United States v. Oakland Cannabis Buyers' Coop. - 532 U.S. 483, 121 S. Ct. 1711 (2001)

Rule:

In the case of the Controlled Substances Act (Act), 21 U.S.C.S. § 801 et seq., the statute reflects a determination that marijuana has no medical benefits worthy of an exception, outside the confines of a government-approved research project. Whereas some other drugs can be dispensed and prescribed for medical use, 21 U.S.C.S. § 829, the same is not true for marijuana. Indeed, for purposes of the Act, marijuana has no currently accepted medical use at all. 21 U.S.C.S. § 811.

Facts:

Respondent Oakland Cannabis Buyers' Cooperative was organized to distribute marijuana to qualified patients for medical purposes. The United States sued to enjoin the Cooperative and its executive director, also a respondent (together, the Cooperative), under the Controlled Substances Act. The United States argued that the Cooperative's activities violated the Act's prohibitions on distributing, manufacturing, and possessing with the intent to distribute or manufacture a controlled substance. The District Court enjoined the Cooperative's activities, but the Cooperative continued to distribute marijuana. The District Court found the Cooperative in contempt, rejecting its defense that any distributions were medically necessary. The court later rejected the Cooperative's motion to modify the injunction to permit medically necessary distributions. The Cooperative appealed, and the Ninth Circuit reversed and remanded the ruling on the motion to modify the injunction. According to the Ninth Circuit, medical necessity was a legally cognizable defense likely applicable in the circumstances, the District Court mistakenly believed it had no discretion to issue an injunction more limited in scope than the Controlled Substances Act, and the District Court should have weighed the public interest and considered factors such as the serious harm in depriving patients of marijuana in deciding whether to modify the injunction. The United States filed a petition for writ of certiorari.

Issue:

Was there a medical necessity exception to the Controlled Substances Act’s prohibitions?

Answer:

No.

Conclusion:

The United States Supreme Court held that, even assuming that necessity was a recognized defense to a criminal violation, a medical necessity exception for marijuana was at odds with the unambiguous terms of the Act. The statute specifically listed marijuana in the category of substances which Congress determined to have no medical benefits warranting an exception from the Act's prohibitions. Further, although the Court had broad discretion in fashioning equitable relief, such discretion did not extend to ignoring the congressional mandate by consideration of the medical benefits of marijuana, or by nonenforcement of the Act. Accordingly, the judgment of the Ninth Circuit was reversed, and the case was remanded for further proceedings.