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Overview of the cannabis industry in the United States

The following is a brief overview of the cannabis industry in the United States. It's meant to give a quick and concise review of where cannabis use, regulation, testing, and research have been and where they are now. Many of the topics touched upon here will be expanded upon later in this guide.

Brief history of cannabis in the U.S.

Cannabis is a rapid-growing, flowering plant that has been used for centuries for industrial, medicinal, and recreational purposes. The plant includes three species or subspecies: indica, ruderalis, and sativa.[1] Both industrial hemp and recreational marijuana are derived from cannabis plants, but with important differences in biochemical composition. Hemp — which has historically been used to create clothing, food and feed, paper, textiles, and other industrial items — tends to have lower levels of the psychoactive component tetrahydrocannabinol (THC) and higher levels of the non-psychoactive component cannabidiol (CBD).[2][3] Some cannabis strains have intentionally been bred to produce low levels of THC, while others have been bred with the intent to maximize the psychoactive component.

Cannabis cultivation began in England's Jamestown colony of America in earnest around 1611, via formal orders. Several years later those orders turned into a royal decree, enacted by the Virginia Company, asking colonists to grow 100 hemp plants for export to England.[3] Colonial American continued its growth, use, and exportation of hemp, even beyond the foundation of the United States. During that time, growers undoubtedly were using the female plant (which flowers and has higher levels of THC) to treat aches and pains as well as enjoy it recreationally. By the time of the U.S. Civil War arrived in the 1860s, however,the growth and use of industrial hemp declined as increased cotton and wood use took away much of the profitability of hemp.[3] Around the same time, local governments began recognizing tonics, tinctures, and extracts from cannabis plants as potentially dangerous substances, labeling them as hypnotics, narcotics, or even poisons.[4] In the early twentieth century, U.S. labeling and prescription laws — such as the the Pure Food and Drug Act of 1906 at the federal level as well as various state laws — saw further restrictions put on cannabis, effectively culminating in the Marihuana Tax Act of 1937 and the Federal Food, Drug, and Cosmetic Act of 1938. With the passage of those acts, hemp and marijuana essentially became illegal, controlled substances.[5][6][7]

State efforts to decriminalize marijuana were somewhat successful in the early 1970s, though progress towards that goal slowed again with the Reagan Administration's war on drugs.[8] Progress picked up steam again in the late 1990s into the 2000s, particularly in states such as California, Massachusetts, Connecticut, Washington, and Colorado.

As of January 2017, twenty-eight U.S. states have approved some sort of decriminalization or legalization of medicinal and/or recreational marijuana.[9] Industrial hemp has also been addressed in some regard, with 16 states having legalized commercialized industrial help production, with federal removal of hemp containing no more than 0.3 percent THC from the controlled substances list.[10] However, cannabis containing more than 0.3 percent THC remains remains a Schedule I controlled substance, as determined by the U.S. Food and Drug Administration.[11] This federal classification continues to clash with changing state laws and regulations at an increasing pace, creating both opportunities and difficulties for involved citizens at all points along the industrial, economic, and social chain.

Testing and research

One area that continues to expand — while taking advantage of new scientific research and techniques — is the laboratory sphere, particularly in research, regulation, and standardization activities. While the research, analysis, and processing of cannabis has been ongoing for centuries[3], it wasn't until 1896 that Wood et al. conducted one of the first documented chemical experiments to determine the constituents of cannabis. Several years later, the researchers were able to correctly identify the extracted and isolated cannabinol from the exuded resin of Indian hemp as C21H26O2.[12] As of mid-2015, 104 of the more than 750 constituents of Cannabis sativa have been identified as cannabinoids[13], "a class of diverse chemical compounds that act on cannabinoid receptors in cells that modulate neurotransmitter release in the brain."[14]

Yet in the United States, when it comes to 1. enacting the broad level of testing required to ensure public safety — whether it be medical, recreational, or industrial use of cannabis — and 2. researching and better understanding the pharmacokinetics and pharmacodynamics (medical use and benefit) of cannabinoids in the human population, many have argued that laboratory testing of cannabis is still in its infancy[15][16][17][18][19][20] and evidence-based research of marijuana continues to be slow and bogged down in regulation.[21][22][23][24][25] In regards to the first issue, as some form of legalization continues to sweep across states, regulators, users, and industry are recognizing the need for improved standardization of the production and testing of medical and recreational marijuana; the current state of improper labeling and potentially harmful contaminants[15][16][17][20] will only serve to hinder the industry. To the second issue, some within the federal government seem to recognize the roadblocks to improved evidence-based research and are working to slowly improve how researchers can legally acquire and test marijuana in the U.S.[23][24][26] In the meantime, government entities such as the National Institutes of Health and non-profits such as jCanna push forward with scientific conferences, summits, and roundtables that bring scientists and interested parties together to share existing knowledge and testing techniques.[27][28]

Other concerns

The U.S. cannabis industry has a few additional concerns, again tightly linked to federal regulations (which are discussed extensively in the next section): banking and advertising. Issues related to both of these topics continue to limit how state-based grow-ops (grow operations), dispensaries, and testing laboratories are funded and operated.

Banking

Since the U.S. federal government still considers marijuana to be illegal, by extension banks and credit unions — which are regulated by a patchwork collection of federal (and state) laws — put themselves into potentially dangerous territory by accepting money from depositors engaging in federally illegal activities; the bank can be punished by federal institutions such as that Federal Deposit Insurance Corporation (FDIC).[29] In an attempt to ease concerns of industry and banks in states that had implements legalization efforts, the Treasury Department's Financial Crimes Enforcement Network (FinCEN) released a guidance document in February 2014 that "does not grant immunity from prosecution or civil penalties to banks that serve legal marijuana businesses" but rather "directs prosecutors and regulators to give priority to cases only where financial institutions have failed to adhere to the guidance."[30][31] However, the guidance has remained just that: guidance; it doesn't prevent federal law enforcement or regulating agencies from taking action. An August 2016 attempt to reclassify marijuana into a lower classification than Schedule I failed[11][24], keeping the FinCEN guidance in place as a recommendation for how federal authorities should enforce existing law.

According to an Associated Press report in April 2016, the guidance has had some sort of impact, with banks and credit unions willing to handle any money associated with marijuana increasing from 51 in March 2014 to 301 in March 2016.[32] However, this hasn't prevented those in states with newly minted medical and recreational marijuana legalization laws from being worried about how cannabis money will be handled, particularly with the new Trump administration taking the reigns of government. California, which in November 2016 legalized recreational use of marijuana beginning in 2018, has already petitioned that administration to clarify it's policy early on. "We have a year to develop a system that works in California and which addresses the many issues that exist as a result of the federal-state legal conflict," wrote California Treasurer John Chiang to Trump. "Uncertainty about the position of your administration creates even more of a challenge."[33]

Similar legalization changes in Massachusetts prompted its senator Elizabeth Warren, along with nine other senators, to write to FinCEN in early 2017 requesting even clearer, more friendly guidance for marijuana vendors.[34] Yet it remains to be seen if entities outside of grow-ops and dispensaries will see banking relief. In particular, testing laboratories continue to struggle with managing cash flow and acquiring bank lending for their operations[35][36][37], causing some to believe consolidation of such labs will occur before the industry can really even take off.[35][38]

Advertising

Advertising of marijuana products is another area of concern, though the regulations and laws regarding it are less clear. When it comes to television and radio broadcasting and its associated advertising, a federally-granted broadcasting license stands to be lost care of the Federal Communications Commission (FCC). The trouble is, it's not clear if the FCC would act against broadcasters; the FCC hasn't issued guidance in the same way FinCEN has. "I don’t think anybody knows, and that’s the problem," said California Broadcasters Association President Joe Berry in an August 2016 report published by the The Sacramento Bee. "Without a clear indication [from the FCC on marijuana advertising], the vast majority of broadcasters are going to stay away from this issue."[39] California, of course, made recreational marijuana legal, and its proposed law sought to address the issue of advertising, including "a provision restricting TV and radio ads so they are not targeted to minors," while also addressing the authority of the FCC to enforce regardless.[40]

Other forms of advertising also remain problematic. In late November 2015, the United States Postal Service (USPS) out of Portland, Oregon published its interpretation of federal law regarding "mailpieces containing advertisements about marijuana," regarding it illegal to distribute certain forms of marijuana advertisement, citing 21 U.S. Code § 843(c).[41] The U.S. Patent and Trademark Office (PTO) has, controversially, also gotten involved, stating that trademarking of a "brand controlled substances or related paraphernalia that are illegal to possess or sell" legally doesn't fit within a trademark's commercial viability because at the federal level marijuana is not legal for commerce.[42] (Legal experts such as Dariush Adli suggest "creative ways" of getting around this, from registering trademarks in multiple states to registering "non-cannabis merchandise in order to generate some federal protection for their mark."[43]) Even billboards are an issue, with state lawmakers proposing new regulations on marijuana advertising on them weeks after the state passed its recreational legalization laws.[44] And state laws, such as those found in Alaska, can create their own set of challenges in staying legal with marijuana advertising.[45]

Despite all this, at least one financial consultant believes marijuana marketing will become more prevalent: GreenWave Advisors' Matthew Karnes estimates spending will jump to $75 million by 2021.[46]

Regulatory scheme

Federal

October 19, 2009: The Ogden Memorandum

Deputy Attorney General David W. Ogden issued a memorandum "intended solely as a guide to the exercise of investigative and prosecutorial discretion" in regards to state-based laws allowing medical cannabis.[47] The guidance essentially told U.S. attorneys to not prosecute those entities complying fully with state cannabis laws. Researchers generally agree that this memo acted "as a catalyst for expansion of [state-sanctioned and gray market] cannabis supply in states with poorly defined regulations," though the degree to which it influenced such growth remains poorly documented and requires further investigation.[48] To be sure, it likely had some effect, as the number of licensed patients using medical marijuana in the state of Colorado increased from 4,800 in 2008 to 41,000 in 2009, and operating dispensaries jumped to more than 900 by mid-2010.[49]

June 29, 2011: The Cole Memorandum 1

Deputy Attorney General James M. Cole issued a memo as a follow-up to the Ogden Memo, muddying the waters in the process. While stating that the stance of efficiently using department resources as outlined in the Ogden Memo still stood, Cole also made it clear that large grow-ops that didn't qualify as "caregivers" had sprung up since.[50] The language of the memo essentially said "get off your butts and nail those suckers."[51] Cambron et al.[48] and Fairman[52] suggest this memo had some impact as evidenced by declines in cannabis patient registration from 2011–2013 in Colorado, Michigan, and Montana.

August 29, 2013: The Cole Memorandum 2

Deputy Attorney General James M. Cole issued a follow-up memo to his original two years later, following 1. on the heels of then President Obama reiterating publicly that the Department of Justice was to not focus in unnecessarily on states that have passed legalization laws and 2. Washington and Colorado legalizing recreational use of cannabis.[48] The second memorandum sought to reduce the emphasis on the size of the grow-op and increase emphasis on — by a case-by-case basis — "whether the operation is demonstrably in compliance with a strong and effective state regulatory system."[53] The memo also clarified specific cases where federal enforcement would be warranted, including distribution to minors, interstate transport, and preventing drugged driving (though it didn't state how). Generally speaking, states saw little federal intervention except in the case of state law being broken or requiring dispensaries to move further away from schools.[54][48] Despite the memo, some attorneys continued to see Cole Memorandum 2 as nothing more than unclear language that had no legal weight for anxious growers and distributors in states where cannabis was legalized.[51]

December 16, 2014 to current: Rohrabacher-Farr Amendment


State medical and recreational

Laboratory testing of cannabis

Tests and standards

Reports

Lab equipment used

Software

Testing labs and pricing info

Future of cannabis testing and market trends

Resources

Trade shows

Producers and vendors

Software vendors

LIMS

Seed-to-sale

LIMSpec

References

  1. ↑ "Genus: Cannabis L.". U.S. National Plant Germplasm System. U.S. Department of Agriculture. 1 January 2011. https://npgsweb.ars-grin.gov/gringlobal/taxonomygenus.aspx?id=2034. Retrieved 20 January 2017. 
  2. ↑ Swanson, T.E. (2015). "Controlled Substances Chaos: The Department of Justice's New Policy Position on Marijuana and What It Means for Industrial Hemp Farming in North Dakota" (PDF). North Dakota Law Review 90 (3): 599–622. https://law.und.edu/_files/docs/ndlr/pdf/issues/90/3/90ndlr599.pdf. 
  3. ↑ 3.0 3.1 3.2 3.3 Deitch, R. (2003). Hemp – American History Revisited. New York City: Algora Publishing. pp. 232. ISBN 9780875862262. 
  4. ↑ U.S. Senate (15 February 1860). "Senate". The New York Times. http://www.nytimes.com/1860/02/16/news/senate-88150825.html. Retrieved 20 January 2017. 
  5. ↑ Walton, R.F. (1938). Marijuana, America’s New Drug Problem. Philadelphia: B. Lippincott. p. 37. 
  6. ↑ Woodward, W.C.; House of Representatives, Committee on Ways and Means (4 May 1937). "Taxation of Marihuana". Schaffer Library of Drug Policy. http://www.druglibrary.org/schaffer/hemp/taxact/woodward.htm. Retrieved 20 January 2017. 
  7. ↑ Cavers, D.F. (1939). "The Food, Drug, and Cosmetic Act of 1938: Its Legislative History and its Substantive Provisions". Law and Contemporary Problems 6: 2–42. http://scholarship.law.duke.edu/lcp/vol6/iss1/2/. 
  8. ↑ Meier, K.J. (2016). The Politics of Sin: Drugs, Alcohol and Public Policy: Drugs, Alcohol and Public Policy. Taylor & Francis. p. 58. ISBN 9781315287270. https://books.google.com/books?id=J4wYDQAAQBAJ&pg=PT58. 
  9. ↑ Steinmetz, K. (8 November 2016). "These States Just Legalized Marijuana". Time. Time, Inc. http://time.com/4559278/marijuana-election-results-2016/. Retrieved 20 January 2017. 
  10. ↑ "State Industrial Hemp Statuses". National Conference of State Legislatures. 19 August 2016. http://www.ncsl.org/research/agriculture-and-rural-development/state-industrial-hemp-statutes.aspx. Retrieved 20 January 2017. 
  11. ↑ 11.0 11.1 Leger, D.L. (11 August 2016). "Marijuana to remain illegal under federal law, DEA says". USA. Today. Gannett Company. http://www.usatoday.com/story/news/2016/08/11/dea-marijuana-remains-illegal-under-federal-law/88550804/. Retrieved 20 January 2017. 
  12. ↑ Wood, T.B.; Newton Spivey, W.T.; Easterfield, T.H. (1899). "III.—Cannabinol. Part I". Journal of the Chemical Society, Transactions 75: 30–36. doi:10.1039/CT8997500020. 
  13. ↑ Radwan, M.M.; ElSohly, M.A.; El-Alfy, A.T. et al. (2015). "Isolation and pharmacological evaluation of minor cannabinoids from high-potency Cannabis sativa". Journal of Natural Products 78 (6): 1271-6. doi:10.1021/acs.jnatprod.5b00065. PMC PMC4880513. PMID 26000707. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4880513. 
  14. ↑ World Health Organization (2016). Hall, W.; Renström, M.; Poznyak, V.. ed. The health and social effects of nonmedical cannabis use. World Health Organization. pp. 95. ISBN 978921510240. http://www.who.int/substance_abuse/publications/cannabis/en/. 
  15. ↑ 15.0 15.1 Hazekamp, A.; Fischedick, J.T. (2012). "Cannabis - from cultivar to chemovar". Drug Testing and Analysis 4 (7–8): 660–7. doi:10.1002/dta.407. PMID 22362625. 
  16. ↑ 16.0 16.1 Bush, E. (18 February 2015). "World’s strongest weed? Potency testing challenged". The Seattle Times. The Seattle Times Company. http://www.seattletimes.com/seattle-news/worldrsquos-strongest-weed-potency-testing-challenged/. Retrieved 25 January 2017. 
  17. ↑ 17.0 17.1 Rutsch, P. (24 March 2015). "Quality-Testing Legal Marijuana: Strong But Not Always Clean". Shots. National Public Radio. http://www.npr.org/sections/health-shots/2015/03/24/395065699/quality-testing-legal-marijuana-strong-but-not-always-clean. Retrieved 25 January 2017. 
  18. ↑ Kuzdzal, S.; Lipps, W. (2015). "Unraveling the Cannabinome". The Analytical Scientist (0915). https://theanalyticalscientist.com/issues/0915/unraveling-the-cannabinome/. Retrieved 19 January 2017. 
  19. ↑ Crombie, N. (25 July 2016). "Marijuana labs prepping for regulation and oversight; no lab licenses issued yet". The Oregonian. Oregon Live LLC. http://www.oregonlive.com/marijuana/index.ssf/2016/07/marijuana_labs_prepping_for_st.html. Retrieved 25 January 2017. 
  20. ↑ 20.0 20.1 Kuzdzal, S.; Clifford, R.; Winkler, P.; Bankert, W. (December 2016). "A Closer Look at Cannabis Testing" (PDF). Shimadzu Corporation. Archived from the original on 19 January 2017. http://web.archive.org/web/20170119191646/http://event.lvl3.on24.com/event/13/38/14/4/rt/1/documents/resourceList1484589923854/emerging_cannabis_industry_whitepaper.pdf. Retrieved 19 January 2017. 
  21. ↑ Bajaj, V. (30 July 2014). "How the Federal Government Slows Marijuana Research". Taking Note: The New York Times. The New York Times Company. https://takingnote.blogs.nytimes.com/2014/07/30/how-the-federal-government-slows-marijuana-research/. Retrieved 25 January 2017. 
  22. ↑ Chesler, J.; Ard, A. (15 August 2015). "Government restrictions, lack of funding slow progress on medical marijuana research". News21: America's Weed Rush. Carnegie Corporation of New York; John S. and James L. Knight Foundation. http://weedrush.news21.com/government-restrictions-lack-of-funding-slow-progress-on-medical-marijuana-research/. Retrieved 25 January 2017. 
  23. ↑ 23.0 23.1 Weiss, S.R.B. (13 July 2016). "Testimony from Susan R.B. Weiss, Ph.D. on The State of the Science on the Therapeutic Potential of Marijuana and Cannabinoids before Judiciary Committee". ASL Testimony. U.S. Department of Health & Human Services. https://www.hhs.gov/about/agencies/asl/testimony/2016-09/the-state-of-the-science-on-the-therapeutic-potential-of-marijuana-and-cannabinoids/index.html. Retrieved 25 January 2017. 
  24. ↑ 24.0 24.1 24.2 Joseph, A. (10 August 2016). "DEA decision keeps major restrictions in place on marijuana research". STAT. Boston Globe Media. https://www.statnews.com/2016/08/10/marijuana-medical-research-dea/. Retrieved 25 January 2017. 
  25. ↑ Rudroff, T. (21 January 2017). "Marijuana Regulation Blocks Vital Multiple Sclerosis Research". Newsweek. IBT Media, Inc. http://www.newsweek.com/marijuana-regulation-blocks-vital-ms-research-544886. Retrieved 25 January 2017. 
  26. ↑ Romza-Kutz, D.; Roth V, F. (15 August 2016). "The silver lining in the DEA’s refusal to reclassify cannabis". Tracking Cannabis. Thompson Coburn LLP. http://www.thompsoncoburn.com/insights/blogs/tracking-cannabis/post/2016-08-15/the-silver-lining-in-the-dea-s-refusal-to-reclassify-cannabis. Retrieved 25 January 2017. 
  27. ↑ "The Marijuana and Cannabinoids: A Neuroscience Research Summit". National Institutes of Health. 23 March 2016. http://apps1.seiservices.com/nih/mj/2016/. Retrieved 25 January 2017. 
  28. ↑ "Cannabis Science Conference". jCanna, Inc. https://www.cannabisscienceconference.com/. Retrieved 25 January 2017. 
  29. ↑ Hill, J.A. (2015). "Banks, Marijuana, and Federalism". Case Western Reserve Federal Law Review 65 (3): 597–647. http://scholarlycommons.law.case.edu/caselrev/vol65/iss3/7. 
  30. ↑ Kovaleski, S.F. (14 February 2014). "U.S. Issues Marijuana Guidelines for Banks". The New York Times. The New York Times Corporation. https://www.nytimes.com/2014/02/15/us/us-issues-marijuana-guidelines-for-banks.html. Retrieved 25 January 2017. 
  31. ↑ Financial Crimes Enforcement Network (14 February 2014). "BSA Expectations Regarding Marijuana-Related Businesses". U.S. Department of the Treasury. https://www.fincen.gov/resources/statutes-regulations/guidance/bsa-expectations-regarding-marijuana-related-businesses. Retrieved 25 January 2017. 
  32. ↑ Hansen, K.; Johnson, G. (20 April 2016). "Banking woes easing for some legal pot businesses". Associated Press: The Big Story. Associated Press. http://bigstory.ap.org/article/804ae396daab4ba98f814b186f872ef6/banking-woes-easing-some-legal-pot-businesses. Retrieved 25 January 2017. 
  33. ↑ Blood, M.R. (2 December 2016). "California treasurer asks Trump for guidance on pot, banking". Associated Press: The Big Story. Associated Press. http://bigstory.ap.org/article/d54ea614db274238986a8e0d77dbb147/california-treasurer-asks-trump-guidance-pot-banking. Retrieved 25 January 2017. 
  34. ↑ LeBlanc, S. (2 January 2017). "US Sen. Warren seeks to pull pot shops out of banking limbo". Las Vegas Sun. Greenspun Media Group. https://lasvegassun.com/news/2017/jan/02/us-sen-warren-seeks-to-pull-pot-shops-out-of-banki/. Retrieved 25 January 2017. 
  35. ↑ 35.0 35.1 Lampach, D. (20 November 2013). "Q&A With CEO of Steep Hill Halent: US Cannabis Testing Market Could Hit $40M by 2016". Marijuana Business Daily. Anne Holland Ventures, Inc. https://mjbizdaily.com/qa-with-steep-hill-lab-ceo-david-lampach-cannabis-testing-market-could-hit-40m-in-2-years/. Retrieved 25 January 2017. 
  36. ↑ Martin, R.W. (May 2016). "Profitability in the Cannabis Laboratory Industry". Association of Commercial Cannabis Laboratories. Association of Commercial Cannabis Laboratories. http://www.cacannabislabs.com/. Retrieved 25 January 2017. 
  37. ↑ Tulsi, B.B. (3 October 2016). "A Bright Future for Cannabis Testing Services". Lab Manager. LabX Media Group. http://www.labmanager.com/research-specific-labs/2016/10/today-s-cannabis-research-market. Retrieved 25 January 2017. 
  38. ↑ "A Unique Investment Vehicle in Laboratory Testing" (PDF). DigiPath, Inc. October 2016. pp. 36. http://digipath.com/wp-content/uploads/2016/10/Digipath-Company-Report.pdf. Retrieved 25 January 2017. 
  39. ↑ White, J.B. (17 August 2016). "If California legalizes pot, will TV ads be far behind?". The Sacramento Bee. The McClatchy Company. http://www.sacbee.com/news/politics-government/capitol-alert/article96040082.html. Retrieved 25 January 2017. 
  40. ↑ McGreevy, P. (30 October 2016). "Q&A: Proposition 64 would legalize recreational use of marijuana though it's illegal under federal law. How will that work?". Los Angeles Times. tronc, Inc. http://www.latimes.com/politics/la-pol-sac-proposition-64-marijuana-legalization-qa-20161030-snap-20161029-story.html. Retrieved 25 January 2017. 
  41. ↑ Rein, L. (21 December 2015). "The pot business may be legal, but newspapers can’t run ads for it, the U.S. Postal Service says". The Washington Post. WP Company, LLC. https://www.washingtonpost.com/news/federal-eye/wp/2015/12/21/the-pot-business-may-be-legal-but-newspapers-cant-run-ads-for-it-the-u-s-postal-service-says/. Retrieved 25 January 2017. 
  42. ↑ Oxenford, D. (13 December 2016). "Accepting Advertising for Marijuana or Marijuana Paraphernalia: The Trademark Office Rules on a Related Issue that Provides More Reason For Caution". Broadcast Law Blog. http://www.broadcastlawblog.com/2016/12/articles/accepting-advertising-for-marijuana-or-marijuana-paraphernalia-the-trademark-office-rules-on-a-related-issue-that-provides-more-reason-for-caution/. Retrieved 25 January 2017. 
  43. ↑ Adli, D. (21 December 2016). "Obtaining Trademark Protection for Cannabis Businesses". ADLI Law Group. http://adlilaw.blogspot.com/2016/12/obtaining-trademark-protection-for_9.html. Retrieved 25 January 2017. 
  44. ↑ McGreevy, P. (21 December 2016). "Pot ads along highways? Lawmakers wrangle over legalization's consequences". Los Angeles Times. tronc, Inc. http://www.latimes.com/politics/la-pol-ca-pot-ads-snap-20161221-story.html. Retrieved 25 January 2017. 
  45. ↑ Andrews, L. (27 December 2016). "Gaps in Alaska marijuana ad rules cause worry". Alaska Dispatch News. Alaska Dispatch Publishing. https://www.adn.com/alaska-marijuana/2016/12/26/gaps-in-alaska-marijuana-advertising-rules-cause-worry/. Retrieved 25 January 2017. 
  46. ↑ Stilson, J. (3 January 2017). "Why Marijuana Marketing Will Be Bigger Than Ever This Year". Adweek. Adweek, LLC. http://www.adweek.com/news/advertising-branding/why-marijuana-marketing-will-be-bigger-ever-year-175246. Retrieved 25 January 2017. 
  47. ↑ Ogden, D.W. (19 October 2009). "Memorandum for Selected United State Attorneys on Investigations and Prosecutions in States Authorizing the Medical Use of Marijuana". Justice Blogs. Department of Justice. https://www.justice.gov/opa/blog/memorandum-selected-united-state-attorneys-investigations-and-prosecutions-states. Retrieved 26 January 2017. 
  48. ↑ 48.0 48.1 48.2 48.3 Cambron, C.; Guttmannova, K.; Fleming, C.B. (2017). "State and National Contexts in Evaluating Cannabis Laws: A Case Study of Washington State". Journal of Drug Issues 47 (1): 74–90. doi:10.1177/0022042616678607. 
  49. ↑ Rocky Mountain HIDTA (August 2013). "The Legalization of Marijuana in Colorado: The Impact" (PDF). http://www.rmhidta.org/html/final%20legalization%20of%20mj%20in%20colorado%20the%20impact.pdf. Retrieved 26 January 2017. 
  50. ↑ Cole, J.M. (29 June 2011). "Memorandum for United States Attorneys" (PDF). Department of Justice. https://www.justice.gov/sites/default/files/oip/legacy/2014/07/23/dag-guidance-2011-for-medical-marijuana-use.pdf. Retrieved 26 January 2017. 
  51. ↑ 51.0 51.1 Greenfield, S.H. (30 August 2013). "The Cole Memo 2.0: This Changes Everything". Simple Justice. https://blog.simplejustice.us/2013/08/30/the-cole-memo-2-0-this-changes-everything/. Retrieved 26 January 2017. 
  52. ↑ Fairman, B.J. (2016). "Trends in registered medical marijuana participation across 13 US states and District of Columbia". Drug and Alcohol Dependence 159: 72–9. doi:10.1016/j.drugalcdep.2015.11.015. PMID 26686277. 
  53. ↑ Cole, J.M. (29 August 2013). "Memorandum for All United States Attorneys" (PDF). Department of Justice. https://www.justice.gov/iso/opa/resources/3052013829132756857467.pdf. Retrieved 26 January 2017. 
  54. ↑ "Federal Marijuana Enforcement Policy". Marijuana Policy Project. 2016. https://www.mpp.org/federal/federal-enforcement-policy-on-state-marijuana-laws/. Retrieved 26 January 2017. 


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