BILL ANALYSIS                                                                                                                                                                                                    



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          Date of Hearing:    July 1, 2003
          Counsel:        Kathleen Ragan


                         ASSEMBLY COMMITTEE ON PUBLIC SAFETY
                                  Mark Leno, Chair

                  SB 420 (Vasconcellos) - As Amended:  May 27, 2003
           

          SUMMARY  :   Establishes a statewide, voluntary program for the  
          issuance of identification cards to identify persons authorized  
          to engage in the medical use of marijuana under the  
          Compassionate Use Act of 1996.  Specifically,  this bill  :  

          1)States that it is the intent of the Legislature to do all of  
            the following:

             a)   Clarify the scope of the act and facilitate the  
               identification of qualified patients and their primary  
               caregivers in order to avoid unnecessary arrests and  
               provide needed guidance to law enforcement officers;

             b)   Promote uniform application of the act among California  
               counties;

             c)   Collect data to ascertain the extent of serious medical  
               conditions that are not being adequately relieved in order  
               to plan for future research and resource allocation; and, 

             d)   Enhance the access of patients and caregivers to medical  
               marijuana through collective, cooperative cultivation  
               projects.

          2)Provides that it is the intent of the Legislature to address  
            additional issues not included within the act that must be  
            resolved in order to promote the fair and orderly  
            implementation of the act.

          3)States that the Legislature finds and declares both of the  
            following:

             a)   A state identification card program will further the  
               goals of the People and the Legislature; and,









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             b)   With respect to individuals, the identification system  
               must be wholly voluntary and a patient entitled to the  
               protections of the act need not possess an identification  
               card in order to claim the protections of the act.

          4)Defines "attending physician", "qualified patient", "primary  
            caregiver", and "serious medical condition".

          5)Defines "serious medical condition" as all of the following  
            medical conditions:

             a)   Acquired Immune Deficiency Syndrome (AIDS);

             b)   Anorexia;

             c)   Arthritis

             d)   Cachexia;

             e)   Cancer;

             f)   Chronic Pain;

             g)   Glaucoma;

             h)   Migraine;

             i)   Persistent muscle spasms including, but not limited to,  
               spasms associated with multiple sclerosis;

             j)   Seizures including, but not limited to, seizures  
               associated with epilepsy;

             aa)  Severe nausea; and,

             bb)  Any other chronic or persistent medical symptom that  
               either:

               i)     Substantially limits the ability of the person to  
                 conduct one or more major life activities as defined in  
                 the Americans with Disabilities Act of 1990.

               ii)    May cause serious harm to the patient's safety or  
                 physical or mental health if not alleviated.









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          6)Requires the Department of Health Services (DHS) to establish  
            and maintain a voluntary program for the issuance of  
            identification cards to qualified patients.

          7)Provides that every county health department shall do all of  
            the following;

             a)   Provide applications to individuals seeking to join the  
               identification card program;

             b)   Receive and process applications, as specified;

             c)   Maintain records of identification card programs;

             d)   Utilize protocols developed by DHS, as specified; and, 

             e)   Issue identification cards to approved applicants and  
               primary caregivers.

          8)Requires DHS to develop all of the following;

             a)   Protocols to implement the responsibilities to be used  
               by county health departments including, but not limited to,  
               protocols to confirm the accuracy of the information in an  
               application and to protect the confidentiality of program  
               records;

             b)   Application forms to be issued to applicants; and,

             c)   An identification card that identifies a person  
               authorized to engage in the medical use of marijuana and an  
               identification card that identifies the person's primary  
               caregiver, if any.  Specifies that the two identification  
               cards shall be easily distinguishable from each other.

          9)States that no person or designated primary caregiver with a  
            valid identification card shall be subject to arrest for  
            possession, transportation, delivery, or cultivation of  
            medical marijuana in an amount approved by DHS unless there is  
            reasonable cause to believe the card is false or has been  
            obtained by means of fraud.

          10)Provides that it shall not be necessary for a person to  
            obtain an identification card in order to claim the  
            protections of the Act.  








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          11)States that a person seeking an identification card shall pay  
            a specified fee and provide all of the following information:

             a)   Name and proof of residency within the county;

             b)   Written documentation by the attending physician that  
               the person has been diagnosed with a serious medical  
               condition and that the medical use of marijuana is  
               appropriate;

             c)   The name, address, telephone number, and California  
               medical license number of the attending physician;

             d)   The name and the duties of the primary caregiver; and, 

             e)   A government-issued photo identification card of the  
               person and of the primary caregiver, if any.

          12)States that within 30 days of receipt of an application for  
            an identification card, a county health department shall do  
            all of the following:

             a)   Verify that the information in the application is  
               accurate;

             b)   Verify with the Medical or Osteopathic Board of  
               California that the attending physician has a license in  
               good standing;

             c)   Contact the attending physician to confirm that the  
               medical records submitted by the patient are a true and  
               correct copy of those contained in the physician's office  
               records;

             d)   Take a photograph or obtain an electronically  
               transmissible image of the applicant and of the primary  
               caregiver, if any; and,

             e)   Approve or deny the application, as specified.

          13)States that an identification card issued by the county  
            health department shall be serially numbered and shall contain  
            all of the following:









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             a)   A unique user identification number of the cardholder;

             b)   The date of expiration of the identification card;

             c)   The name and telephone number of the county health  
               department that approved the application;

             d)   A 24-hour, toll-free telephone number that will enable  
               state and local law enforcement officers to have immediate  
               access to information necessary to verify the validity of  
               the card; and, 

             e)   Photo identification of the cardholder.

          14)States that an identification card shall be valid for one  
            year and may be renewed annually upon verification of all new  
            information.

          15)Provides that DHS shall establish application and renewal  
            fees that are sufficient to include the expenses incurred by  
            DHS and by each county health department for administering the  
            identification card program.

          16)States that not less than one-half of the fees collected  
            shall be made available to county health departments for  
            reimbursement for costs incurred operating the program.

          17)Provides that qualified patients, designated primary  
            caregivers, and persons providing assistance to them in the  
            administration of medical marijuana or in acquiring the skills  
            necessary to cultivate or administer marijuana shall not, on  
            that sole basis, be subject to criminal liability for the  
            following:

             a)   Possessing marijuana;

             b)   Cultivating, processing, or harvesting of marijuana;

             c)   Possessing marijuana for sale;

             d)   Transporting, selling, importing, or giving away  
               marijuana;

             e)   Opening or maintaining a place for the purpose of  
               selling, giving away or using marijuana;








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             f)   Renting, leasing or making available for use a building,  
               room or space; and, 

             g)   Maintaining a building for the purpose of manufacturing,  
               serving, storing, or using marijuana which is otherwise a  
               nuisance subject to abatement, injunction, and damages.

          18)Provides that DHS shall issue emergency regulations by July  
            1, 2004 to determine the appropriate amounts of marijuana for  
            the qualified patient's own personal medical use.

          19)States that qualified patients, persons with identification  
            cards, and their primary caregivers may associate, within  
            California, in order to collectively or cooperatively  
            cultivate marijuana for medical purposes, and that such  
            persons shall not be subject to state criminal sanctions under  
            the specified laws listed above.

          20)Requires DHS to adopt regulations no later than December 31,  
            2004 governing the operation of the above cooperatives.

          21)Provides that the regulations relative to the cooperatives  
            shall specify only the methods, procedures and criteria that  
            the cultivation projects will employ to ensure the consistency  
            of composition, non-contamination and non-diversion, of  
            medical marijuana.  

          22)States that accommodation of any medical use of marijuana is  
            not required in places of employment or in jails, correctional  
            facilities, or other penal institutions.

          23)Provides that penal institutions are not prohibited from  
            allowing the use of marijuana for medical purposes under  
            circumstances that will not endanger the health of other  
            prisoners or the security of the facility.

          24)States that the smoking of medical marijuana may not be done  
            in specified circumstances, such as in places where smoking is  
            prohibited by law; on a school bus or within 1,000 feet of a  
            school or youth center; while in a motor vehicle; or while  
            operating a boat.  

          25)Provides that no professional licensing board may impose a  
            civil penalty or take other disciplinary action based solely  








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            on the fact that the licensee has performed acts as a  
            designated primary caregiver.

          26)Provides penalties for persons who fraudulently obtain,  
            steal, or use an identification card.

           EXISTING LAW  :

          1)Prohibits the possession, cultivation, transportation, and  
            sale of marijuana.  (Health and Safety Code Sections 11357,  
            11358, 11359, and 11360.)

          2)Authorizes a patient or the patient's primary caregiver to  
            possess marijuana or cultivate marijuana for the patient's  
            medical use upon the written or oral recommendation of a  
            physician.  (Health and Safety Code Section 11362.5.)

          3)Authorizes the University of California to create a California  
            Marijuana Research Program to determine the efficacy and  
            safety of administering marijuana as part of medical  
            treatment.  (Health and Safety Code Section 11362.9.)

          4)Existing federal law prohibits the possession, sale, and  
            distribution of marijuana.  (21 U.S.C. Section 841  et seq  .)

          5)Federal law lists marijuana as a Schedule I drug, deemed to  
            have no accepted medical use.  (21 U.S.C. Section 812.)

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   

           1)Author's Statement  : According to the author, "This bill  
            establishes a voluntary registry identification card system  
            for persons who are legitimate users of medical marijuana and  
            their primary caregivers.  The card immunizes the cardholder  
            from arrest and prosecution for possession, transportation,  
            and cultivation of marijuana for medicinal purposes. 

            "Attorney General Bill Lockyer convened a task force to find a  
            way to implement Proposition 215.  This bill represents the  
            work product of this task force.  Proposition 215 urges  
            California to work with the Federal Government to facilitate  
            the safe and affordable distribution of medicinal marijuana.









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            "Despite the voters' strong support of medicinal marijuana,  
            the only efforts to provide access have been initiated by  
            community organizations and local governments.  The only  
            response from the Federal Government so far has been to try to  
            shut down the providers?Local providers have placed themselves  
            at risk of civil and criminal prosecution by courageously  
            pursuing a variety of distribution models.  While the  
            providers fill a vacuum created by local government  
            inactivity, the government continues to avoid dealing with the  
            distribution issue.

            "Eight other states have implemented laws similar to  
            Proposition 215; Alaska, Colorado, Oregon, and Hawaii are  
            among those states that have established a registry system for  
            patients and caregivers."

           2)The United States General Accounting Office (GAO) Report :  The  
            GAO issued a report, "Marijuana:  Early Experiences with Four  
            States that Allow Use for Medicinal Purposes" (November 2002),  
            at the request of Congressman Mark Souder, Chairman,  
            Subcommittee on Criminal Justice, Drug Policy, and Human  
            Resources, Committee on Government Reform.  The GAO report  
            examined the implementation of medical marijuana laws in four  
            states:  Oregon, Alaska, Hawaii, and California.   Prior to  
            issuing the report, GAO provided a draft copy to the United  
            States Department of Justice (US DOJ) and included the US DOJ  
            comments in the final report.

            Although the US DOJ said the GAO had fully described the  
            current status of the programs in the states reviewed, the US  
            DOJ stated that GAO failed to adequately address serious  
            difficulties associated with the programs.  "Specifically, the  
            US DOJ commented that the report did not adequately address  
            issues related to the:  (a) inherent conflict between state  
            laws permitting the use of marijuana and federal laws that do  
            not; (b) potential for facilitating illegal trafficking; (c)  
            impact of such laws on cooperation among federal state, and  
            local law enforcement; and, (d) lack of data on the medicinal  
            value of marijuana."

            The GAO report stated, "We disagree."  (Emphasis added.)  The  
            GAO report indicates that the GAO interviewed officials from  
            37 selected federal, state, and local law enforcement  
            organizations to obtain their views on the effect, if any,  
            state medical marijuana laws had on their law enforcement  








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            activities.  Officials representing 21 of these organizations  
            indicated that medical marijuana laws had had little impact on  
            their law enforcement activities.  Some of the federal law  
            enforcement officials interviewed by GAO indicated that the  
            introduction of medical marijuana laws has had little impact  
            on their operations.

            Of particular note, the GAO report stated, "During our review,  
            none of the federal officials we spoke with provided  
            information to support a statement that abuse of medical  
            marijuana laws was routinely occurring in any of the states,  
            including California." (Emphasis added.)

            The GAO report is #GAO-03-189 and is available on the GAO's  
            website (www.gao.gov).

           3)Medical Marijuana Statute Requirements in Other States  :  The  
            medical marijuana statutes in Oregon, Hawaii, and Alaska  
            establish state-administered registries with established  
            requriements, and issue identification cards to certified  
            registrants.  (See Alaska Stat.Ann. 11.71.090, 17.37.010 to  
            17.37.080; Hawaii Rev. Stat. 329-121 to 329-128; and Oregon  
            Rev. Stat. 475.300 to 475.346.)  The following are some  
            requirements:  
           
             a)   A completed application form, submitted by the applicant  
               in Oregon and Alaska, and by a physician in Hawaii;

             b)   A written physician documentation in specified formats;

             c)   An annual renewal fee for registry card; and,

             d)   Established registry verification procedures.

            Oregon, Alaska and Hawaii specify the permissible amounts of  
            marijuana a patient and a designated caregiver may possess.   
            For example, Oregon limits the patient and primary caregiver  
            to no more than three mature plants, four immature plants, and  
            one ounce of usable marijuana per each mature plant.  Alaska  
            allows not more than one ounce of marijuana in useable form  
            and six marijuana plants (with no more than three mature and  
            flowering plants producing usable marijuana at any one time.    
            Hawaii defines an "adequate supply" as an amount that is not  
            more than is reasonably necessary to assure the uninterrupted  
            availability of marijuana for the purpose of alleviating the  








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            symptoms of the qualifying patient's debilitating medical  
            condition, provided the adequate supply does not exceed three  
            mature plants, four immature plants, and one ounce of usable  
            marijuana per each mature plant.  

           4)Conflict with Federal Law  : As indicated above, marijuana is  
            classified as a Schedule I drug under federal law.  In the US  
            DOJ response to the GAO report, the Acting Assistant Attorney  
            General stated, "The most fundamental problem with the draft  
            GAO report is that it fails to emphasize the fact that there  
            is no federally recognized medicinal use of marijuana and,  
            thus, possession or use of this substance is a federal crime."  
             Although federal policy does not currently recognize the  
            medicinal use of marijuana, federal case law has left open the  
            possibility of additional, future challenges to this policy  
            (as discussed below).  Moreover, the California Supreme Court  
            has interpreted the Compassionate Use Act (Proposition 215) as  
            a matter of state law not impacted by interpretation of  
            federal laws.  (See  People v. Mower  , infra.)

           5)Ninth Circuit Decision Protected Physician's Right to Discuss  
            Medical Marijuana with Patients.  The Court stated, "? the  
            government may not initiate an investigation of a physician  
            solely on the basis of a recommendation of marijuana within a  
            bona fide doctor-patient relationship, unless the government  
            in good faith believes that it has substantial evidence of  
            criminal conduct.  Because a doctor's recommendation does not  
            itself constitute illegal conduct, the portion of the  
            injunction barring investigations solely on that basis does  
            not interfere with the Federal Government's ability to enforce  
            its laws."  [  Conant v. Walters  , 309 F. 3d 629, 636 (2002).]   
            It should be noted that this decision was based upon First  
            Amendment grounds.  

          In a concurring opinion in the  Conant  case, it was stated,  
            "Medical marijuana, when grown locally for personal  
            consumption, does not have any direct or obvious effect on  
            interstate commerce.  Cf.  Oakland Cannabis Buyers' Coop ., 532  
            U.S. at 495 n.7 (reserving 'whether the Controlled Substances  
            Act exceeds Congress' power under the Commerce Clause.'  
            Federal efforts to regulate it considerably blur the  
            distinction between what is national and what is local.  But  
            allowing the Federal Government, already nearing the outer  
            limits of its power, to act through unwilling state officials  
            would "obliterate the distinction" entirely.   United States v.  








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            Lopez  , 514 U.S. 549, 557, (1995)."  

          The concurring opinion further stated, "It may well be, as our  
            opinion holds, that interference with the rights of doctors to  
            speak is sufficient to support the district court's  
            injunction. Nevertheless, it remains a significant step for a  
            court to enjoin the prosecution and even investigation of what  
            federal officials believe may be a violation of federal law.   
            See, e.g.,   Bresgal v. Brock  , 843 F.2d 1163, 1171 (9th Circuit  
            1987);  Jett v. Castaneda  , 578 F.2d 842, 845 (9th Circuit  
            1978).  In affirming the district court, I therefore find  
            comfort in knowing that the interests of the patients, and  
            those of the state, provide significant additional support for  
            the district court's exercise of discretion."  

           6)The United States Supreme Court has held that marijuana  
            cooperatives may not assert a medical necessity defense  :  In  
             United States v. Oakland Cannabis Buyers' Cooperative  532 U.S.  
            483, (2001), the Court stated that, at least as to the Buyer's  
            Cooperative, there was no "medical necessity" defense to the  
            manufacture and distribution of marijuana under the Controlled  
            Substances Act (CSA), 21 U.S.C. Section 801 et seq.  However,  
            as stated above, the Court did not reach the constitutional  
            issue of whether the CSA is a proper exercise of the federal  
            interstate commerce powers.  

          In addition, Justice Stevens, in a concurring opinion, left open  
            the possibility of a challenge to the CSA on the basis of  
            states' rights.  Stevens stressed the importance of "showing  
            respect for the sovereign states that comprise our Federal  
            Union.  That respect imposes a duty on federal courts,  
            whenever possible, to avoid or minimize conflict between  
            federal and state law, particularly in situations in which the  
            citizens of a state have chosen to 'serve as a laboratory' in  
            the trial of 'novel social and economic experiments without  
            risk to the rest of the country'."  (quoting  New State Ice Co.  
            v. Liebmann  , 285 U.S. 262, 311 (1932)  (Brandeis, J.,  
            dissenting.)

           7)The California Supreme Court has interpreted Proposition 215  
                                         as a state issue not affected by the United States Supreme  
            Court's decision  : In discussing the  Oakland Cannabis Buyers'  
            Cooperative  case, the California Supreme Court has stated,  
            "The [United States Supreme] Court's holding, which involves  
            the interpretation of federal law, has no bearing on the  








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            questions before us, which involve state law alone."  [  People  
            v. Mower,  28 Cal. 4th 457, 465 (2002), interpreting  
            California's medical marijuana act.]  

          Other California courts have declined to extend the limited  
            immunity provided by Proposition 215 to seriously ill patients  
            and their primary caregivers to others cultivating or  
            providing marijuana to patients and their caregivers, absent  
            specific legislation.  As the Court stated in  People v.  
            Galambos  , 104 Cal. App. 4th 1147 (2002), regarding the concept  
            of permitting sales to further medical marijuana use, "whether  
            that concept has merit is not a decision for the judiciary.   
            It is one the Legislature or the People by initiative are free  
            to make."   

           8)Previous Legislation  :  SB 187 (Vasconcellos), of the 2001-02  
            Legislative Session, was similar to this bill and died on the  
            Senate Unfinished Business File.  

          AJR 13, Resolution Chapter 64, Statutes of 2003, urges the  
            President and the Congress of the United States to take  
            specified actions to ease restrictions on the use of cannabis  
            for medicinal purposes. 

           9)Arguments in Support  : According to background information  
            supplied by the author, "We are duty bound to honor the will  
            of Californians who passed Proposition 215 in 1996, which  
            allows seriously ill patients to use marijuana to treat  
            illnesses.  Due to the vague guidelines, patients and  
            physicians have been subject to needless arrest and  
            prosecution.  A statewide registry system will afford patients  
            standardized and instant proof that they are legal users by  
            state law.   ...This is a win-win for every person involved  
            because it provides statewide guidelines and clarity for law  
            enforcement while protecting medical cannabis users.  In  
            addition, this bill requires the DHS, with input from medical  
            experts and patients, to determine appropriate quantities for  
            qualified users."

          The Office of the Mayor, City and County of San Francisco  
            states, "San Francisco's Medical Cannabis User ID Program has  
            been in operation since July 2000.  More than 6,000 cards have  
            been issued since that time and approximately 3,000 are  
            currently active.  From the beginning, this program has had  
            strong support from the San Francisco District Attorney and  








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            could be used as a guide to establishing an effective  
            statewide program."

          The President of the Board of Supervisors, County of San Mateo,  
            writes, "Providing medical marijuana in a cost-effective and  
            uniform manner that promotes the collection of data for  
            research and future research allocation is a critical step in  
            meeting the objectives of the Compassionate Use Act.  Since  
            the late 1990's, San Mateo County has worked to research the  
            efficacy of medical marijuana.  The County's efforts include  
            working with the Food and Drug Administration to research the  
            use of medical marijuana to relieve chronic pain and suffering  
            as well as AIDS-related wasting.  Recognizing the need for  
            consistent application of the Act as well as the assurance  
            that the state will reimburse counties for the costs incurred  
            in administering the program, I believe this bill would  
            benefit the residents of San Mateo County."

          According to the California Medical Association (CMA), this bill  
            "is an agreement developed by the California Attorney General  
            Task Force, comprised of representatives of key stakeholder  
            groups including patients, patient advocates, law enforcement,  
            and medical professionals.  Voter enactment of Proposition 215  
            has been followed by a degree of confusion and conflict  
            between various stakeholders, resulting in wasted government  
            resources and needless harm to many patients.  This bill takes  
            a considered and rational approach toward ending that  
            confusion and conflict by allowing the DHS to establish  
            guidelines for the appropriate use of medical marijuana, as  
            well as a voluntary registry program to issue identification  
            cards for qualified patients.  

          "A voluntary registry program will afford patients standardized  
            proof of their physician-recommended use of medicinal  
            marijuana.  Such a system would also enable law enforcement  
            officials to easily distinguish between legitimate and illicit  
            users of the drug; and the system would reduce unnecessary  
            criminal investigation of patients and the seizure of their  
            medicine."  

           10)Arguments in Opposition  : The California Narcotic Officers'  
            Association (CNOA) states that CNOA has two general areas of  
            concern:  one related to the quantification of the acceptable  
            levels of medical marijuana and the second related to the  
            voluntary nature of the registration card.  CNOA states that  








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            directing the DHS to determine the appropriate amounts of  
            marijuana for a qualified patient's personal use may result in  
            undue complexity.  CNOA states, "For example, are the  
            appropriate amounts of marijuana different depending on the  
            illness or symptoms of the individual?  How might regulations  
            allow for quantitative variance based on those different  
            illnesses?"

          CNOA further states, "CNOA strongly believes that the  
            registration system must be a doctor-driven, mandatory system.  
             This is important so that diversion of marijuana into illicit  
            markets is minimized.  It is also important so that law  
            enforcement may know with certainty the identities of the  
            patients and caregivers.  CNOA believes that the best approach  
            is for the doctor to notify their county health department  
            whenever they make a determination of medical appropriateness  
            for a specific patient.  The doctor would also notify the  
            county health department of the identity of the patient's  
            caregiver.  

          "After making a determination of the authenticity of the doctor  
            in question, the county health department could simply purge  
            all records identifying the specific doctors and could forward  
            the names of the patients and caregivers to the DHS or the DOJ  
            (the specific state agency is unimportant to CNOA).  The names  
            of the patients and the caregivers would be accessible by law  
            enforcement via an 800 number.  This 800 number would enable  
            law enforcement, upon finding a person in possession of  
            marijuana, to simply make a call to determine whether or not  
            the person was a patient or caregiver pursuant to Proposition  
            215.  This type of certainty would ensure that no one who is a  
            Proposition 215 patient or caregiver would ever be arrested or  
            cited again."

          According to the California Conference of Local Health  
            Officials, establishing and operating a registry system for  
            medical marijuana is not a public health function and public  
            health departments should not be diverted from their primary  
            core public health functions in order to do this.  As stated  
            in their opposition letter, "responsibility for this program  
            has been assigned to the wrong level of government."

          The Recovery California Coalition states that there is no  
            medical benefit for the use of marijuana that cannot be  
            achieved through other methods such as marinol.  The Coalition  








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            further states that since federal law supersedes state law,  
            with the exception for qualified research projects, "we must  
            reverse our previous position and oppose this bill."

          A private citizen states that any registration will inevitably  
            be used against patients, "as the Drug Enforcement Agency will  
            surely argue federal law to seize these files . . ." 

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Americans for Medical Rights
          Attorney General Bill Lockyer
          Being Alive Los Angeles, Inc.
          California Medical Association
          California NORML (National Organization for the Reform of  
          Marijuana Laws
          California Nurses Association
          City and County of San Francisco
          County of San Mateo
          Drug Policy Alliance Network
          Friends Committee on Legislation in California
          Marijuana Policy Project
          San Francisco AIDS Foundation
          Santa Barbara Patient / Doctor Coalition
          451 Private Citizens

           Opposition 
           
          California Conference of Local Health Officials
          California Narcotic Officers' Association
          Campaign for California Families
          Committee on Moral Concerns
          Recovery California Coalition
          1 Private Citizen
           
          Analysis Prepared by  :    Kathleen Ragan / PUB. S. / (916)  
          319-3744