United States v. Oakland Cannabis Buyers' Cooperative

532 U.S. 482 (2001)

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Nature of the Case

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Facts

California voters enacted the Compassionate Use Act of 1996. Its purpose was to ensure that seriously ill Californians have the right to obtain and use marijuana for medical purposes. In the wake of the approval of this initiative, several groups organized medical cannabis dispensaries to meet the needs of qualified patients. The Oakland Cannabis Buyers’ Cooperative (D) was one such group. D is a not for profit organization, and a doctor serves as a medical director and registered nurses staff the operation during business hours. A patient can become a member if he provides a written statement from a treating physician for marijuana therapy and submit to a screening interview. If accepted, the patient gets a card entitling him to get marijuana from D. The United States sued D to enjoin the distribution of marijuana in that their activities violate federal law. The court ruled that D violated the Controlled Substances Act 21 U.S.C. 841(a). D did not appeal the injunction granted but instead openly violated it. Contempt proceedings were initiated. D defended with medical necessity. The District Court rejected this defense on grounds of insufficient evidence. The government then requested a modification to the injunction to empower Marshals to seize the premises. The court granted the modification. D appealed. Before the Ninth Circuit decided the case, D voluntarily purged its contempt by promising to comply. The matter was then deemed moot by the Ninth Circuit. The motion to modify the injunction was still a live issue and the Ninth Circuit reversed and remanded. They reasoned that medical necessity was a legally cognizable defense that likely would apply in these circumstances. The District Court then granted the motion to modify the injunction to incorporate a medical necessity defense. The United States petitioned for certiorari to determine if medical necessity is a cognizable defense to violations of the Controlled Substances Act.