens the under­stand­ing of the CSA as a statute com­bat­ing recre­ation­al drug abuse, and also indi­cates that when Con­gress wants to reg­u­late med­ical prac­tice in the giv­en scheme, it does so by explic­it lan­guage in the statute.

It’s clear that Con­gress nev­er intend­ed to tell states what they can accept for med­ical use with­in their own bor­ders.  But, we have states telling the DEA it’s a fed­er­al deci­sion when it’s not.  The DEA sim­ply refus­es to budge until some­one gives them a valid legal argu­ment for remov­ing mar­i­jua­na from sched­ule 1.

There are three ways that could hap­pen: (1) an exec­u­tive order declar­ing mar­i­jua­na has accept­ed med­ical use in the Unit­ed States as a mat­ter of law would clar­i­fy that the DEA has no author­i­ty to keep mar­i­jua­na in sched­ule 1; (2) a rul­ing from a court declar­ing mar­i­jua­na has accept­ed med­ical use in the Unit­ed States as a mat­ter of law would clar­i­fy that the DEA has no author­i­ty to keep mar­i­jua­na in sched­ule 1; and, final­ly (3) a clar­i­fi­ca­tion from Con­gress explain­ing that state laws are accept­ed med­ical use in the Unit­ed States as a mat­ter of law would clar­i­fy that the DEA has no author­i­ty to keep mar­i­jua­na in sched­ule 1.  There are some bills pend­ing in Con­gress (S. 683 and H.R. 1538, for exam­ple) that would do this, but they are not as clean as sim­ply enforc­ing the exist­ing law (they would place mar­i­jua­na into anoth­er sched­ule, which an exec­u­tive or judi­cial rul­ing would not do, for the best exam­ple).

Con­gress has with­held fund­ing for enforce­ment of fed­er­al sched­ule 1 against med­ical use of mar­i­jua­na in states that have accept­ed it.  See Unit­ed States v. Marin Alliance, 3:98-cv-00086-CRB (N.D. Cal., 12/18/2015); and Unit­ed States v. Steve McIn­tosh, No. 15–10117 (9th Cir., 8/16/2016).  These cas­es demon­strate the dif­fi­cul­ty imposed on the fed­er­al courts, because the court has to deter­mine if the defen­dant was in com­pli­ance with a state med­ical mar­i­jua­na law, and then has to deter­mine if the mon­ey being appro­pri­at­ed for the pros­e­cu­tion of the case falls with­in the time peri­od that Con­gress has for­bid­den the appro­pri­a­tion of such funds for such pur­pos­es.  Wow!

International Law

Final­ly, the DEA rul­ing pub­lished in the Fed­er­al Reg­is­ter on August 12, 2016, relies on inter­na­tion­al treaty oblig­a­tions.  If a sched­ule is required by an inter­na­tion­al treaty, then the DEA is pre­clud­ed from apply­ing some or all of the sched­ul­ing cri­te­ria.  21 U.S.C. § 811(d)(1).  The courts have pre­vi­ous­ly deter­mined that inter­na­tion­al treaty oblig­a­tions pre­vent mar­i­jua­na from being sched­uled any low­er than sched­ule 2.  NORML v. DEA, 559 F.2d 735, 751 (D.C. Cir. 1977).  Because the abuse poten­tial for sched­ule 1 and sched­ule 2 is the same, the only rel­e­vant ques­tion then is whether mar­i­jua­na has “cur­rent­ly accept­ed med­ical use in treat­ment in the Unit­ed States.”  Abuse poten­tial is not rel­e­vant, because the inter­na­tion­al treaties pre­vent the DEA from con­sid­er­ing it.

Because the states of Wash­ing­ton and Rhode Island ced­ed the author­i­ty to define “med­ical use” to a fed­er­al admin­is­tra­tive agency, they also lim­it­ed the choic­es to sched­ule 1 or sched­ule 2, regard­less of whether mar­i­jua­na actu­al­ly belongs in either of those clas­si­fi­ca­tions.

But, the inter­na­tion­al treaties them­selves pro­vide the answer.  Only one of the treaties is specif­i­cal­ly men­tioned, the Sin­gle Con­ven­tion on Nar­cot­ic Drugs, 1961 (As amend­ed by the 1972 Pro­to­col), but all of the treaties use the same lan­guage in their enforce­ment sec­tions:

Arti­cle 36(2) “Sub­ject to the con­sti­tu­tion­al lim­i­ta­tions of a Par­ty, its legal sys­tem and domes­tic law, …”

The treaty does not apply if there is a domes­tic law that allows the activ­i­ty.  A domes­tic law would be intrastate and sole­ly with­in the bor­ders of a state.  State med­ical mar­i­jua­na laws are exempt from the inter­na­tion­al treaties.

The states of Wash­ing­ton and Rhode Island have not only ced­ed their state sov­er­eign­ty to a fed­er­al admin­is­tra­tive agency, but they have also ced­ed their state sov­er­eign­ty to an inter­na­tion­al admin­is­tra­tive agency, the Unit­ed Nations Com­mis­sion on Nar­cot­ic Drugs.  This is treach­ery of the high­est mag­ni­tude.

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8 Responses to Is the DEA wrong about marijuana’s medical value?

  1. Skip says:

    De-sched­ul­ing it would be the hon­est & respectable way to pro­ceed… Nei­ther of those traits are found in our gov­ern­ment.

    • Carl Olsen says:

      The prob­lem, at least as I see it, is that these two states asked for sched­ule 2, which is ced­ing state sov­er­eign­ty to an admin­is­tra­tive agency in vio­la­tion of the U.S. Con­sti­tu­tion. I sup­pose, in the­o­ry, the agency could have reject­ed the peti­tion on the grounds they don’t have the author­i­ty to tell a state what to accept for med­ical use. But, I am plac­ing the blame on the peti­tion­ers. If the DEA is not giv­en the cor­rect argu­ment by a state, I’m not sure the DEA can just resolve that by sub­sti­tut­ing the cor­rect argu­ment.

  2. Pingback: Is the DEA wrong about marijuana’s medical value? – Hemp Genix Skin Care Products

  3. Leslie Douglas Hart says:

    I guess I am stu­pid but the fact that there is an indus­try that man­u­fac­tures mar­i­jua­na sub­sti­tutes in pill form mean any thing to them. There is med­ical need for cocaine and any ENT doc­tor can obtain about as much as they want or need. Same goes for syn­thet­ic hero­in.

  4. Leslie Douglas Hart says:

    I always under­stood the sched­ul­ing sys­tem was to give the gov­ern­ment an easy way to out law new sub­stances dur­ing the age of syn­thet­ics. So it only works to close prison doors but not to open them?

    • Carl Olsen says:

      Sched­ul­ing is not legal­iza­tion. Sched­ul­ing is clas­si­fi­ca­tion. The cur­rent clas­si­fi­ca­tion of mar­i­jua­na says it has no accept­ed med­ical use in treat­ment in the Unit­ed States, but I count 44 states that have accept­ed the med­ical use of the whole plant (29 states) or extracts from the whole plant (15 states). It’s just an out­dat­ed clas­si­fi­ca­tion. I agree the sched­ul­ing sys­tem does allow new syn­thet­ics to be out­lawed quick­ly, but I don’t see how that has any rel­e­vance to the issue of med­ical mar­i­jua­na. Usu­al­ly, when a new syn­thet­ic sub­stance is out­lawed by adding it to sched­ule 1, the states go along with it. In some cas­es, the states out­law it first and the fed­er­al gov­ern­ment just catch­es up with them lat­er.

  5. Napasechnik says:

    Carl, It remains a lit­tle to suf­fer and legal­ize in all states, you can make a screen­shot;)

    • Carl Olsen says:

      I’m not sure what you’re ask­ing for. The graph­ics are no longer cur­rent. Anoth­er state has legal­ized med­ical use and anoth­er one has legal­ized an extract for med­ical use.

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