DHS Divides Arizona into 126 Community Health Analysis Areas (CHAAs) for Dispensary Locations

The second draft of the Arizona Department of Health Services medical marijuana rules apparently divided Arizona into 126 areas where dispensaries can be located.  These areas are called “Community Health Analysis Areas (CHAAs).”  See the map of the CHAAs.  Read DHS Director Will Humble’s January 28, 2011, explaination of CHAAs in which he states:

“Several years ago, our public health statistics team divided the State into 126 Community Health Analysis Areas to help us analyze data for various disease monitoring programs.  The initial trigger to develop the CHAAs was a 1988 law that directed the ADHS to use the data in the cancer registry to identify areas and populations that need investigation.”

By |2011-02-06T09:13:21-07:00January 31st, 2011|CHAAs, DHS Rules, Will Humble Speaks|Comments Off on DHS Divides Arizona into 126 Community Health Analysis Areas (CHAAs) for Dispensary Locations

Arizona Department of Health Services Issues 1/31/11 Draft of Its Medical Marijuana Rules

Today, January 31, 2011, Arizona Department of Health Services posted its second draft of its proposed Arizona medical marijuana rules.  Check back.  I will review the second draft of the rule as soon as possible and put up a new article.  Here are my first impressions of changes made to the first draft of the rules:

  • New:  “CHAA” means a Community Health Analysis Area, a geographic area based on population, established by the Department for use by public health programs.
  • New:  The walls of the cultivation site must prevent anybody from seeing the plants from outside the walls of the facility.
  • New:  There is a two stage process.  Stage 1:  Dispensary applies for and received a dispensary registration certificate.  Stage 2:  apply for a approval to operate a dispensary.  A dispensary that has a DRC may apply for a   The Department shall accept dispensary registration certificate applications for 30 calendar days beginning May 1, 2011.
  • Change:  The two year residency requirement went from two years to three years.
  • Change:  A business plan demonstrating the on-going viability of the dispensary as on a non-profit organization not-for-profit basis.  Very interesting!
  • ChangeThe dispensary is not required to grow any of its marijuana.
  • Change:  Medical directors can serve an unlimited number of dispensaries rather than just three.
  • Change: Eliminated the requirement for dispensary agents with respect to surety bonds and failure to file a tax return.
  • New:  Revoke a dispensary registration certificate if it operates before obtaining approval to operate a dispensary from the Department.

DHS asks the public to submit comments to the proposed rules.

Related story “CHAA on This!”

By |2011-02-03T16:17:09-07:00January 31st, 2011|DHS Rules|Comments Off on Arizona Department of Health Services Issues 1/31/11 Draft of Its Medical Marijuana Rules

Update on Arizona Attorney Rules of Professional Conduct and Medical Marijuana

Question:  Will the Arizona State Bar allow Arizona lawyers to represent businesses in the Arizona medical marijuana industry or will it push the industry toward LegalZoom?

Answer:  The Arizona State Bar says to Arizona lawyers, “we’ll  get back to you on that.”  Today, January 31, 2011, I received the following email message from John F. Phelps, CEO/Executive Director of the Arizona State Bar:

The State Bar’s Committee on Rules of Professional Conduct has undertaken a review of Arizona’s new medical marijuana law and its impact on our ethical rules.  The committee is composed of members of the State Bar from a wide variety of practice areas, all with significant experience and interest in lawyer ethics.  The State Bar plans to provide guidance on this matter in advance of the law’s implementation, currently scheduled for late March of this year.  In the interim, the State Bar will not take regulatory action against attorneys for counseling or assisting clients in the implementation of the medical marijuana law during this period.

By |2012-08-18T09:14:52-07:00January 31st, 2011|Legal Issues, Stories & Articles|Comments Off on Update on Arizona Attorney Rules of Professional Conduct and Medical Marijuana

Arizona Department of Health Services Director Will Humble Discusses Arizona’s Medical Marijuana Law

KSAZ Fox 10 TV interviews Arizona Department of Health Services Will Humble on Arizona’s new medical marijuana law.

Health Director Committed to Preventing Pot Misuse: MyFoxPHOENIX.com

By |2015-04-06T18:49:27-07:00January 31st, 2011|Stories & Articles, Video, Will Humble Speaks|Comments Off on Arizona Department of Health Services Director Will Humble Discusses Arizona’s Medical Marijuana Law

Arizona Association of Dispensary Professionals Threatens to Sue Phoenix Over Its Pre-registration Zoning Procedure

Alan Sobol and the Arizona Association of Dispensary Professionals are claiming that the City of Phoenix zoning department has been up to no good.  Here is the text of a January 31, 2011, email message I received from Alan Sobol and the Consiglieri Group:

We have uncovered a scheme to defraud Dispensary Applicants in the City of Phoenix. Phoenix recently implemented a Pre-registration scheme fraught with Cronyism, Nepotism, Favoritism and Abuse of Authority.  To read the complaint click here: (seed2success.com/phxcomplaint.html).  We have exposed the truth, now we need to wait and see what the mayor will do. If you were planning to file for zoning approval in the City of Phoenix I urge you to contact the city and let them know what you think about this.  mayor.gordon@phoenix.gov  If you have any questions or comments please contact me at Marijuanamarketing@gmail.com

Thanks,

Al Sobol

Read the Press Release found at the above link.  AZADP alleges that Phoenix instituted its medical marijuana zoning pre-registration without legal authority because pre-registration is not provided for in the zoning ordinance G-5573 adopted by the Phoenix CIty Council.  Quotes from the Press Release:

Notice of Intent to Commence Legal Action:  City of Phoenix Initiates Illegal Pre-registration of Potential Marijuana Sites:  Allegations of Fraud, Cronyism, Nepotism, Favoritism and Abuse of Authority

It appears from the evidence that the City’s “pre-registration” program was solely intended to provide certain influential entities preferential treatment with respect to the selection of their medical Marijuana Business locations.

By |2014-01-05T09:52:55-07:00January 31st, 2011|Stories & Articles, Zoning|Comments Off on Arizona Association of Dispensary Professionals Threatens to Sue Phoenix Over Its Pre-registration Zoning Procedure

Don’t Copy Original Content Found on This Site Without Prior Written Consent

Warning:  Do Not Steal Our Content

I spend a considerable amount of time writing original content for this website and other websites I own.  None of my original content may be copied or republished without my express prior written consent.

In the last week, I learned that two different websites each copied my original content more than once.  I am not a happy camper when that happens.  The U.S. copyright law provides that nobody can copy or republish a copyrighted work without the consent of the copyright holder. Last week I asked one of the sites to take down my articles and that site complied immediately.  Today I learned of the second site on which I found three articles that were copied entirely.  I asked that site to take down those articles.  Neither site had the courtesy to link to this site.

I am the copyright holder for all original content on this site, except for articles that are written by other people whose names appear at the beginning of the article.  I do register the copyrights for all the original content on this site with the U.S. Copyright office.  As the warning says on the right column – do not steal content from a copyright lawyer, which I am.  If you steal my content, you risk having me file a lawsuit for copyright infringement in federal court and asking the court to impose statutory damages of $150,000 for each infringement.  Take my advice, you don’t want to be a defendant in a copyright infringement lawsuit when the plaintiff holds a registered copyright.

Warning to Infringers:  If you think I will not discover that you stole my content, you would be making a mistake that could cost you a lot of money.  There are websites that find and monitor copyright infringement on the internet.  See for example Copyscape.   Infringers should know that KEYTLaw attorney Richard Keyt is a copyright lawyer and his brother, Norman Keyt is the copyright infringement litigation attorney who will represent me in the federal court lawsuit.  I could be wrong, but my copyright lawyer will probably cost me a lot less than yours plus your lawyer won’t be getting paid to represent you on a contingency fee basis.

If you want to learn more about U.S. copyright law and the large financial liability incurred by somebody that copies a work that was registered with the U.S. Copyright Office,  read the following articles on this topic that I wrote in while wearing my copyright lawyer hat:

  • Internet Copyright Law: A Rat Pilfered My Web Site Cheese – What Do I Do?  Remedies for Web Site Copyright Infringement
  • Top 10 Urban Copyright Myths
  • Benefits of Web Site Copyright Registration
By |2015-04-06T18:49:27-07:00January 30th, 2011|Copyright Warning|Comments Off on Don’t Copy Original Content Found on This Site Without Prior Written Consent

Arizona Main Stream Media Silent on HB 2557 & the Proposed 300% Tax on Medical Marijuana

HB 2557 (aka the Grow Your Own Pot All Over Arizona Act or the Small Group of Elites Overrules the Majority of the Arizona Voters Act)

On January 26, 2011,  a group of legislators who want to overturn the will of the majority of the Arizona people who voted for Arizona Proposition 203 (legalization of medical marijuana) and who know what is best for the masses introduced a proposed law that would kill Arizona’s medical marijuana industry before it begins and allow all 160,000 future medical marijuana patients to grow their own marijuana.  House Bill 2557 will, if enacted unchanged, impose a sales tax of 300% on all medical marijuana.  That means a $10 THC laden candy bar would cost the patient $40 and an ounce of marijuana that retails for $250 would cost the patient $1,000.

I googled “HB 2557” and marijuana today and found only one story in the first 5 pages of Google results in Arizona’s main stream media about HB 2557.  The Tucson Citizen published a story on January 26, 2011, entitled “Drug Cartel Empowerment Act: Arizona Legislature proposes 300% sales tax on medical marijuana,” which stated:

All I can say is WTF are you thinking?

On January 27, 2011, the Arizona Daily Star published “Medical marijuana sales taxable, Horne says” in which HB 2557 is discussed.  Apparently the paper interviewed one of the bill’s sponsors, Rep. Steve Farley, D-Tucson (phone (602) 926-3022; email address: sfarley@azleg.gov), about HB 2557.   Farley said the tax could bring in as much as $1.8 billion a year and solve Arizona’s deficit problem.  He also claimed that patients would not have a problem paying a total of $160 to buy an ounce of medical marijuana for $40.  This guy appears to be out of touch with reality.  Taxing anything 300% does not generate more sales tax revenue it generates ZERO sales tax revenue.  Is there any item in the U.S. that must be purchased for 4 times its actual value?

My clients who operate dispensaries in Colorado tell me that an ounce of medical marijuana in Colorado sells between $250 – $400 depending on the strain and quality.  For the benefit of the we know what is best for the people of Arizona legislators who think a 300% sales tax will generate revenue, I will do the math and show my work.

Example:  Patient goes to local dispensary to purchase 1 ounce of medical marijuana and decides to buy the cheapest ounce for $250.  Clerk rings up the sale and says “that will be $1,000 please.”  Let’s analyze this sale from the perspective of the Arizona legislators who live in a different world and the perspective of the average guy on the street who may not be as smart as our legislators.

How the legislators  think:  160,000 patients will happily fork over $1,000 to buy one $250 ounce of medical marijuana as just a small part of the patient’s grand plan to purchase 5 ounces per month and 60 ounces a year. Total cost to patient to purchase 60 ounces a year = (60 ounces x $250) $15,000 plus 300% tax of $45,000 = $60,000.  Total sales tax revenue collected annually on medical marijuana purchases by 160,000 patients = 160,000 x $45,000 = $7,200,000,000.   Budget deficit solved with the additional bonus that Arizona will have so much new revenue it can cancel all other types of sales taxes.

How the patients and citizens think:  Are you kidding?  Nobody is going to pay $40 for a $10 candy bar or $1,000 for a $250 ounce of medical marijuana.   All  160,000 patients will grow their own marijuana.  Total sales tax revenue collected by Arizona = 160,000 patients x $0 plus $0 sales tax = $0.  There will not be medical marijuana dispensaries in Arizona.

Some years ago the brains in Congress who also are unaware of the laws of economics passed a luxury tax on yachts.  The idiots actually thought that the rich would be happy to pay the tax and the federal government would collect more revenue.  What actually happened was the rich (who are not stupid) stopped buying luxury yachts, the luxury yacht manufacturing industry died and the federal government collected less money from yacht sales.

Main Stream Media Not Reporting for Duty

Why isn’t the main stream media reporting this story?  Does the main stream media oppose Proposition 203 and want to suppress news of HB 2557 to minimize public opposition to the bill?  Early on the morning of January 27, 2011, I called and emailed an Arizona Republic reporter who has written a lot of stories about Prop 203 and medical marijuana in Arizona.   The reporter responded that he/she would check out my January 27, 2011, article called “Arizona Legislators Introduce HB 2557 to Overturn Voters Approval of Proposition 203.”  No Republic story on the 27th, 28th or 29th, but it did have two  “who cares” stories on the front page of the Saturday, January 29, 2011, online version of the paper called “Valley cities fight unwanted garage-sale signs” and “Economy has 3 Valley chefs down, not out.”

What gives?  Why aren’t the big Arizona papers and TV channels covering this story?

By |2014-05-21T19:46:29-07:00January 29th, 2011|AZ Legislation, Legal Issues, Tax Issues|Comments Off on Arizona Main Stream Media Silent on HB 2557 & the Proposed 300% Tax on Medical Marijuana

Phoenix Medical Marijuana Zoning a Confusing Nightmare

People are asking me questions about Phoenix zoning that I cannot answer such as:

  • What is pre-registration, what does it mean and how does it work?
  • If I pre-register how does pre-registration relate to actual registration?
  • The application requires the applicant to list the location of all existing and/or pending medical marijuana dispensaries, cultivation and infusion facilities within 5,280 feet (1 mile) of the applicant’s site.  Are you kidding?  How in the world would an applicant know the location of other sites that have not yet been approved by Phoenix zoning and that do not yet have DHS licenses?
  • The application requires the applicant to submit its operations procedures.  Excuse me!  What are operations procedures?  Arizona Department of Health Services doesn’t require operations procedures so why would Phoenix other than to create a pain in the nonprofit entity’s butt.
  • The application requires the applicant to submit a plot plan or survey showing compliance with the separation requirements.  Does this mean the applicant must hire a licensed surveyor to prepare a survey that shows the location is not too close to any thing?  Probably.  You will need a legal description of the site, which a surveyor can provide if it’s not easily obtainable.  Without a survey how are you going to determine if your location is more than:

1.  5,280 feet from existing and/or pending medical marijuana dispensaries, cultivation and infusion facilities

2.  1,320 feet from all preschool, kindergarten, elementary, secondary or high school, public park or public community center

3.  500 feet from all places of worship

4.  250 feet from any residence (for a dispensary)

5.  1,000 feet from any residence (for cultivation and infusion sites).  I thought the 1,000 foot setback was a typo because according to my calculations (which could be wrong because I’m a lawyer not a mathematician) the site would have to be at least 92 acres in size.  A 1,000 foot setback requires a square parcel to have four sides each 2,000 feet long, which is 4,000,000 square feet.  Are there any locations in Phoenix that have the necessary zoning and meet this setback requirement?

The application contains this confusing statement:

“Registrations that have expired are NON-RENEWABLE. A new registration for the proposed use shall not be accepted within thirty (30) days of the expiration date of the prior registration. A maximum one-time thirty (30) day extension may be granted to the applicant by the Zoning Administrator.”

Here are links to the actual Phoenix zoning documents:

For additional information, questions, or comments, please send an e-mail to larry.tom@phoenix.gov.

I am not the only one who has a problem with Phoenix’ zoning ordinance and procedures.  See “Arizona Association of Dispensary Professionals Threatens to Sue Phoenix Over Its Pre-registration Zoning Procedure.”

By |2015-04-06T18:49:26-07:00January 28th, 2011|Stories & Articles, Zoning|Comments Off on Phoenix Medical Marijuana Zoning a Confusing Nightmare

Arizona Attorney General Calls for a Tax on Medical Marijuana

Arizona Republic:  “Attorney General Tom Horne opposed a ballot measure to legalize medical marijuana  but now he’s calling for it to be taxed.  State tax collectors say that’s exactly what they plan to do.”

The Republic missed the big story on taxing medical marijuana.  On January 26, 2011, a group of legislators introduced House Bill 2557 (aka the “Don’t Divert Money from the Drug Cartels Act”) that would tax the sale of medical marijuana at the rate of 300 percent.  See “Arizona Legislators Introduce HB 2557 to Overturn Voters Approval of Proposition 203.”

By |2014-01-05T09:52:27-07:00January 28th, 2011|Tax Issues|Comments Off on Arizona Attorney General Calls for a Tax on Medical Marijuana

Arizona Medical Marijuana Dispensaries Need Commercial Insurance

No business should operate without insurance, especially a business in which the owners have invested a lot of money.  Bad things happen in business no matter how careful people are.  All businesses need appropriate insurance first to pay the legal cost to defend a lawsuit and second to pay the amount of a judgment or settlement.

All Arizona medical marijuana dispensaries need appropriate commercial insurance for all of their activities.  I feared that perhaps the industry might not be able to buy insurance because the business involves the possession and sale of marijuana, a substance that is illegal to possess and sell under federal law.

Fortunately my fear is unfounded.  My long-time good friend Dan Ellington, a commercial insurance agent with BBVA Compass Insurance in Phoenix, tells me that he and his firm are able to advise prospective Arizona medical marijuana dispensaries and dispensaries with licenses on the types of commercial insurance needed and the coverage amounts and purchase the desired insurance for the dispensaries.

Hee are a few of Dan Ellington’s comments to me about insuring an Arizona medical marijuana dispensary:

  • Insurance coverage can be obtained for professional liability associated with dispensing.
  • Insurance coverage can be obtained for general liability associated with the dispensing location.
  • Coverage cannot exceed what is allowed under Arizona law.
  • Products / completed operations can be insured only if the marijuana sold by the dispensary is grown by the dispensary.
  • Products-stand alone coverage may be offered under products line of business.
  • If the dispensary or cultivation site has armed security, the insurer considers the insured to have a very high hazard situation.
  • Coverage will be denied if the insured does not comply with all applicable laws, statutes, regulations, ordinances and other federal, state and local restrictions governing the dispensing of medical marijuana.
  • Minimum policy premium $2,750
  • Maximum limits:  $1 million per claim; $3 million aggregate.
  • Minimum deductible:  $2,500.

For more information about insuring your dispensary or to purchase insurance for your dispensary, call Dan Ellington at 602-956-7800.  BBVA Compass Insurance is located at 2002 East Osborn Road, Phoenix, AZ 85016.

By |2011-01-29T14:32:18-07:00January 27th, 2011|Dispensary Insurance, Stories & Articles|Comments Off on Arizona Medical Marijuana Dispensaries Need Commercial Insurance

Medical Marijuana in Community Associations – A Smoking Hot Issue

My friend Beth Mulcahy is one of the premier homeowner association (HOA) attorneys in Arizona.  What follows is the text of a January 27, 2011, email message she sent to her clients and others in which she discusses issues Arizona’s new medical marijuana law creates for HOAs.

In late 2010, Arizona residents voted via Prop 203 to legalize medical marijuana. This new law will allow qualifying patients with certain debilitating medical conditions (such as cancer, HIV/AIDS, hepatitis C and multiple sclerosis) to receive up to 2 1/2 ounces of marijuana every two weeks from dispensaries or cultivate up to 12 marijuana plants if they live 25 miles or farther from a dispensary. Arizona became the fifteenth (15) state to approve medical marijuana. The approval of Prop 203 was a surprise, having passed by approximately 4,300 votes out of 1.67 million votes cast and being behind by 7,200 votes on Election Day in November, 2010.

The state health department released its first draft of medical-marijuana rules in December, 2010. The rules outline who may qualify for medical marijuana, establish operating criteria for dispensaries and provide strict guidelines for doctors who may recommend marijuana. The state health department must finish drafting the rules by April 13, 2011.The agency will then review applications from people who want to use medical marijuana or operate a dispensary. The program should be fully functioning by summer 2011, when dispensaries have had time to grow the plants.

Our firm has received questions regarding how this law will apply to community associations. At present, it is our firm’s opinion that this is a complicated issue and as association rules conflict with a unit/lot owners’ use of medical marijuana the issue will become more entangled. A major concern is that marijuana is not legal under federal law.

A few questions association boards should consider and discuss:

1. Should association boards allow residents to smoke medical marijuana on association common areas?

It is our firm’s position that association boards can pass rules pursuant to their association documents to prohibit smoking of medical marijuana on association common areas. It is important to note that under Arizona law, an owner would be allowed to smoke medical marijuana within the confines of their unit or lot.

2. Should association boards allow owners to grow medical marijuana on association common areas?

It is our firm’s position that growing of medical marijuana on association common areas can be prohibited by the association so long as rules to that effect are passed by the board.

3. What can the association do if neighbors complain about medical marijuana use by another owner within that owner’s unit?

This is a complicated situation and will need to be evaluated on a case by case basis. Is the medical marijuana use prohibiting the peaceful enjoyment of the use of their unit by the complaining owner?

4. Can a commercial space, in mixed use communities, be used as a medical marijuana dispensary?

Medical marijuana dispensaries may try to rent space in mixed use associations. Will other tenants complain about the type of individuals who patronize them? It is our firm’s opinion that an association would NOT have the right to prohibit the rental of space to medical marijuana dispensaries.

These are all tough questions. As this issue comes to the forefront for associations our firm suggests that boards and managers consult with our firm to discuss options and risks regarding use of medical marijuana within associations.

Articles that appeared in the November and December Arizona Republic were the source for this article.

The author, Beth Mulcahy, is the founder and senior partner of the Mulcahy Law Firm, P.C.  See the firm’s website for more information about the firm.

By |2011-01-27T19:14:24-07:00January 27th, 2011|Legal Issues|Comments Off on Medical Marijuana in Community Associations – A Smoking Hot Issue

Arizona Legislators Introduce HB 2557 to Overturn Voters Approval of Proposition 203

The voters of Arizona spoke when a majority approved Proposition 203.  Now a group of elected elites who know what is best for the people of Arizona introduced House Bill 2557 (aka the “Don’t Divert Money from the Drug Cartels Act”) on January 26, 2011, for the sole purpose of killing Arizona’s medical marijuana industry before it begins.  Maybe the goal of the elites is to kill the dispensary industry so that under Proposition 203 nobody will live within 25 miles of a dispensary so all licensed patients can grow their own throughout the entire state.

Yesterday Arizona’s Attorney General Tom Horne issued a press release that said Arizona could impose a sales tax on medical marijuana and he estimated Arizona would collect $40 million in badly needed revenue.  If HB 2557 passes, Arizona can kiss the medical marijuana industry good bye, which means no need for the 125 would be dispensaries to hire thousands of employees, security personnel, growers, transporters and the many other types of ancillary jobs that the industry would generate.

Here is the key language in HB 2557.  It will amend Arizona Revised Statutes Section 42-5010 by adding the following as new subsection A.5 to read:

The tax imposed by this article is levied and shall be collected at the following rates:

THREE HUNDRED PER CENT OF THE TAX BASE AS COMPUTED FOR THE BUSINESS OF EVERY PERSON ENGAGING OR CONTINUING IN THIS STATE IN THE NONPROFIT MEDICAL MARIJUANA DISPENSARY CLASSIFICATION DESCRIBED IN SECTION 42-5077.

HB 2557 will add the following new section 42-5077 to Arizona’s statutes:

42-5077. Nonprofit medical marijuana dispensary classification

A.  THE NONPROFIT MEDICAL MARIJUANA DISPENSARY CLASSIFICATION IS COMPRISED OF THE BUSINESS OF SELLING OR DISPENSING MEDICAL MARIJUANA TO  QUALIFYING PATIENTS PURSUANT TO TITLE 36, CHAPTER 28.1.

B.  THE TAX BASE FOR THE NONPROFIT MEDICAL MARIJUANA DISPENSARY CLASSIFICATION IS THE GROSS PROCEEDS OR GROSS INCOME DERIVED FROM THE BUSINESS.

C.  IF A PERSON WHO IS ENGAGED IN BUSINESS AS A NONPROFIT MEDICAL MARIJUANA DISPENSARY ALSO SELLS OTHER TANGIBLE PERSONAL PROPERTY AT RETAIL, THE PERSON’S BOOKS MUST SEPARATELY ACCOUNT FOR SALES OF THE OTHER TANGIBLE PERSONAL PROPERTY, AND IF NOT SO KEPT THE TAX UNDER THIS SECTION APPLIES TO  THE TOTAL OF THE PERSON’S ENTIRE GROSS PROCEEDS OR GROSS INCOME FROM THE BUSINESS.

If you want Arizona to have legalized medical marijuana, you must tell your legislators to impose a reasonable tax on medical marijuana of 5% – 7%.  Here’s the contact information for the Arizona legislators who introduced this bill (more…)

By |2017-02-11T17:28:53-07:00January 27th, 2011|AZ Legislation, Legal Issues, Tax Issues|Comments Off on Arizona Legislators Introduce HB 2557 to Overturn Voters Approval of Proposition 203

Arizona’s Three Universities Will Ban Medical Marijuana on Campus

East Valley Tribune:  “federal law prohibits possession and use of marijuana, even for medical purposes. And the penalty for schools that don’t enforce that . . . is loss of any federal aid, including student participation in the guaranteed student loan program.

By |2011-02-16T18:35:44-07:00January 26th, 2011|Stories & Articles|Comments Off on Arizona’s Three Universities Will Ban Medical Marijuana on Campus

Medical Marijuana Will be Taxed Says Arizona Attorney General Tom Horne

Here is the text of a January 26, 2011, press release by Arizona Attorney General Tom Horne:

HORNE TO RECOMMEND TAXATION OF MEDICAL MARIJUANA

Phoenix (Wednesday January 26, 2011) – Attorney General Tom Horne today announced that he is recommending to the Arizona Department of Revenue that medical marijuana, made legal in a recent initiative, be taxed by the State.

Horne stated, “I was opposed to the medical marijuana initiative during the 2010 election, but it was passed by the voters and the issue now presented is whether it should be taxed under existing law.”

He added, “Normally, there would be no tax on prescriptions. However, the legislation refers to doctors giving a ‘written certification’ rather than a prescription, an apparent effort, copied from other states, to protect doctors from discipline for giving prescriptions of substances prohibited under federal law. Since these are ‘written certifications’ rather than prescriptions, the sale of the substance can be taxed by the State, and we are recommending to the Department of Revenue that it tax the sales accordingly. We are informed by the Department of Revenue that they will take this advice, and tax the sales.”

The taxes are estimated to yield revenues to the State of Arizona in the approximate amount of $40 million per year. This number is projected, on a pro rata basis, to the Arizona population the statistics for Denver County, as reported by the Denver Post using the Phoenix sales tax rate.

By |2011-01-26T21:09:26-07:00January 26th, 2011|Legal Issues, Tax Issues|Comments Off on Medical Marijuana Will be Taxed Says Arizona Attorney General Tom Horne

Must All Dispensary Owners, Officers & Directors be U.S. Citizens?

Question:  Must all owners, officers and members of the board of directors of an Arizona medical marijuana dispensary be a citizen of the United States?

Answer:  Apparently “the principal officer” or one board member must be a U.S. citizen as of today, January 26, 2011. It appears that no other owner, officer or director must be a U.S. citizen, except for  the one  “principal officer” or board member selected by the insiders to give proof of U.S. citizenship to the Arizona Department of Health Services.

Although Proposition 203 does not contain U.S. citizenship or Arizona residency requirements, the first draft of the Arizona Department of Health Services rules contain both requirements.  Rule R9-17-107.F.1.d.v(1) requires that after a dispensary applicant receives the written notice of preliminary approval from DHS, the applicant shall submit to DHS “a copy of  the principal officer or board member’s Arizona driver’s license or identification card issued before October 1, 1996, and one of the following:

(1)  Birth certificate verifying U.S. citizenship,
(2 ) U. S. Certificate of Naturalization, or
(3)  U. S. Certificate of Citizenship.”

My take from reading this poorly worded rule is that only one person who is an owner, officer or board member of an Arizona medical marijuana dispensary must be a United States citizen.  The term “principal officer” is used 47 times in the rules, but the term is not defined.

By |2011-01-26T21:00:21-07:00January 26th, 2011|DHS Rules, Legal Issues, Questions People Ask|Comments Off on Must All Dispensary Owners, Officers & Directors be U.S. Citizens?

New Daily & Weekly Vistor Record

The number of visitors to Arizona Medical Marijuana Law continues to grow.  On January 24, 2011, we had 604 visitors, a new daily record.  For the week ending at midnight on January 23, 2011, this site had 2,750 visitors.   Not bad for its fourth week of existence.

Thanks for stopping by.  Please send a link to this site at www.arizonamedicalmarijuanalaw.com to your friends and people who you think might have an interest in Arizona medical marijuana.  Don’t forget to send suggestions for articles.  If you have an original article you think would be of interest to our readers, please send it to me.

By |2015-04-06T18:49:23-07:00January 25th, 2011|Miscellaneous|Comments Off on New Daily & Weekly Vistor Record

How Can a Non-Arizona Resident Who Wants to Own an Interest in an Arizona Medical Marijuana Dispensary Participate Before Becoming a Resident?

Question:  Arizona Department of Health Services’ first draft of the medical marijuana dispensary rules requires that all officers and directors of Arizona medical marijuana dispensaries be Arizona residents for at least three years.  I don’t satisfy the residency requirement so how can I be involved in a dispensary now and become an owner when I qualify?

Answer:  There are several ways.  If your goal is to own an interest in an Arizona medical marijuana dispensary, you must establish Arizona residency for at least three years so the sooner you move to Arizona, the sooner you will meet the residency requirement.  The current DHS rules contain a three year Arizona residency requirement to be an owner, officer or director of a dispensary.  Myself and others have suggested to DHS that it eliminate the residency requirement because the requirement is not contained in Proposition 203 and it is a violation of the equal protection clause of the United States Constitution.  DHS could increase or decrease the residency requirement or eliminate it altogether before it issues the final rules.

A person who has not lived in Arizona for three years could become a paid employee or an unpaid volunteer of a dispensary.  These positions are great learning experiences and can help to establish contacts and relationships with the dispensary owner that could lead to an ownership interest in a dispensary.  However, without a legally binding written contract between you and the nonprofit entity or the owner(s) of the nonnprofit entity to acquire an ownership interest in the dispensary, you probably would never become an owner.

Make a Loan with an Option to Convert the Debt to Equity

A better way for a non-Arizona resident to acquire an ownership interest in an Arizona medical marijuana dispensary is by the non-Arizona resident loaning money to the nonprofit entity and having a written option to convert the loan to an equity (ownership) position after the non-Arizona resident establishes residency and each of the 17 other requirements of ownership currently in the DHS rules.  For example, if you and another person want to own a dispensary and become equal 50/50 owners, the other person could loan or contribute $125,000 to the nonprofit entity and you could loan it $125,000.  The other person would initially be the sole owner of the dispensary.  Your loan documents would provide that once you satisfy all 18 requirements to be an owner of an Arizona medical marijuana dispensary, you would have the option to notify the entity and its owner that you exercise your option to purchase a fifty percent ownership interest in the entity in exchange for releasing the entity from its obligation to repay the loan.  A condition to actually becoming an owner would be that DHS would have to approve you becoming an owner.

During the period of time before the lender becomes eligible to become an owner of the dispensary, the lender could be a paid employee of the nonprofit entity.

What Documents are Needed to Evidence a Debt to Equity Conversion Option

Here are the documents that must be prepared and signed by the appropriate parties do create and document a transaction where the nonprofit entity borrows money and gives the lender an option to convert the debt to equity:

  1. Loan Agreement:  This document sets forth all of the terms and conditions of the loan and the rights and obligations of the parties with respect to the option to convert the debt to equity.  For example, it would state the conditions that must be satisfied before the borrower can exercise the option such as establish residency and each of the 17 other DHS requirements for ownership, state when the option would expire, require the borrower to become a signer on the entity’s governing document [Operating Agreement for an LLC and stockholders agreement for a corporation] and on a buy-sell agreement and state the conversion ratio for converting one dollar of debt into a specified percentage of ownership of the entity.
  2. Promissory Note:  The Note evidences the loan terms and repayment obligation of the nonprofit entity.  It could be interest only for a period of time.  If principal payments are made, the lender would receive a smaller ownership interest in the entity on converting the debt to equity.
  3. Security Agreement:  If the loan will be secured by any personal property of the entity, the lien is evidenced by a Security Agreement signed by borrower and lender.
  4. UCC-1 Financing Statement:  If the borrower obtains a lien on the entity’s personal property, the lender must file a UCC-1 Financing Statement with the Arizona Secretary of State
  5. Deed of Trust on Real Property:  If the nonprofit entity owns any real property, the loan could be secured by a lien on the real property.
  6. Lender’s Title Insurance:  If the loan is secured by a lien on the entity’s real property, the lender should obtain a policy of lender’s title insurance.
  7. Personal Guaranty:  The lender should require the other owners of the nonprofit entity to guaranty the Loan Agreement.
  8. Resolutions of an Action by Unanimous Consent:  The governing body of the entity (board of directors of a corporation or members of an LLC) must hold a duly called and noticed meeting and adopt a resolution authorizing the entity to enter into the Loan Agreement, the Promissory Note and any other documents and designating the person who has the authority to sign the documents on behalf of the entity.  In lieu of holding a meeting, the governing body can sign an Action by Unanimous Consent that adopts all of the necessary resolutions, but all members of the governing body must sign the Action by Unanimous Consent or it will not be valid and the governing body must then hold a duly called and noticed meeting.
  9. Employment Agreement:  Needed if the lender will work for the nonprofit entity and be paid compensation before becoming an owner of the entity.
  10. NonDisclosure & Confidentiality Agreement:  The parties should sign this document to prevent either party from disclosing anything about the loan and to keep information confidential.
By |2014-01-05T09:33:44-07:00January 25th, 2011|Legal Issues, Questions People Ask|Comments Off on How Can a Non-Arizona Resident Who Wants to Own an Interest in an Arizona Medical Marijuana Dispensary Participate Before Becoming a Resident?

Should I Loan Seed Money to My Medical Marijuana Dispensary or Should I Give it to the Entity as a Capital Contribution?

Question:  I estimate that my Arizona medical marijuana dispensary will need $250,000 to open its retail store.  Should I loan the money to the nonprofit entity or should I pay it to the entity as a capital contribution?

Answer:  You should discuss this question with your accountant.  There are significant differences in the two primary methods (debt vs. equity) of inserting money into a business.  Here are some pros and cons associated with each method.

Debt:  You could loan the entity $250,000.  The loan should be evidenced by a Promissory Note signed by an authorized agent of the entity.  The governing body of the entity (members of an LLC or directors of a corporation) should hold a meeting (or sign an action by unanimous consent) and vote to approve the terms and conditions of the loan and designate the person who has the authority to sign the Promissory Note on behalf of the entity.  The loan should be commercially reasonable as to the interest rate, payment terms and maturity date.  If I were representing the lender, I would recommend that the Promissory Note be secured by a Security Agreement that encumbers all of the assets of the borrower.  If I were representing the borrower, I would suggest the loan be unsecured.

There are several advantages for the lender / owner who capitalizes the entity using a loan.  First and foremost, the entity becomes indebted to repay the loan according to its terms.  A loan creates a greater likelihood of being repaid before a capital contribution because the law of Arizona prohibits an Arizona entity from paying its owners and not paying creditors.  A loan may also be a better way to capitalize a medical marijuana entity because presumably Arizona’s medical marijuana laws and the Arizona Department of Health Services rules do not consider the entity’s repayment of a loan to be inconsistent with the require of the law and rules that the entity be operated on a nonprofit basis.

One problem with debt vs. equity is that although the entity has the funds, the infusion of capital does nothing for its balance sheet.  The assets of the entity increase by $250,000, but so does the entity’s debt, which means the loan does not increase the net worth of the entity.

If an owner does make a loan to the entity, it is critically important the the loan be properly documented with a good Promissory Note, Security Agreement and a UCC-1 Financing Statement filed with the Arizona Secretary of State (if the loan will be secured by a lien on personal property), and resolutions or an action by unanimous consent of the entity’s governing body.  If your entity needs to document a loan, call KEYTLaw business and contracts attorney Jeana Morrissey at 602-906-4953, ext. 4.

Equity:  Instead of loaning $250,000 to the entity, you could pay the money to the entity as a capital contribution.  Capital contributions have a lower priority the debt on the repayment totem pole.  The last people to be paid and recover their investment when a business goes bad are the owners.  Some organizational documents such as an Operating Agreement may provide that the owner does not have the right to demand that capital contributions be repaid.  Usually capital contributions do not accrue interest although it is possible to accrue interest if company documents provide for the accrual.

Because Arizona medical marijuana dispensaries must be operated on a nonprofit basis, it may also be more difficult to repay a capital contribution than a loan.  Currently the DHS rules do not give us any guidance as to whether an entity may freely repay owners their capital contributions so we do not know if a capital contribution in year 1 followed by a total repayment in the same year would be considered an improper use of entity profits contrary to the nonprofit character of the entity required by Arizona law.

An owner could also fund the entity with debt and equity.  In the above example, the owner could loan $125,000 to the entity and also make a capital contribution of $125,000.

By |2015-04-06T18:49:25-07:00January 24th, 2011|Legal Issues, Questions People Ask|Comments Off on Should I Loan Seed Money to My Medical Marijuana Dispensary or Should I Give it to the Entity as a Capital Contribution?

Arizona’s Medical Marijuana Law

Phoenix Magazine:  “A dazed new world?  Could the new medical marijuana act and its ‘cannabusinesses’ create a sixth ‘c’ for Arizona, or will it devolve into California’s reefer madness?”

By |2015-04-06T18:49:25-07:00January 24th, 2011|Stories & Articles|Comments Off on Arizona’s Medical Marijuana Law

Pot Meets Pop: Entrepreneur Plans to Market Line of Smartly Branded Medical-marijuana Soft Drinks

Santa Cruz Sentinel:  “How strange is the emerging world of medical-marijuana entrepreneurship?  Consider Clay Butler, who may soon be marketing a food product that he’s never tasted, and that he would never buy. The product is called Canna Cola, and it’s a soft drink that contains THC, the psychoactive ingredient in marijuana, aimed at medical marijuana dispensaries.”

By |2019-06-14T08:24:51-07:00January 24th, 2011|Stories & Articles|Comments Off on Pot Meets Pop: Entrepreneur Plans to Market Line of Smartly Branded Medical-marijuana Soft Drinks

Alan Sobol Questions Propriety of Phoenix Planning & Zoning

On January 23, 2011, I received an email from Alan Sobol and the Consiglieri Group that raises some interesting questions about alleged conduct by the City of Phoenix with respect to “pre-registration of dispensary” locations.  The following is the text of Alan’s message:

“Nepotism at Phoenix City Hall?

January 17 2011, without any notice, twelve people lined up at Phoenix City Hall to reserve their Dispensary Locations. Without any public notice the City of Phoenix rolled out their “Pre-Registration Program”,. According to the City officials, the program was intended to allow individuals to reserve a site for medical marijuana dispensary, cultivation or infusion facilities within the City of Phoenix. The problem, zoning officials had no authority to offer such pre-registration services. The Phoenix City Council adopted Ordinance G5573( the Marijuana zoning ordinance) on December 15, 2010. Nowhere contained therein was there a provision for such pre-registration services. The city violated its own public information rules.

Perhaps the more important question is who are these twelve people that showed up to register their marijuana facility locations, and how did they find out about this program? Hmmm!

But don’t worry, we are conducting an extensive investigation into this matter and will take appropriate action should we find evidence of wrongdoing.

We urge those of you who are considering locating your facility in Phoenix to immediately visit the Phoenix website and download this pre-registration form. (Phoenix.gov/planning). We would also suggest that you keep apprised of any such pre-registration services that might pop-up in other cities or towns. We will shortly be posting a link on our website to all Arizona City and Town websites. As always if you have any questions feel free to contact us.”

By |2015-04-06T18:49:22-07:00January 24th, 2011|Stories & Articles, Zoning|Comments Off on Alan Sobol Questions Propriety of Phoenix Planning & Zoning

New Record: 2,750 Visitors During the Week Ending 1/23/11

January 23, 2011, was the end of the fifth week since I started this website.  The number of visitors continues to grow each week.  For the week ending at midnight on January 23, 2011, this site had 2,750 visitors.  Thanks to all who visit.  If you have any suggestions for topics for articles, please send me a message.

By |2011-01-24T01:05:02-07:00January 24th, 2011|Miscellaneous|Comments Off on New Record: 2,750 Visitors During the Week Ending 1/23/11

Is it Legal for a Promoter to Ask Me to Invest $25,000 in a Syndicate that Will Seek to Own an Arizona Medical Marijuana Dispensary

Question:  An Arizona business has a website on which it is offering to put together a group of people to own minority interests in an entity that will seek to obtain a license to operate a medical marijuana dispensary in Arizona.  In exchange for paying $25,000 I would become a part owner with several other investors in the entity that will seek the license.  Is this legal?

Answer:  Maybe, but be cautious.  It appears that the people who are seeking the investors are soliciting investors to purchase a security.  Federal and state securities law regulate the offer and sale of securities.  The general rule is that no person or entity can offer to sell or actually sell a security unless the securities are registered with the United States Securities and Exchange Commission or offered and sold as a private offering under one of the SEC’s rules that provide for exceptions to the general rule.

In the famous United States Supreme Court case of Securities & Exchange Commission v. W. J. Howey Co. the Court ruled that the sale of real estate coupled with a mandatory leaseback of the land was a type of security called an “investment contract.”  The Court said that”

an investment contract for purposes of the Securities Act means a contract, transaction or scheme whereby a person invests his money in a common enterprise and is led to expect profits solely from the efforts of the promoter or a third party.”

If Sure Thing Investments, Inc., solicits me to join nine other investors who will each contribute $25,000 to World Wide Widgets, LLC, and my only involvement with the company is as a silent investor, I have purchased a security, i.e., the 10% membership interest in the LLC.  Sure Thing Investments, Inc., and the people who put the deal together must comply with applicable federal and state securities laws or they will be liable to me  and the other investors for any loss I suffer plus be subject to sanctions by the SEC and each state where an investor resides.  Complying with securities law involves many things, including  a requirement that the promoter deliver to investors before purchase a written prospectus or private placement memorandum that contains all material facts concerning the investment and that does not fail to disclose a material fact.

Given that the medical marijuana industry is brand new in Arizona and that its core busi9ness involves violating federal law, it is especially important that promoters and prospective issuers of securities involving an Arizona medical marijuana dispensary provide all prospective investors with a detailed disclosure document that lists all of the many risks arising from the unusual type of business.

Note:  Federal law provides that no person or entity can be compensate or receive property of value for finding an investor who purchases a security unless the person or entity is licensed as a securities broker or licensed as a securities sales agent working for a licensed securities broker.  For example, if Joe solicits investors on his website to invest $25,000 to become one of ten people who form an Arizona limited liability company that seeks to obtain a license to operate an Arizona medical marijuana dispensary and the LLC pays Joe $500 for each investor he brings to the deal, Joe must be a licensed securities broker or a licensed securities salesman working for a licensed securities broker.

Query:  What if Joe finds the investors for the would be dispensary LLC, but the LLC does not pay Joe any money or property for finding investors.  Instead, the LLC hires Joe  for big bucks to assist the LLC in obtaining a dispensary license.  Must Joe be a broker or a salesman working for a broker?  I don’t know, but it is a good question to ask a securities law lawyer or the Securities Division of the Arizona Corporation Commission.  You could argue that Joe must be licensed because the only reason the LLC paid Joe the money was because of Joe’s efforts that caused the investors to form the LLC for the purpose of hiring Joe.  My advise to Joe is to consult with an experienced securities law lawyer and if necessary, get licensed.

Warning:  Any person or business that solicits investors over the internet is by definition involved in a public offering that must be registered with the Securities and Exchange Commission.  As an Arizona business lawyer I have had people come to me from time to time because they placed an ad in a newspaper soliciting investors and received a cease and desist letter from the Securities Division of the Arizona Corporation Commission.  If you know of a website that is making a public offer to sell a security that has not been registered with the SEC or that is exempt from registration, contact the SEC.  If you have any inquiries or complaints regarding salesmen, investment advisers or securities involving offers or sales of securities to an Arizona resident, call the Securities Division of the Arizona Corporation Commission at  (602) 542-0662.

See “Arizona Corporation Commission Takes Action Against Sellers of Unregistered Real Estate Investments,”  “But is it a security?” and “Federal Securities Laws Basics.

By |2017-02-12T07:38:36-07:00January 22nd, 2011|Legal Issues, Questions People Ask|Comments Off on Is it Legal for a Promoter to Ask Me to Invest $25,000 in a Syndicate that Will Seek to Own an Arizona Medical Marijuana Dispensary

Chandler Working on Tough Medical-marijuana Zoning

Arizona Republic:  “Chandler’s regulations for medical-marijuana dispensaries will likely be more restrictive than those in other Valley cities, forcing greater distances from schools, churches, day care centers and public parks and requiring additional permits for dispensaries that also grow marijuana. . . . Under the proposed Chandler law, dispensaries must be at least 5,280 feet from another medical-marijuana facility”

By |2012-08-18T09:29:07-07:00January 22nd, 2011|Zoning|Comments Off on Chandler Working on Tough Medical-marijuana Zoning

Thanks for Coming – 569 Visitors Yesterday is a New Record

Yesterday, January 20, 2011, this website had a new record number of daily visitors – 569.  I started my Arizona medical marijuana law website on December 23, 2010, because I want to help people learn about legal issues affecting Arizona’s new industry.  The number of viewers has climbed steadily since day one.  Each of the last four days set a new daily record number of visitors.  This site has had 6,836 visitors in the first 29 days its been online.

My website at www.keytlaw.com has had over 6,000,000 visitors since January 1, 2006, because it contains tons of useful information about Arizona and federal law.  I currently have two other law websites.  They are IRA LLC Law and the KEYTLaw Law Blog.  I just started a new website called U.S. Real Estate Law, but it is not live yet.  The purpose of the new site is to inform non-U.S. citizens about legal issues that arise when they want to purchase investment real estate in the United States.

By |2011-01-21T07:51:44-07:00January 21st, 2011|Miscellaneous|Comments Off on Thanks for Coming – 569 Visitors Yesterday is a New Record

Chandler Medical-marijuana Zoning Recommended by Commission

Arizona Republic:  “Chandler Planning and Zoning Commissioners unanimously recommended regulations for medical marijuana cultivation and dispensaries Wednesday night that require separate permits for selling and cultivating, allow 9 a.m. to 9 p.m. hours of operation and restrict locations.”

By |2012-08-18T09:29:22-07:00January 20th, 2011|Zoning|Comments Off on Chandler Medical-marijuana Zoning Recommended by Commission

Alan Sobol & Andrew Meyer Speak at the Same NORML Event

I got an email message from The Consiglieri Group on January 16, 2011, that contained the following from Alan Sobol about his close encounter of the third kind with Andrew Meyer at a NORML meeting in Tucson where both men had been invited to speak.  I’m sure Alan was hoping to start the debate with Andrew that Alan asked for recently, but alas, it didn’t happen.  Here’s what Alan wrote:

As you may recall I challenged MPP Manager , Andrew Meyer to a debate last week.  So far no response.

However, I did have the opportunity to bump into Mr. Meyers last Saturday at the Tucson Norml meeting.  Meyer’s did not know that I was asked to speak.  According to the Norml president Jon,   in order to give balance to the meeting both Meyers and me were invited to speak.  Mr. Meyer was obviously shaken to  learn of the dual speaking event. During Meyer’s presentation he admitted that he was working with the Health Department  through “third party agencies” to develop the rules. He repeately  referred to the  rule making progress as, “WE ARE” working on the rules”.  But the most shocking revelation was Meyer’s admission that he now believed that my original idea of a “two step” application process was the appropriate way to administer the approval process.

Immediately after his presentation Meyer rudely and hurrily  exited the building apparently  so as not to be confronted with any attendee questions regarding my presentation.
Meyer and I had no direct communication except  for the finger I received from his lady friend Ms. Tea  as they ran from the building.

I believe that on January 31, 2011 when the AZDHS releases their revised  proposed rules  we will see a more reasonable application process. I further believe that as a direct result of the thousands of comments received from all of you, the AZDHS will be forced to moderate their rules.  want to encourage all of you to continue with your business plans, whatever they may be. Don’t loose the opportunity to become involved in this new industry, simply because you do not have enough time to get it finished.  Keep moving forward prudently.

Thanks for all your support, and keep fighting,

Allan Sobol
Marijuana Marketing strategies, LLC

By |2011-01-19T20:52:39-07:00January 19th, 2011|Stories & Articles|Comments Off on Alan Sobol & Andrew Meyer Speak at the Same NORML Event

Why Every Arizona Medical Marijuana Dispensary Must Hire a Primary & an Alternate Medical Director

The rules of the Arizona Department of Health Services require that every Arizona medical marijuana dispensary have a medical director.  See “What is a Medical Director & Why Does Every Arizona Medical Marijuana Dispensary Need One?”  If an operating dispensary were to suddenly lose its medical director, the dispensary would be in jeopardy of losing its Dispensary Registration Certificate, i.e., its license to grow and sell medical marijuana.

A dispensary could lose its medical director if the doctor were to:

  • die
  • become incapacitated or incompetent
  • lose his or her license to practice medicine
  • refuse to provide services even though it might be a breach of contract
  • suffer health problems
  • or experience any of an infinite number of events that result in no further services.

I could be wrong, but I’m pretty sure that no dispensary owner would want to risk losing the Dispensary Registration Certificate because of the loss of its medical director.  Because the risk of the  medical director could stop providing services at any time and cause the dispensary to lose its license and because the financial consequences so great, every dispensary should enter into a written contract with at least one other doctor to be an alternate medical director who automatically becomes the primary medical director if for any reason the primary medical director ceases to be the medical director.

By |2012-08-18T09:21:18-07:00January 19th, 2011|Legal Issues, Medical Directors|Comments Off on Why Every Arizona Medical Marijuana Dispensary Must Hire a Primary & an Alternate Medical Director