About On the Net

The author of this article is Richard Keyt, an Arizona business law attorney who is the creator of this Arizona medical marijuana law website. Connect with Richard at 480-664-7478 or on Google+

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.  [email protected]  If you have any questions or comments please contact me at [email protected]

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

Arizona Association of Dispensary Professionals Files Bar Complaint Against Rose Law Group

Apparently the Arizona Association of Dispensary Professionals filed a complaint with the Arizona State Bar that contains allegations about the Rose Law Group and its involvement in the medical marijuana industry.

By |2015-04-06T18:49:27-07:00January 31st, 2011|Stories & Articles|Comments Off on Arizona Association of Dispensary Professionals Files Bar Complaint Against Rose Law Group

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

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

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

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

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

Medical Marijuana Backers Air Views at Tempe Council Session

Arizona Republic:  “”A crowd of medical marijuana supporters attended a Tempe City Council meeting to demand that council members respect the ‘will of the voters’ who passed Proposition 203 in November. . . . Many of the medical marijuana advocates took issue with the proposed Tempe ordinance requiring dispensaries be located only in industrial areas and operate only in the daytime.”

By |2012-08-18T10:16:53-07:00January 18th, 2011|Stories & Articles, Zoning|Comments Off on Medical Marijuana Backers Air Views at Tempe Council Session

Text of the Public Comments to the 1st Draft of the Rules

On December 17, 2010, the Arizona Department of Health Services posted a draft of the medical marijuana rules for public comment.  Read the following comments received by ADHS  via its online survey from December 17, 2010, through January 7, 2011:

The Department also received the additional comments below:

By |2011-01-18T19:12:41-07:00January 15th, 2011|DHS Rules|Comments Off on Text of the Public Comments to the 1st Draft of the Rules

Chandler Planners Mull Marijuana Restrictions

Arizona Republic:  “Proposals for [medical marijuana dispensary] restrictions in Chandler, including those below, go before the city’s Planning and Zoning Commission on Wednesday for an advisory vote before it goes to the City Council in February. The 7 p.m. commission meeting is in City Council Chambers, 88 E. Chicago St.”

By |2012-08-18T09:29:36-07:00January 15th, 2011|Zoning|Comments Off on Chandler Planners Mull Marijuana Restrictions

Gilbert Sets Rules for Medical Marijuana Locations, Hours

Arizona Republic:  “As area entrepreneurs prepare to capitalize on a voter-approved initiative legalizing medical marijuana, the Gilbert Town Council approved regulations on where, when and how the pot-based businesses can operate.  Dispensaries and cultivation sites will only be allowed within industrial zoning districts in northwest Gilbert near Morrison Ranch and near Gilbert Road and the Santan Freeway.”

By |2012-08-18T09:34:53-07:00January 15th, 2011|Stories & Articles, Zoning|Comments Off on Gilbert Sets Rules for Medical Marijuana Locations, Hours

Glendale Unveils Medical-marijuana Proposals

Arizona Republic:  “Residents armed with questions attended a community meeting Thursday to hear Glendale’s proposed zoning restrictions on marijuana-related facilities.  City planners propose to allow dispensaries in general-office, general-commercial and heavy-commercial zones and the cultivation in light- and heavy-industrial zones.”

By |2012-08-18T09:37:41-07:00January 11th, 2011|Stories & Articles, Zoning|Comments Off on Glendale Unveils Medical-marijuana Proposals

Medical Marijuana Raid in San Luis Obispo County Raises Questions

San Luis Obispo Tribune: “on Dec. 27, 45 to 50 officers started serving the search warrants over three days at seven locations. Fifteen people were arrested on various allegations of possessing and selling marijuana. . . . Law enforcement officials say the arrestees were selling and transporting marijuana illegally throughout San Luis Obispo, Santa Barbara and Monterey counties, in violation of the state’s Compassionate Use Act and Medical Marijuana Program.   [The defendants] operated collectives. . . . groups that form to cultivate marijuana for medical purposes for patient and caregiver members. They should only provide a means for facilitating or coordinating transactions between members — and should not purchase marijuana from, or sell to, nonmembers.  They also cannot make a profit.”

By |2017-02-11T17:26:06-07:00January 9th, 2011|California News, Marijuana Crimes|Comments Off on Medical Marijuana Raid in San Luis Obispo County Raises Questions

Arizona Medical Marijuana Association is Alive!

Today the yet to be formed Arizona Medical Marijuana Association (AzMMA) had its attorney send a 17 page letter to the Arizona Department of Health Services with its suggested changes to the December 17, 2010, proposed rules.  For the most part, I think its suggested are good and should be adopted by DHS.  The only change I disagree with is AzMMA’s suggestion to increase the Arizona residency requirement to three years.  Proposition 203 does not contain a requirement that owners of medical marijuana dispensaries be residents of Arizona.  Query:  Could that requirement be an unconstitutional violation of the equal protection clause of the U.S. Constitution?

By |2011-01-18T19:13:56-07:00January 7th, 2011|Stories & Articles|Comments Off on Arizona Medical Marijuana Association is Alive!

Department of Health Services: Medical Marijuana Public Comments

The following was posted on the Arizona Department of Health Services’ blog today:

So far, we’ve received well over 1,300 comments on the Informal Draft Rules that we posted December 17.  Our first comment period ends today.  We’ll be reviewing the comments and revising our initial draft over the next couple of weeks.  We’ll be releasing new draft rules for public comment on Monday, January 31, kicking off our next comment period (which will go through February 18).  After that, we’ll craft the final Rules and publish the finished package on March 28.

The following issues are generating the most comments:

  • The definition/requirements for patient-physician relationship;
  • Adding additional medical conditions including mental illness, PTSD, fibromyalgia, depression, etc.;
  • The fee structure (especially for patients with limited income);
  • The 25 mile limit for patient/caregiver cultivation (which is actually in the Initiative, not the rules);
  • The requirement that dispensaries cultivate 70% of their own product;
  • The processes for approving dispensary registration certificate;
  • The requirement that dispensaries have a medical director;
  • The qualifications for medical directors (e.g. allow other medical professionals including a pharmacist, naturopathic physician, homeopathic physician, family nurse practitioner, physician assistant, or registered nurse to be the medical director);
  • The 2 year residency requirement for dispensary applicants; and
  • The requirement that cultivation facilities be licensed in association with a dispensary (which is actually in the Initiative).

Overall, the comments so far have been constructive and many have been positive and support much of the overall language in informal draft rules.  All the comments on the informal draft rule are part of the public record and will be available for review on our hub 203 website (with personal identifiers removed) by next Wednesday.

By |2011-01-18T19:14:36-07:00January 7th, 2011|DHS Rules|Comments Off on Department of Health Services: Medical Marijuana Public Comments

Medical Marijuana Bill Fails In Illinois State House

CBS Channel 2 Chicago:  “A push to legalize medicinal marijuana failed in the state House [of Illinois] on Thursday.  As WBBM Newsradio 780’s Brian Seay reports, the bill fell four votes short of the 60 it required for passage. The final vote was 60-56.”

By |2011-01-07T07:08:53-07:00January 7th, 2011|Stories & Articles|Comments Off on Medical Marijuana Bill Fails In Illinois State House

Arizona Pharmacy Alliance Comments on Medical Marijuana Rules

Mindy D. Smith, the Chief Executive Officer of the Arizona Pharmacy Alliance sent a letter dated January 7, 2011, to Will Humble, Director of the Arizona Department of Health Services, in which she states the AzPA’s suggested changes to the December 17, 2010, first draft of Arizona’s medical marijuana rules.

By |2011-01-18T19:15:03-07:00January 7th, 2011|DHS Rules|Comments Off on Arizona Pharmacy Alliance Comments on Medical Marijuana Rules

Mesa Tightening Medical Marijuana Rules

Arizona Republic:  “Medical marijuana shops in Mesa will be confined to industrial areas under an ordinance heading for City Council approval in early February.  The council’s third study-session discussion of the state’s new medical marijuana law resulted Thursday in a further tightening of the areas where the council prefers shops to be located.”

By |2012-08-18T09:41:57-07:00January 7th, 2011|Stories & Articles, Zoning|Comments Off on Mesa Tightening Medical Marijuana Rules
Go to Top