BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 473
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          Date of Hearing:  April 16, 2013
          Counsel:       Sandy Uribe


                         ASSEMBLY COMMITTEE ON PUBLIC SAFETY
                                 Tom Ammiano, Chair

                    AB 473 (Ammiano) - As Amended:  April 15, 2013
           
           
           SUMMARY  :  Creates the Division of Medical Marijuana Regulation  
          and Enforcement in order to regulate the cultivation,  
          manufacture, testing, transportation, distribution, and sale of  
          medical marijuana.  Specifically,  this bill  :  

          1)States legislative intent to provide for the comprehensive  
            regulation of the cultivation, manufacturing, testing,  
            transportation, distribution, and sale of medical marijuana  
            and the enforcement of laws relating to these activities.

          2)Creates the Division of Medical Marijuana Regulation  
            (division) in the Department of Alcoholic Beverage Control  
            (ABC).

          3)Defines the following terms:

             a)   "Division" is the Division of Medical Marijuana  
               Regulation and Enforcement.

             b)   "Identification program" is "the universal  
               identification card program for mandatory commercial  
               registrants."

             c)   "Mandatory commercial registrant" is "any individual,  
               partnership, joint venture, association, limited liability  
               company, corporation, estate, trust, receiver, syndicate,  
               or any other group or combination thereof acting as a unit,  
               or any employee thereof, that operates any facility,  
               building, structure, or location where medical marijuana is  
               grown, possessed, stored, manufactured, tested, or sold,  
               other than a location or building in which a patient or  
               patient's primary caregiver, as defined by the  
               Compassionate Use Act of 1996, is growing medical marijuana  
               exclusively for patient medical use and not for sale."









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             d)   "Testing and labeling" means mandatory labeling and a  
               quality assurance plan in place that addresses:  dosage,  
               microbiological contaminants, random sample testing,  
               handling, care, and storage.

             e)   "Fund" is the Medical Marijuana Fund established under  
               Business and Professions Code Section 26028.

          4)Requires the division to be administered by a chief executive  
            to be appointed by the director.

          5)Mandates that the chief executive be the appointing authority  
            of all employees within the division.

          6)States that all heads of subdivisions or advisory commissions  
            within the division are responsible to the chief executive.

          7)Confers on the division all power necessary for the  
            administration of this chapter, including, but not limited to:

             a)   Establishing statewide standards for the cultivation,  
               manufacturing, testing, transportation, distribution, and  
               sales of medical marijuana and medical marijuana products;

             b)   Establishing a scale of state-imposed fees for the  
               cultivation, manufacture, testing, transportation,  
               distribution, and sale of medical marijuana and medical  
               marijuana products; 

             c)   Adopting, amending, and rescinding reasonable  
               regulations, special rulings, and necessary findings for  
               the regulation and control of the cultivation, manufacture,  
               testing, transportation, distribution, and sale of medical  
               marijuana, and to govern the procedures of the division to  
               exercise the powers and perform the duties conferred upon  
               it;

             d)   Approving or denying mandatory registration application  
               for cultivation, manufacturing, testing, labeling,  
               transportation, distribution, and sale of medical  
               marijuana;

             e)   Suspending, fining, restricting, or revoking mandatory  
               commercial registration upon a violation of a rule or  
               regulation adopted by the division;








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             f)   Imposing penalties;

             g)   Taking any reasonable action with respect to a mandatory  
               commercial registration application; 

             h)   Hearing and determining, at a public hearing, any  
               appeals of application denials and any complaints against a  
               mandatory commercial registrant;

             i)   Administering oaths and issuing subpoenas to require the  
               presence of individuals and the production of documents  
               necessary to the determination of a hearing; 

             j)   Maintaining the confidentiality of any information  
               obtained from a mandatory commercial registrant related to  
               medical marijuana patients and caregivers in strict  
               compliance with the federal Health Insurance Portability  
               and Accountability Act and other specified laws;

             aa)  Developing any necessary forms, identification cards,  
               and applications;

             bb)  Overseeing the operation of the Medical Marijuana Fund;  
               and, 

             cc)  Establishing reasonable fees.

          8)Allows the division to charge separate fees for each mandatory  
            commercial registrant application but limits the total fees  
            imposed to the total costs of administering this regulatory  
            scheme.

          9)Requires the division to assist in the development of uniform  
            policies for the taxation of medical marijuana businesses.

          10)Requires the division to identify successful regulatory  
            structures for the purpose of supporting cities and counties  
            in appropriately governing activities related to medical  
            marijuana.

          11)Establishes the Medical Marijuana Fund within the State  
            Treasury.  The fund shall include any interest and dividends  
            earned on money in the fund.









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          12)Specifies that all fees collected pursuant to this regulatory  
            scheme shall be deposited into the fees account, that all  
            monies are continuously appropriated without regard to fiscal  
            year to the division.

          13)Establishes the Medical Marijuana Penalties Account and  
            specifies that all penalties collected shall be deposited into  
            it.  All monies available in the penalties account are  
            available for purpose of this chapter, upon appropriation by  
            the Legislature.

          14)Requires, by July 1, 2014, the division to establish a  
            mandatory commercial registration program and a fee structure  
            for the cultivation, manufacture, testing, transportation,  
            distribution, and sale of medical marijuana and medical  
            marijuana products, and make available mandatory commercial  
            registration forms.

          15)Specifies that a mandatory commercial registration  
            application or renewal shall be approved unless the division  
            determines any of the following:

             a)   The applicant fails to meet the established requirements  
               or any regulation adopted;

             b)   The applicant, or any of its officers or directors, is  
               under 21 years of age; 

             c)   The applicant has knowingly answered a question or  
               request for information falsely on the form;

             d)   The applicant, or any of its officers or directors, has  
               been convicted in the past five years of a serious or  
               violent felony, as specified, a felony involving fraud or  
               deceit, or any other felony that, in the division's  
               estimation, would impair the applicant's ability to  
               appropriately operate medical marijuana cultivation,  
               manufacturing, testing, distribution or sales;

             e)   The applicant is a licensed physician making medical  
               marijuana recommendations for patients; or, 

             f)   The applicant, or any of its officers or directors, had  
               been sanctioned by the division for operating unregistered  
               commercial medical marijuana activities, or has had a  








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               registration revoked in the previous three years.

          16)Allows the division to establish various classes or types of  
            registration, including distinguishing between operators and  
            employees, for specific medical marijuana-related activities.

          17)States that each mandatory commercial registration  
            application approved by the division is separate and distinct.

          18)Allows an applicant to apply for registration in multiple  
            classes of specified medical marijuana activities.

          19)States that an approved application is valid for a period not  
            to exceed two years from the date of approval, unless revoked  
            or suspended.

          20)Requires the division to notify the registrant 90days prior  
            to expiration.

          21)Requires the registrant to apply for renewal not less than 60  
            days prior to expiration, but allows the division to waive  
            this requirement in its discretion.

          22)Requires the division to act upon a renewal application  
            within 10 days before expiration of the registration.

          23)Requires an application for mandatory commercial registration  
            to include, but not be limited to, all of the following:

             a)   A plan for conformance with testing;

             b)   A plan to address security for the premises where  
               marijuana cultivation, manufacturing, testing,  
               distribution, or sales will occur;

             c)   A plan for conformance with local zoning requirements;  
               and,

             d)   Protocols to prevent the unlawful diversion of  
               marijuana.

          24)Requires the division to approve and to contract with one or  
            more laboratories that can document compliance with industry  
            best practices to provide plan-consulting services and testing  
            services to determine compliance.








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          25)Allows the division to approve cultivation registration only  
            in conjunction with the city, county, or city and county land  
            use authority in which the cultivation occurs, where the city,  
            county, or city and county address compliance with relevant  
            state and federal environmental impact laws and regulations,  
            including, but not limited to clear-cutting, road building,  
            water diversion, and use of chemicals.

          26)Exempts all mandatory commercial registrants from arrest,  
            prosecution, or sanctions, as specified, unless the registrant  
            does not possess a valid registration or the conduct in  
            question is not within the scope of the registration.

          27)States that this chapter does not apply to and has no  
            diminishing effect on the rights and protections granted to  
            individual patients and primary caregivers under the  
            Compassionate Use Act (CUA).

          28)Exempts individual patients and caregivers cultivating  
            marijuana at their private residences who do not sell or  
            charge for the cultivation of marijuana from mandatory  
            commercial registration.

          29)Allows a facility, building, structure, or location operating  
            in conformance with local zoning requirements as of the  
            effective date of this chapter to continue to operate until  
            such time as its application for registration is approved or  
            denied.

          30)Requires the division to work with law enforcement entities  
            throughout California in order to implement and to enforce the  
            rules and regulations regarding medical marijuana, and to take  
            appropriate action against businesses and individuals who do  
            not comply.

          31)States that nothing in this chapter prevents a city, county,  
            or city and county from enforcing a local zoning ordinance or  
            law of general application.

          32)Requires, commencing on January 1, 2015, that any product  
            containing marijuana offered for sale be subject to testing  
            and labeling requirements.

          33)Makes it a misdemeanor, commencing on January 1, 2015, for  








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            any person, except a mandatory commercial registrant, to offer  
            for sale any product containing marijuana, or to operate any  
            facility where medical marijuana is grown, processed, stored,  
            manufactured, tested, or sold, other than a place where a  
            patient or his or her primary caregiver, as defined by the  
            CUA, is growing marijuana exclusively for patient use and not  
            for sale.

          34)Makes it a misdemeanor for a person to steal or fraudulently  
            use a registrant's identification card or status to acquire,  
            possess, cultivate, transport, use, produce, or distribute  
            marijuana, or to tamper with or fraudulently produce an  
            identification card or registration status.

          35)Establishes the following penalties for the misdemeanor  
            crimes:

             a)   For the first offense, imprisonment in the county jail  
               for no more than six months, or a fine up to $1,000, or  
               both.

             b)   For a second or subsequent offense, imprisonment in the  
               county jail for no more than one year, or a fine up to  
               $1,000, or both.

          36)Subjects a person operating an unregistered medical marijuana  
            facility to civil penalties of up to $25,000, which shall be  
            deposited in the Penalties Account.

          37)Authorizes the division to destroy any marijuana being  
            cultivated, manufactured, or possessed in violation of this  
            chapter.

          38)Prohibits the spending of funds by state or local officials  
            to assist federal authorities in enforcing federal marijuana  
            prohibitions with regard to activities carried out by  
            mandatory commercial registrants in compliance with these  
            provisions.  Nothing in this chapter shall be construed to  
            limit law enforcement's ability to investigate unlawful  
            activity in relation to a mandatory commercial registrant.

          39)States that the provisions of this Act are severable, and  
            that if one is held invalid, the invalidity will not affect  
            other provision which can still be given effect.









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           EXISTING LAW  : 

          1)States that the People of the State of California hereby find  
            and declare that the purposes of the Compassionate Use Act of  
            1996 are as follows:

             a)   To ensure that seriously ill Californians have the right  
               to obtain and use cannabis for medical purposes where that  
               medical use is deemed appropriate and has been recommended  
               by a physician who has determined that the person's health  
               would benefit from the use of cannabis in the treatment of  
               cancer, anorexia, AIDS, chronic pain, spasticity, glaucoma,  
               arthritis, migraine, or any other illness for which  
               cannabis provides relief.

             b)   To ensure that patients and their primary caregivers who  
               obtain and use cannabis for medical purposes upon the  
               recommendation of a physician are not subject to criminal  
               prosecution or sanction.

             c)   To encourage the Federal and State governments to  
               implement a plan to provide for the safe and affordable  
               distribution of cannabis to all patients in medical need of  
               cannabis. [Health and Safety Code (HSC) Sections  
               11362.5(b)(1)(A) to (C).]

          2)States that nothing in this section shall be construed to  
            supersede legislation prohibiting persons from engaging in  
            conduct that endangers others, nor to condone the diversion of  
            cannabis for nonmedical purposes.  [HSC Section  
            11362.5(b)(2).] 

          3)Provides that, notwithstanding any other provision of law, no  
            physician in California shall be punished, or denied any right  
            or privilege, for having recommended cannabis to a patient for  
            medical purposes.  [HSC Section 11362.5(c).]

          4)Defines a "primary caregiver" as the individual designated by  
            a patient who has consistently assumed responsibility for the  
            housing, health, or safety of that person.  [HSC Section  
            11362.5(e).]

          5)States existing law, relating to the possession and the  
            cultivation of cannabis, shall not apply to a patient, or to a  
            patient's primary caregiver, who possesses or cultivates  








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            cannabis for the personal medical purposes of the patient upon  
            the written or oral recommendation or approval of a physician.  
             [HSC Section 11362.5(d).]

          6)Requires the Department of Public Health to establish and  
            maintain a voluntary program for qualified patients to apply  
            for identification cards, and county health departments to  
            issue identification cards to qualified patients and their  
            caregivers.  [HSC Sections 11362.71(a) and (b)]. 

          7)Provides that persons with valid identification cards shall  
            not be subject to arrest for possession, transportation,  
            delivery, or cultivation of cannabis, absent evidence of  
            fraud.  [HSC Section 11362.71(e).] 

          8)Provides that patients and caregivers may possess and  
            cultivate an amount of cannabis reasonably necessary for the  
            patient's current medical needs, notwithstanding any limits  
            set by the Legislature that impermissibly amend the  
            Compassionate Use Act.  [People v. Kelly (2010) 47 Cal.4th  
            1008, 1043.]

          9)Requires a person who seeks an identification card to pay a  
            fee and provide to the county health department the person's:  
            name, proof of residency, written doctor's recommendation,  
            doctor's name and contact information, caregiver's name and  
            duties, and patient's and caregiver's government-issued photo  
            identification card.  [HSC Section 11362.715(a).] 

          10)Requires county health departments to issue serially numbered  
            identification cards to patients and caregivers containing: a  
            unique user identification number, an expiration date, the  
            county health department's name and telephone number, photo  
            identification of the cardholder, and a toll-free Department  
            of Public Health telephone number enabling state and local law  
            enforcement officers to immediately verify the card's  
            validity.  [HSC Section 11362.735(a).]

          11)Prohibits state or local law enforcement officers from  
            refusing to accept an identification card unless the officer  
            has reasonable cause to believe that the card is being used  
            fraudulently or its information is false or fraudulent.  (HSC  
            Section 11362.78.)

          12)Provides that qualified patients, persons with valid  








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            identification cards, and their designated primary caregivers  
            who associate in order collectively or cooperatively to  
            cultivate cannabis are not subject to criminal liability on  
            that basis.  (HSC Section 11362.775.)

          13)Restricts the location of medical marijuana cooperatives,  
            collectives, or dispensaries to more than 600 from a school,  
            and authorizes cities and counties to further restrict the  
            locations of these establishments.  [HSC Section 11362.768(b),  
            (f), and (g).]

          14)Allows local governments to adopt and enforce local  
            ordinances that regulate the location, operation, or  
            establishment of a medical marijuana collective or  
            cooperative.  [HSC Section 11362.83(a) and (b).]

          15)Prohibits the possession, possession with intent to sell,  
            cultivation, sale, transportation, importation, or furnishing  
            of marijuana, except as otherwise provided by law.  (HSC  
            Sections 11357, 11358, 11359, and 11360.)

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   

           1)Author's Statement  :  According to the author, "The people of  
            California overwhelmingly enacted the Compassionate Use Act of  
            1996 with the passage of Proposition 215.  The people declared  
            that their purpose in enacting the measure was, among other  
            things, '[to] ensure that seriously ill Californians have the  
            right to obtain and use medical marijuana for medical purposes  
            where that medical use is deemed appropriate and has been  
            recommended by a physician who has determined that the  
            person's health would benefit from the use of marijuana in the  
            treatment of cancer, anorexia, AIDS, chronic pain, spasticity,  
            glaucoma, arthritis, migraine, or any other illness for which  
            marijuana provides relief.'

          "The Compassionate Use Act of 1996 called on state government to  
            implement a plan for the safe and affordable distribution of  
            marijuana to all patients in medical need of marijuana.

          "In 2003, the Legislature enacted the Medical Marijuana Program  
            Act (MMPA).  Under the guidance of the MMPA, approximately 60  
            California cities and counties have created medical marijuana  








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            access ordinances that can act as a guide for the state.   
            However, many other cities and counties are calling for more  
            guidance and regulation from the state and have passed bans or  
            moratoria on medical marijuana cultivation and distribution  
            while awaiting such guidance.

          "Greater certainty and uniformity are urgently needed regarding  
            the rights and obligations of medical marijuana facilities,  
            and for the imposition and enforcement of regulations to  
            prevent unlawful cultivation and the diversion of marijuana to  
            nonmedical use."

           2)Medical Marijuana Law at Present  :  California voters passed  
            Proposition 215, the Compassionate Use Act (CUA), in 1996.   
            The CUA prohibits prosecution for growing or using cannabis of  
            Californians who have the oral or written recommendation of  
            their doctors, and these patients' caregivers.  The  
            Legislature sought to clarify this initiative in 2003 with SB  
            420 (Vasconcellos), Chapter 875, Statutes of 2003, the Medical  
            Marijuana Program Act (MMPA).  The MMPA offered a voluntary  
            identification card which patients and caregivers could obtain  
            that would additionally protect them from arrest, and set  
            limits on the amounts of cannabis to be legally grown and  
            possessed.  In 2010, the California Supreme Court ruled in  
            People v. Kelly, supra, 47 Cal.4th 1008 that the MMPA section  
            limiting quantities of cannabis is unconstitutional because it  
            amends a voter initiative.  Additionally, the U.S. Supreme  
            Court ruled in Gonzales v. Raich (2005) 545 U.S. 1, that the  
            federal government can enforce cannabis prohibition despite  
            state medical cannabis laws.
                                                                          
          Now, California patients who obtain a physician's oral or  
            written recommendation are protected from prosecution for  
            possessing or cultivating an amount of cannabis reasonably  
            related to their current medical needs, as are these patients'  
            caregivers.  Patients and caregivers who obtain a state MMPA  
            identification card from their county health department are  
            protected from arrest and prosecution for possessing,  
            transporting, delivering, or cultivating cannabis.  Patients  
            and caregivers who engage in these activities remain liable  
            for federal arrest and prosecution, and those who operate  
            dispensaries face frequent federal enforcement actions.  

          Meanwhile, many city and county officials have expressed  
            confusion about the scope of state medical cannabis law.  Some  








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            localities have passed ordinances that have been overturned by  
            the courts (Los Angeles) while others have been upheld  
            (Riverside).

           3)Pending Litigation Could Conflict with this Bill  :  The  
            California Supreme Court has recently granted review in  
            several cases related to the rights of medical cannabis  
            patients and dispensaries:  City of Riverside v. Inland Empire  
            Patient's Health and Wellness Center (review granted Jan. 18,  
            2012, S198638), People v. G3 Holistic (review granted Jan. 18,  
            2012, S198395); County of Los Angeles v. Alternative Medicinal  
            Cannabis Collective (review granted Sept.19, 2012, S204663);  
            420 Caregivers, LLC v. City of Los Angeles (review granted  
            Sept. 19, 2012, S204684); and, City of Temecula v. Cooperative  
            Patients Services, Inc., (review granted Dec. 12, 2012,  
            S206085).  All of these cases deal with the legality of local  
            rules regarding the operation and location of dispensaries and  
            cultivation sites.  Oral argument in the lead case, City of  
            Riverside v. Inland Empire Patient's Health & Wellness Center,  
            was held on February 5, 2013.  Generally, the Supreme Court  
            issues an opinion within 90 days of argument.  Since the  
            Supreme Court will soon rule on the legality of regulations  
            governing dispensaries, parts of this bill could possibly be  
            preempted.

           4)California Constitutional Limitations on Legislative  
            Regulation of Medical Marijuana  :
          Because the CUA was enacted by voter initiative, the Legislature  
            may not amend the statute without subsequent voter approval  
            unless the initiative permits such amendment, and then only  
            upon whatever conditions the voters attached to the  
            Legislature's amendatory powers.  [People v. Superior Court  
            (Pearson) (2010) 48 Cal.4th 564, 568; see also Cal. Const.,  
            art. II, Section 10, subd. (c).]  The California Constitution  
            states, "The Legislature may amend or repeal referendum  
            statutes.  It may amend or repeal an initiative statute by  
            another statute that becomes effective only when approved by  
            the electors unless the initiative statute permits amendment  
            or repeal without their approval."  [Cal. Const., art. II,  
            Section 10, subd. (c).]  Therefore, unless the initiative  
            expressly authorizes the Legislature to amend, only the voters  
            may alter statutes created by initiative.  Proposition 215 is  
            silent as to the Legislature's authority to amend that  
            proposition. 









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          The purpose of California's constitutional limitation on the  
            Legislature's power to amend initiative statutes is to protect  
            the people's initiative powers by precluding the Legislature  
            from undoing what the people have done, without the  
            electorate's consent.  Courts have a duty to jealously guard  
            the people's initiative power and, hence, to apply a liberal  
            construction to this power wherever it is challenged in order  
            that the right to resort to the initiative process is not  
            improperly annulled by a legislative body.  [Proposition 103  
            Enforcement Project v. Quackenbush (1998) 64 Cal.App.4th  
            1473.]  Yet, despite the strict bar on the Legislature's  
            authority to amend initiative statutes, judicial decisions  
            have recognized that the Legislature is not thereby precluded  
            from enacting laws addressing the general subject matter of an  
            initiative.  The Legislature remains free to address a  
            "related but distinct area" or a matter that an initiative  
            measure "does not specifically authorize or prohibit." [People  
            v. Kelly (2010) 47 Cal. 4th 1008, 1025-1026.] 

            As noted above, the California Supreme Court has previously  
            ruled on the Legislature's ability to regulate the use of  
            medical marijuana because it was an initiative.  In People v.  
            Kelly, supra, 47 Cal.4th 1008, the California Supreme Court  
            ruled that the Legislative restriction on the number of plants  
            a person may possess was unconstitutional as it interfered  
            with the rights established by the initiative.  Although the  
            Legislature may be able to clarify or expand the rights  
            established in Proposition 215, it may not enact legislation  
            that interferes with the use of marijuana for medicinal  
            purposes.  (Id. at 1044.)

            This bill establishes a regulatory scheme.  This bill does not  
            appear to place a greater burden on patients than the CUA  
            does.  Rather, by providing for the uniform regulation of  
            medical cannabis, arguably, this bill makes the rules clearer  
            for both law enforcement and medical cannabis users and  
            providers.  
             
           5)Argument in Support  :  According to the  American Civil  
            Liberties Union of California  , "Although the text of  
            Proposition 215, passed by the California voters in 1996,  
            specified that the Legislature should pass a statutory  
            regulatory scheme for the operation of medical marijuana  
            dispensaries in California, SB 420 (Vasconcellos) enacted in  
            2004, did not include any mechanism for the application and  








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            registration of commercial entities selling or distributing  
            marijuana.  Hence, more than fifteen years after the passage  
            of Proposition 215, a great deal of confusion has resulted  
            regarding the respective rights of patients, card holders, and  
            businesses, vis-'a-vis the duty and responsibility of local  
            governments to faithfully comply with the tenants of SB 420,  
            and authorize some access to medical marijuana within city or  
            county limits.

          "As a result, several local governments are now enacting  
            ordinances to ban, or substantially restrict collectives,  
            cooperatives, or other business entities distributing medical  
            marijuana from operating in a particular area.  Additionally,  
            there has been considerable federal law enforcement  
            intervention to those operating medical marijuana  
            dispensaries.  The California Supreme Court is currently  
            deciding on whether local government bans on medical marijuana  
            dispensaries are unconstitutional.  (Pack v. Long Beach 2011  
            WL 939163 (holding that local jurisdictions cannot ban  
            dispensaries).

          "By creating the Division of Medical Marijuana Enforcement  
            within the Department of Alcoholic Beverage Control,  
            businesses operating as growers, processors, manufactures, and  
            all other retailers, will be identified, licensed, and  
            regulated in a fair, unbiased, and uniform manner.  It will  
            also create a greater sense of stability and safety in the  
            operation of storefronts - decreasing the likelihood that  
            local governments will ban dispensaries.  Moreover, other  
            states with rigid regulatory schemes for the sale of medical  
            marijuana do not suffer from the same rate of federal  
            intervention.  AB 473 also ensures that the marijuana sold  
            complies with the highest standards for safety and quality.   
            This is crucial to protecting patients, and ensuring that the  
            marijuana purchased is safe and effective.

          "Finally, AB 473 specifically precludes any person who has been  
            convicted of a serious or violent felony from operating,  
            owning, or working in a storefront distributing medical  
            marijuana.  This is both a prudent public safety measure, as  
            well as a faithful application of both the spirit and the text  
            of Proposition 215."

           6)Argument in Opposition  :  The  California Narcotic Officers'  
            Association  states, "This bill will open the door to virtual  








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            unfettered trafficking in so-called medical marijuana.  AB 473  
            contemplates vesting jurisdiction over commercial marijuana in  
            the Department of Alcoholic Beverage Control.  In its present  
            form, AB 473 will prevent local governments from taking action  
            to keep marijuana stores out of their communities.  Moreover,  
            by creating a state agency to promote the trafficking of  
            marijuana, AB 473 has the unintended consequence of placing  
            state employees in danger of federal prosecution for promoting  
            illegal drug trafficking.

          "Marijuana is and remains a Schedule I substance.  Its  
            cultivation and trafficking are prohibited under federal law.   
            AB 473 appears to even go beyond the confines of current  
            California law by proposing a commercial model for so-called  
            medical marijuana that is not authorized by Proposition 215 or  
            by Senate Bill 420.  In short AB 473 appears to be in  
            violation of both federal and state law."

           7)Related Legislation  :  SB 439 (Steinberg) exempts marijuana  
            collectives and cooperatives from criminal acts and abatement  
            of certain nuisance provisions.  SB 439 also exempts those  
            entities and persons from criminal prosecution or punishment  
            solely on the basis of the fact that they receive compensation  
            for actual expenses incurred in carrying out activities that  
            are in compliance with those guidelines.  SB 439 is pending  
            hearing by the Senate Public Safety Committee.

           8)Prior Legislation  :  

             a)   AB 2312 (Ammiano), of the 2011-12 Legislative Session,  
               would have established the Medical Marijuana Regulation and  
               Control Act, authorizing local taxes on medical cannabis  
               and creating a board to regulate the medical cannabis  
               industry.  AB 2312 was never heard by the Senate Committee  
               on Business, Professions and Economic Development.

             b)   AB 1300 (Blumenfield), Chapter 196, Statutes of 2011,  
               provides that a local government entity may enact an  
               ordinance regulating the location, operation or  
               establishment of a medical marijuana cooperative or  
               collective; authorizes local government entity to enforce  
               such ordinances through civil or criminal remedies and  
               actions; and authorizes a local government entity to enact  
               any ordinance that is consistent with the Medical Marijuana  
               Program.  AB 1300 did not directly regulate medical  








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               marijuana facilities.  

             c)   SB 626 (Calderon), of the 2011-12 Legislative Session,  
               would have required the Board of Equalization (BOE) to  
               establish a nine-member task force to conduct a study to  
               determine ways to enhance collections of sales and use  
               taxes on retail sales of marijuana and ensure proper  
               regulation of the cultivation, transportation, and  
               distribution of marijuana and marijuana products.  SB 626  
               was held on the Senate Appropriations Committee's Suspense  
               File.

             d)   AB 390 (Ammiano), of the 2009-10 Legislative Session,  
               would have legalized the possession, sale, cultivation and  
               other conduct relating to marijuana and required ABC to  
               administer and enforce the terms of legalized marijuana.   
               AB 390 passed this Committee and was never heard by the  
               Assembly Committee on Health.

             e)   SB 1098 (Migden), of the 2007-08 Legislative Session,  
               would have required the State Board of Equalization to  
               administer a tax amnesty program, as specified, for medical  
               marijuana dispensaries, as defined.  SB 1098 was never  
               voted on by the Senate Revenue and Taxation Committee.

             f)   SB 420 (Vasconcellos) Chapter 875, Statutes of 2003,  
               established the Medical Marijuana Program Act, 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.

             g)   Proposition 215, of the November 1996 General Election,  
               prohibits prosecution for the possession and cultivation of  
               cannabis by a patient or a patient's primary caregiver with  
               a physician's written or oral recommendation or approval.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          American Civil Liberties Union of California
          California Attorneys for Criminal Justice
          California Public Defenders Association
          Drug Policy Alliance
          Legal Services for Prisoners with Children








                                                                  AB 473
                                                                  Page  17

          Marijuana Policy Project
          United Food and Commercial Workers Western States Council

           Opposition 
           
          Alcohol Justice
          California Council on Alcohol Problems
          California District Attorneys Association
          California Narcotics Officers' Association
          California Police Chiefs Association, Inc.
           

          Analysis Prepared by  :    Sandy Uribe / PUB. S. / (916) 319-3744