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HomeMy WebLinkAboutAGENDA REPORT 2005 0720 CC REG ITEM 08CMOORPARK CITY COUNCIL AGENDA REPORT ITEM 9- G . CITY OF MOORPARK, CALIFORNIA City Council Meeting 29 _ _ Q'90- 3i BY: TO: Honorable City Council FROM: Barry K. Hogan, Community Development Director By: Laura Stringer, Administrative Services a age. DATE: July 8, 2005 (CC Meeting of 07/20/05) SUBJECT: Consider an Interim Urgency Ordinance Extending a Temporary Moratorium on the Establishment and Operation of Medical Marijuana Dispensaries BACKGROUND /DISCUSSION On July 6, 2005, the Moorpark City Council enacted an interim urgency ordinance (the "45 Day Ordinance ") to impose a moratorium on issuance of any land use entitlements for medical marijuana dispensaries, and directed staff to schedule and notice a public hearing for July 20, 2005, to consider extending the Interim Ordinance for an additional twenty -two (22) months and fifteen (15) days, or until June 4, 2007. On July 7, 2005, the City issued a report describing the measures taken to alleviate the condition which led to the adoption of the interim ordinance (the "Ten (10) Day Report" (Attachment 2) . The report (with exhibits) was made available at the public counter at City Hall, on the City Website, and copies are available at the July 20, 2005 City Council meeting. If adopted, the Ordinance (Attachment 3) would extend the temporary moratorium on the establishment and operation of medical marijuana dispensaries in the City of Moorpark for an additional twenty -two (22) months and fifteen (15) days, or until June 4, 2007, allowing staff to conduct the necessary reviews and research identified in the July 6, 2005 City Council Agenda Report. 000031 :r1onorable City Council July 20, 2005 Page 2 STAFF RECOMMENDATION (ROLL CALL VOTE 4 /5TH AFFIRMATION) 1. Open the public hearing, take public testimony and close the public hearing. 2. Adopt Ordinance No. AT'- 'ACHMENTS : 1. July 06, 2005 City Council Agenda Report 2. Report on the Measures Taken to Alleviate `he Conditions Which Led the City to Enact the Interim Urgency Ordinance on July 6, 2005 (Ten (10) Day Report) 3. Ordinance 000032 MOORPARK CITY COUNCIL AGENDA REPORT TO: Honorable City Council FROM: Scott E. Porter, Assistant City Attorney �� Barry K. Hogan, Community Development Director DATE: June 16, 2005 (CC Meeting of 07/06/05) SUBJECT: Consider Interim Urgency Ordinance to Establish Temporary Moratorium on the Establishment and Operation of Medical Marijuana Dispensaries SUMMARY Federal law prohibits, while California law allows, me&cal marijuana dispensaries. It is unclear whether and how the City may regulate such facilities. As such, it is recommended that the City Council consider adopting an interim zoning ordinance, to place a 45 day moratorium on the issuance of any entitlement relating to medical marijuana dispensaries. This moratorium would allow the City more time to determine how to proceed. BACKGROUND It is a federal crime to manufacture, distribute, dispense, or possess marijuana.) California, too, prohibits the possession or cultivation of marijuana.2 Unlike federal law, however, California law creates an exception from these prohibitions for certain parties relating to the use of marijuana for medical purposes ( "medical marijuana "). On June 6, 2005, the Supreme Court of the United States confirmed in Gonzales v. Raich that notwithstanding California's 121 U.S.C. §§ 541(a)(1), 844(a). 2Cal. Health & Saf. Code §§ 11357, 11358. CC ATTACHMENT 1 000033 Honorable City Council July 6, 2005 Page 2 exception for medical marijuana, federal law still prohibits marijuana in all circumstances, and the federal government has the right to enforce its laws against private individuals using medical marijuana for purely personal consumption. Since Gonzales v. Raich was announced, there has been increased attention on the issue of medical marijuana, and numerous bills have already been introduced, and additional bills are anticipated, which might alter the federal government's regulation of medical marijuana. As such, it is unclear whether federal law will continue to prohibit the usage of marijuana for medical purposes. Further, it is unclear how federal enforcement (or lack thereof), and the public's perception of Gonzales v. Raich will affect local government and local use of marijuana at or near medical marijuana dispensaries. The City may obtain requests to permit medical marijuana dispensaries within the City. Even though federal law prohibits such activity, there are numerous cities throughout California that continue to have medical marijuana dispensaries within their jurisdictions. For example, the City of Berkeley ci►pped the number of permitted facilities at three. The City of West Hollywood currently has nine in operation. Although Gonzales v. Raich was clear that the use of medical marijuana is illegal for federal purposes, it is still unclear how that decision and future Congressional action will affect requests to the City for permits to establish and /or operate medical marijuana facilities. If the federal law permits medical marijuana or changes its regulation, these changes may affect whether medical marijuana dispensaries would constitute a hazard to health, safety and welfare of the City's residents. Simply stated, after Gonzales v. Raich, it is unclear whether medical marijuana dispensaries will continue, how the City may regulate such facilities, and whether such facilities will exist absent City actions. DISCUSSION Pursuant to Government Code § 65858, with a 4/5 vote, the City Council may enact an urgency ordinance, which would place a 45 day moratorium on issuance of use permits, variances, building permits, business licenses, or any other entitlement for the establishment or operation of a medical marijuana dispensary. S: \Community Development \DEV PMTS \Z 0 A \2005 \MM Urgency Ord \050706 cc agenda rpt.doc O O O 0 3 4 Honorable City Council July 6, 2005 Page 3 There are various such a moratorium the City's gener and /or how the Ci dispensaries. S City's zoning c indicate whether regulated within prepare any reco zoning amendments deliberate on an would allow more approvals would amendments to t moratorium would state of the law, action, or other Moorpark. reasons that the City may consider enacting First, after an initial review, it appears al plan does not expressly indicate whether ty will regulate or permit medical marijuana econd, the City will need time to review the ode, as it apparently does not explicitly and /or how medical marijuana dispensaries are the City. City staff would need time to mmendations relating to any general plan and and the City Council would need time to y potential amendments. Third, a moratorium time for the City to ensure that any subsequent be consistent with the future potential he zoning code or general plan. Last, a allow the City time to research the existing and to determine how potential Congressional enforcement changes could affect the City of Under state law, an initial moratorium may be adopted by a�14/5 vote of the Council, but can only last for 45 days. Thereafter, the ordinance may be extended, but only after holding a public hearing. If the City Council adopts this proposed moratorium, a public hearing would need to be noticed for the July 20 meeting, since the City Council does not plan to meet in August. At that time, staff would have a recommendation for the duration of the moratorium. STAFF RECObBERMATION (ROLL CALL VOTE 4/5' AFFIRMATION) 1. Adopt Interim Ordinance No. ; and 2. Schedule and notice a public hearing for July 20, 2005, to extend the Interim Ordinance. Attachment: Ordinance S: \Community Development \DEV PMTS \Z 0 A \2005 \MM Urgency Ord \050706 cc agenda rpt.doc 0 00 0315 MEMORANDUM COMMUNITY DEVELOPMENT DEPARTMENT TO: Honorable City Council Steven Kueny, City Manager FROM: Barry K. Hogan, Community Development Director By: Laura Stringer, Administrative Services Ma g DATE: July 7, 2005 SUBJECT: REPORT ON THE MEASURES TAKEN TO ALLEVIATE THE CONDITIONS WHICH LED THE CITY TO ENACT THE INTERIM URGENCY ORDINANCE ON JULY 6, 2005 BACKGROUND /DISCUSSION On July 6, 2005, the Moorpark City Council enacted an interim urgency ordinance (the "45 Day Ordinance ") to impose a moratorium on issuance of any land use entitlements for medical marijuana dispensaries, and directed staff to schedule and notice a pubird hearing for July 20, 2005, to consider extending the Interim Ordinance for an additional 22 months and fifteen (15) days, or until June 4, 2007. On or before July 10, 2005, the City must issue a report describing the measures taken to alleviate the condition which led to the adoption of the interim ordinance (the "Ten (10) Day Report"). The attached report (with exhibits) is available at the public counter at City Hall, and copies will be available at the July 20, 2005 City Council meeting. Please do not hesitate to contact me if you have any questions. Attachments: Report on the Measures Taken to Alleviate the Condition which Led the City to Enact the Interim Urgency Ordinance on July 6, 2005 S:1Community DevetopmentlDEV PMTS\Z O A\2005\MM Urgency OrM050705 10 day rpt cover.doc CC ATTACHMENT 2 000036 REPORT ON THE MEASURES TAKEN TO ALLEVIATE THE CONDITIONS WHICH LED THE CITY TO ENACT THE INTERIM URGENCY ORDINANCE ON JULY 6, 2005 Background On July 6, 2005, pursuant to Government Code § 65858, the Moorpark City Council enacted an interim urgency ordinance (the "45 Day Ordinance ") to impose a moratorium on issuance of any land use entitlements for medical marijuana dispensaries. Absent any additional action, the interim ordinance would expire after 45 days. The proposed ordinance (the "Extension Ordinance ") would extend the moratorium for an additional 22 months and fifteen (15) days, or until June 4, 2007. Reasons for the 45 Day Ordinance The Extension Ordinance, if adopted, would be adopted for the same reasons that the 45 Day Ordinance was originally adopted, as those reasons are still accurate. The 45 Day Ordinance was adopted for various reasons, including: • Anecdotal reports suggested that crime and other public nuisances increase in those areas where medical marijuana facilities exist. The City was unaware of any additional evidence which indicated whether such facilities in fact foster crime or other public nuisances. The City needed time to gather more information. • Current law was unclear. o On the one hand, federal law prohibits marijuana use, distribution and possession. The Supreme Court of the United States ruled in United States v. Oakland Cannabis Buyers' Cooperative, 532 US 483 (2001),1 that notwithstanding California law,2 the federal Controlled Substances Act continues to prohibit marijuana use, distribution, and possession, and that no medical necessity exception exists to these prohibitions. o Additionally, the Supreme Court of the United States ruled in Gonzales v. Raich, U.S. LEXIS 4656 (2005),3 that pursuant to the commerce clause, the federal government has the power to prohibit the local ' This case is attached hereto as Exhibit "A ". 2 Cal Health & Saf. Code 5 11362.5 is attached hereto as Exhibit "B ". The enrolled version of SE 420 is attached hereto as Exhibit "C ". ' This case is attached hereto as Exhibit "D ". LA #4828- 8626 -3808 vl 00000`7 cultivation and use of marijuana, even though such cultivation and use complies with California law. o On the other hand, California law specifically indicates that certain uses of marijuana for medical purposes are legal. o In Gonzales v. Raich, the Supreme Court of the United States did not indicate that California law was invalid, but rather, merely indicated that the federal government could continue to enforce its medical marijuana laws. o It was unclear whether the City was required to allow medical marijuana facilities, as the City is governed by state law; or whether the City was required to prohibit medical marijuana facilities, because otherwise, the City would be specifically authorizing what is known to violate federal law. It was also unclear whether the City had the freedom to determine whether to allow or prohibit medical marijuana facilities. • Future laws might be amended to resolve this discrepancy. o Members of Congress have introduced bills which would, among other things, have the effect of legalizing the medical use of marijuana in California, or impose moratoriums on all federal government enforcing marijuana laws against users of marijuana for medical purposes. For example, on May 4, 2005, Representative Frank introduced HR 20874, with 36 co- sponsors, to provide for the medical use of marijuana in accordance with the laws of the various States. It was expected that future legislation would answer whether the City should allow such dispensaries. Unless the City waited for this legislation, and any subsequent related pieces of legislation to be voted upon, the City might be authorizing uses which would ultimately be illegal. Measures Taken to Alleviate the Conditions Which Led to the Adoption of the Ordinance Thus far, the office of the City Attorney has only begun to review applicable law in this area, given the recent Supreme Court cases and recently introduced legislation. Thus far, the Office of the City Attorney has: ` This bill is attached hereto as Exhibit ,E.,, LA #4828 -8626 -3808 v1 QQOVu8 • Begun a factual analysis of medical marijuana dispensaries on a community; and • Completed a preliminary analysis of Gonzales v. Raich and United States v. Oakland Cannabis Buyers' Cooperative. Duration of the Extension ordinance If adopted by the City Council, the Extension Ordinance would cause the moratorium on issuance of entitlements relating to medical dispensaries to be extended until June 4, 2007. It is not expected that the Extension Ordinance will be necessary for the entire 22 months and 15 days. However, given the very recent developments in the law in this area, it may take some months for the scope of the City's authority to be clarified, as well as several months for City staff to craft appropriate regulations thereafter. Because the City may repeal the Extension Ordinance at any time, the Extension Ordinance has been drafted to extend for the maximum time permissible under Government Code section 65858, with the understanding that once appropriate regulations can be drafted, the Extension Ordinance can be repealed. Exhibits A. U.S. v. Oakland Cannabis Buyers' Cooperative B. Cal Health & Saf. Code § 11362.5. C. SB 420 (Chaptered) D. Gonzales v. Raich E. HR 2087 LA #4828- 8626 -3808 v1 0000319 EXHIBIT A LEXSEE 532 US 483 UNITED STATES, PETITIONER v. OAKLAND CANNABIS BUYERS' COOPERATIVE AND JEFFREY JONES No. 00 -151 SUPREME COURT OF THE UNITED STATES 532 U.S. 483; 121 S. CC 1711; 149 L. Ed. 2d 722; 2001 U.S. LEXIS 3518; 69 U.S.L.W. 4316; 2001 Cal. Daily Op. Service 3836; 2001 Daily Journal DAR 4691; 14 Fla. L. Weekly S 238; 2001 Colo. J. C.A.R. 2428; 14 Fla. L. Weekly Fed. S 238 March 28, 2001, Argued May 14, 2001, Decided PRIOR HISTORY: ON WRiT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT, DISPOSITION: 190 F.3d 1109, reversed and remanded. LexisNexis(R) Headnotes SYLLABUS: Respondent Oakland Cannabis Buyers' Cooperative was organized to distribute marijuana to qualified patients for medical purposes. The United States sued to enjoin the Cooperative and its executive director, also a respondent (together, the Cooperative), under the Controlled Substances Act. The United States argued that the Cooperative's activities violated the Act's prohibitions on distributing, manufacturing, and possessing with the intent to distribute or manufacture a controlled substance. The District Court enjoined the Cooperative's activities, but the Cooperative continued to distribute marijuana. The District Court found the Cooperative in contempt, rejecting its defense that any distributions were medically necessary. The court later rejected the Cooperative's motion to modify the injunction to permit medically necessary distributions. The Cooperative appealed, and the Ninth Circuit reversed and remanded the ruling on the motion to modify the injunction. According to the Ninth Circuit, medical necessity is a legally cognizable defense likely applicable in the circumstances, the District Court mistakenly believed it had no discretion to issue an injunction more limited in scope than the Controlled Substances Act, and the District Court should have weighed the public interest and considered factors such as the serious harm in depriving patients of marijuana in deciding whether to modify the injunction. rMcA 1. There is no medical necessity exception to the Controlled Substances Act's prohibitions on manufacturing and distributing maryuana. Pp. 5 -11. (a) Because that Act classifies marijuana as a schedule 1 controlled substance, it provides only one express exception to the prohibitions on manufacturing and distributing the drug: Government- approved research projects. The Cooperative's contention that a common - law medical necessity defense should be written into the Act is rejected There is an open question whether federal courts ever have authority to recognize a necessity defense not provided by statute. But that question need not be answered to resolve the issue presented here, for the terms of the Controlled Substances Act leave no doubt that the medical necessity defense is unavailable. Pp. 5 -7. (b) Under any conception of legal necessity, the defense cannot succeed when the legislature itself has made a determination of values. Here, the Act reflects a determination that marijuana has no medical benefits worthy of an exception (other than Government - approved research). Whereas other drugs can be dispensed and prescribed for medical use, see 21 U.S.C. Page 2 532 U.S. 483, *; 121 S. Ct. 1711, * *; 149 L. Ed. 2d 722, * * *; 2001 U.S. LEXIS 3518 § 829, the same is not true for marjuana, which has 'no currently accepted medial use" at all, § 811. This conclusion is supported by the structure of the Act, which divides drugs into five schedules, depending in part on whether a drug has a currently accepted medical use, and then imposes restrictions according to the schedule in which it has been placed. The Attorney General is authorized to include a drug in schedule 1, the most restrictive schedule, only if the drug has no currently accepted medical use. The Cooperative errs in arguing that, because Congress, instead of the Attorney General, placed marijuana into that schedule, marijuana can be distributed when medically necessary. The statute treats all schedule 1 drugs alike, and there is no reason why drugs that Congress placed there should be subject to fewer controls than those that the Attorney General placed there. Also rejected is the Cooperative's argument that a drug may be found medically necessary for a particular patient or class even when it has not achieved general acceptance as a medical treatment. It is clear from the text of the Act that Congress determined that marijuana has no medical benefits worthy of an exception granted to other drugs. The statute expressly contemplates that many drugs have a useful medical purpose, see § 801(1), but it includes no exception at all for any medical use oj' marijuana. This Court is unwilling to view that omission as an accident and is unable, in any event, to override a legislative determination manifest in the statute. Finally, the canon of constitutional avoidance has no application here, because there is no .statutory ambiguity. Pp. 7 -11. 2. The discretion that courts of equity traditionally possess in fashioning relief does not serve as a basis for arming the Ninth Circuit in this case. To be sure, district courts properly acting as courts of equity have discretion unless a statute clearly provides otherwise. But the mere fact that the District Court had discretion does not suggest that the court, when evaluating the motion, could consider any and all factors that might relate to the public interest or the parties' conveniences, including medical needs. Equity courts cannot ignore Congress' judgment expressed in legislation. Their choice is whether a particular means of enforcement should be chosen over another permissible means, not whether enforcement is preferable to no enforcement at all. To the extent a district court considers the public interest and parties' conveniences. the court is limited to evaluating how those factors are affected by the selection of an injunction over other enforcement mechanisms. Because the Controlled Substances Act covers even those who have what could be termed a medical necessity, it precludes consideration of the evidence that the Ninth Circuii deemed relevant. Pp. 11 -15. 190 F. 3d 1109, reversed and remanded. COUNSEL: Barbara D, Underwood argued the cause for petitioner. Gerald F. Uelmen argued the cause for respondents. JUDGES: THOMAS, J., delivered the opinion of the Court, in which REHNQUIST, C. J., and O'CONNOR, SCALIA, and KENNEDY, JJ., joined. STEVENS, J., filed an opinion concurring in the judgment, in which SOUTER and GINSBURG, JJ., joined. BREYER, J., took no part in the consideration or decision of the case. OPINIONBY: THOMAS OPINION: [* *1715] [ ** *729] [ *486] JUSTICE THOMAS delivered the opinion of the Court. [ * * *LEdHRIA] [lA] The Controlled Substances Act, 84 Stat. 1242, 21 U.S.C. § 801 et seq., prohibits the manufacture and distribution of various drugs, including marijuana. In this case, we must decide whether there is a medical necessity exception to these prohibitions. We hold that there is not. In November 1996, California voters enacted an initiative measure entitled the Compassionate Use Act of 1996. Attempting "to ensure that seriously ill Californians have the right to obtain and use marijuana for medical purposes," Cal. Health & Safety Code Ann. § 11362.5 (West Supp. 2001), the statute creates an exception to California laws prohibiting the possession and cultivation of marijuana. These prohibitions no longer apply to a patient or his primary caregiver who possesses or cultivates marijuana t'or the patient's medical purposes upon the recommendation or approval of a physician. Ibid. In the wake of this voter initiative, several groups organized "medical cannabis dispensaries" to meet the needs of qualified patients. United States v. Cannabis Cultivators Club, 5 F. Supp. 2d 1086, 1092 (ND Cal. 1998). Respondent Oakland Cannabis Buyers' Cooperative is one of these groups. The Cooperative is a not - for - profit organization that operates in downtown Oakland. A physician serves as medical director, and registered nurses staff the Cooperative during business hours. To become a member, a patirnt must provide a written statement from a treating physician assenting to marijuana therapy and must submit to a screening interview. If accepted as a 000041 532 U.S. 483,'; 121 S. Ct. 1711, i'; 149 L. Ed. 2d 722,' "'; 2001 U.S. LEXIS 3518 member, the patient receives an identification card entitling him to obtain marijuana from the Cooperative. In January 1998, the United States sued the Cooperative and its executive director, respondent Jeffrey Jones (together, ['487] the Cooperative), in the United States District Court for the Northern District of California. Seeking to enjoin the Cooperative from distributing and manufacturing marijuana, nl the United States argued that, ["• 17161 whether or not the Cooperative's activities are legal under California law, they violate federal law. Specifically, the Government argued that the Cooperative violated the Controlled Substances Act's prohibitions on distributing, manufacturing, and possessing with the intent to distribute or manufacture a controlled substance. 21 U.S.C. § 841(a). Concluding that the Government had established a probability of success on the merits, the District Court granted a preliminary [' "'730] injunction. App. to Pet. for Cert. 39a -40a, 5 F. Supp. 2d at 1105. nl The Government requested, and the District Court granted, an injunction that prohibited the possession of marijuana with the intent to manufacture and distribute, as well as the distribution and manufacture of marijuana. For simplicity, in this opinion, we refer to these activities collectively as distributing and manufacturing marijuana. The legal issues are the same for all of these activities. The Cooperative did not appeal the injunction but instead openly violated it by distributing marijuana to numerous persons, App, to Pet. for Cert. at 21 a -23a. To terminate these violations, the Government initiated contempt proceedings. In defense, the Cooperative contended that any distributions were medically necessary. Marijuana is the only drug, according to the Cooperative, that can alleviate the severe pain and other debilitating symptoms of the Cooperative's patients. Id. at 29a. The District Court rejected this defense, however, after determining there was insufficient evidence that each recipient of marijuana was in actual danger of imminent harm without the drug. Id. at 29a -32a. The District Court found the Cooperative in contempt and, at the Government's request, modified the preliminary injunction to empower the United States Marshal to seize the Cooperative's premises. Id. at 37a. Although recognizing that ['488] "human suffering" could result, the District Court reasoned that a court's "equitable powers [do] not permit it to ignore federal law." Ibid. Three days later, the District Court summarily rejected a Page 3 motion by the Cooperative to modify the injunction to permit distributions that are medically necessary. The Cooperative appealed both the contempt order and the denial of the Cooperative's motion to modify. Before the Court of Appeals for the Ninth Circuit decided the case, however, the Cooperative voluntarily Purged its contempt by promising the District Court that it would comply with the initial preliminary injunction, Consequently, the Court of Appeals determined that the appeal of the contempt order was moot. 190 F.3d 1109, 1112 -1113 (1999). The denial of the Cooperative's motion to modify the injunction, however, presented a live controversy that was appealable under 28 U.S.C. § 1292(a)(1). Reaching the merits of this issue, the Court of Appeals reversed and remanded. According to the Court of Appeals, the medical necessity defense was a "legally cognizable defense" that likely would apply in the circumstances. 190 F.3d at 1114. Moreover, the Court of Appeals reasoned, the District Court erroneously "believed that it had no discretion to issue an injunction that was more limited in scope than the Controlled Substances Act itself." Id. at 1114 -1115. Because, according to the Court of Appeals, district courts retain "broad equitable discretion" to fashion injunctive relief, the District Court could have, and should have, weighed the "public interest" and considered factors such as the serious harm in depriving patients of marijuana. Ibid. Remanding the case, the Court of Appeals instructed the District Court to consider "the criteria for a medical necessity exemption, and, should it modify the injunction, to set forth those criteria in the modification order." Id. at 1115. Following these instructions, the District Court granted the Cooperative's [ "489] motion to modify the injunction to incorporate a medical necessity defense. n2 n2 The amended preliminary injunction reaffirmed that the Cooperative is generally enjoined from manufacturing, distributing, and possessing with the intent to manufacture or distribute marijuana, but it carved out an exception for cases of medical necessity. Specifically, the District Court ordered that "the foregoing injunction does not apply to the distribution of cannabis by (the Cooperative] to patient- members who (1) suffer from a serious medical condition, (2) will suffer imminent harm if the patient- member does not have access to cannabis, (3) need cannabis for the treatment of the patient- member's medical condition, or need cannabis to alleviate the medical condition or symptoms associated with the medical condition, and (4) have no reasonable legal alternative to 000042 532 U.S. 483, *; 121 S. Ct. 1711, * *; 149 L. Ed. 2d 722, * * *; 2001 U.S. LEXIS 3518 cannabis for the effective treatment or alleviation of the patient - member's medical condition or symptoms associated with the medical condition because the patient - member has tried all other legal alternatives to cannabis and the alternatives have been ineffective in treating or alleviating the patient- member's medical condition or symptoms associated with the medical condition, or the alternatives result in side effects which the patient- member cannot reasonably tolerate." App. to Pet. for Cert. 16a -17a. The United States appealed the District Court's order amending the preliminary injunction. At the Government's request, we stayed the order pending the appeal. 530 U.S. 1298 (2000). The Court of Appeals has postponed oral argument pending our decision in this case. [* *1717] [ ** *731] The United States petitioned for certiorari to review the Court of Appeals' decision that medical necessity is a legally cognizable defense to violations of the Controlled Substances Act. Because the decision raises significant questions as to the ability of the United States to enforce the Nation's drug laws, we granted certiorari. 531 U.S. 1010 (2000). Il The Controlled Substances Act provides that, "except as authorized by this subchapter, it shall be unlawful for any person knowingly or intentionally ... to manufacture, distribute, or dispense, or possess with intent to manufacture, distribute, or dispense, a controlled substance." 21 U.S.C. § 841(a)(1). The subchapter, in turn, establishes exceptions. [ *490] For marijuana (and other drugs that have been classified as "schedule I" controlled substances), there is but one express exception, and it is available only for Government- approved research projects, § 823(f). Not conducting such a project, the Cooperative cannot, and indeed does not, claim this statutory exemption. [ * * *LEdHRIB] [1B]The Cooperative contends, however, that notwithstanding the apparently absolute language of § 841(a), the statute is subject to additional, implied exceptions, one of which is medical necessity. According to the Cooperative, because necessity was a defense at common law, medical necessity should be read into the Controlled Substances Act. We disagree, [ * * *LEd1IR2] [2]As an initial matter, we note that it is an open question whether federal courts ever have authority to recognize a necessity defense not provided Page 4 by statute. A necessity defense "traditionally covered the situation where physical forces beyond the actor's control rendered illegal conduct the lesser of two evils." United States v. Bailey, 444 U.S. 394, 410, 62 L. Ed. 2d 575, 100 S. Ct. 624 (1980). Even at common law, the defense of necessity was somewhat controversial. See, e.g., Queen v. Dudley & Stephens, 14 QB 273 (1884). And under our constitutional system, in which federal crimes are defined by statute rather than by common law, see United States v. Hudson, 1 I U.S. 32, 7 Cranch 32, 34, 3 L. Ed. 259 (1812), it is especially so. As we have stated: "Whether, as a policy matter, an exemption should be created is a question for legislative judgment, not judicial inference." United States v. Rutherford, 442 U.S. 544, 559, 61 L. Ed. 2d 68, 99 S. Ct. 2470 (1979). Nonetheless, we recognize that this Court [ ** *732] has discussed the possibility of a necessity defense without altogether rejecting it. See, e.g., Bailey, supra, at 415. n3 n3 The Cooperative is incorrect to suggest that Bailey has settled the question whether federal courts have authority to recognize a necessity defense not provided by statute. There, the Court rejected the necessity defense of a prisoner who contended that adverse prison conditions justified his prison escape. The Court held that the necessity defense is unavailable to prisoners, like Bailey, who fail to present evidence of a bona fide effort to surrender as soon as the claimed necessity had lost its coercive force. 444 U.S. at 415. It was not argued, and so there was no occasion to consider, whether the statute might be unable to bear any necessity defense at all. And although the Court noted that Congress "legislates against a background of Anglo -Saxon common law" and thus "may" have contemplated a necessity defense, the Court refused to "balance [the] harms," explaining that "we are construing an Act of Congress, not drafting it." Id. at 415, n. 11. [* *1718] [ *491] [ * * *LEdHRIC] [IC] [ * * *[.EdHR3] [3] [* * *LEdHR4A] [4A]We need not decide, however, whether necessity can ever be a defense when the federal statute does not expressly provide for it. In this case, to resolve the question presented, we need only recognize that a medical necessity exception for marijuana is at odds with the terms of the Controlled Substances Act. The statute, to be sure, does not explicitly abrogate the defense, n4 But its provisions leave no doubt that the defense is unavailable. [ * * *LEdfIR4B] [4B] 000043 532 U.S. 483,'; 121 S. Ct. 1711, * *; 149 L. Ed. 2d 722, * * *; 2001 U.S. LEXIS 3518 n4 We reject the Cooperative's intimation that elimination of the defense requires an "explicit" statement. Brief for Respondents 21. Considering that we have never held necessity to be a viable justification for violating a federal statute, see supra, at 5-6, and n. 3, and that such a defense would entail a social balancing that is better left to Congress, we decline to set the bar so high. [ * * *LEdHRiD] [ID] [ * *'LEdHR5] [5]Under any conception of legal necessity, one principle is clear: The defense cannot succeed when the legislature itself has made a "determination of values." I W. LaFave & A. Scott, Substantive Criminal Law § 5.4, p. 629 (1986). In the case of the Controlled Substances Act, the statute reflects a determination that marijuana has no medical benefits worthy of an exception (outside the confines of a Government- approved research project). Whereas some other drugs can be dispensed and prescribed for medical use, see 21 U.S.C. § 829, the same is not true for marijuana. Indeed, for purposes of the Controlled Substances Act, marijuana has "no currently accepted medical use" at all. § 811. [ * * *LEdIIRIE] [IE]The structure of the Act supports this conclusion. The statute divides drugs into five schedules, depending in part on whether the particular drug has a currently accepted [ *492] medical use. The Act then imposes restrictions on the manufacture and distribution of the substance according to the schedule in which it has been placed. Schedule I is the most restrictive schedule. n5 The Attorney General can include a drug in schedule I only if the drug "has no currently accepted medical use in treatment in the United States," "has a high potential for abuse," and has "a lack of accepted safety for use . . . under medical supervision." § § 812(b)(1)(A) -(C). Under the statute, the Attorney General could not put marijuana into schedule I if [•* *733] marijuana had any accepted medical use. n5 As noted, supra, at 5, the only express exception for schedule I drugs is the Govern ment- approved research project, see 21 U.S.C. § 823(f). Unlike drugs in other schedules, see § 829, schedule I drugs cannot be dispensed under a prescription. The Cooperative points out, however, that the Attorney General did not place marijuana into schedule I. Congress put it there, and Congress was not required to Page 5 find that a drug lacks an accepted medical use before including the drug in schedule 1. We are not persuaded that this distinction has any significance to our inquiry. Under the Cooperative's logic, drugs that Congress places in schedule I could be distributed when medically necessary whereas drugs that the Attorney General places in schedule I could not. Nothing in the statute, however, suggests that there are two tiers of schedule I narcotics, with drugs in one tier more readily available than drugs in the other. On the contrary, the statute consistently treats all schedule I drugs alike. See, e.g., § 823(a) (providing criteria for Attorney General to consider when determining whether to register an applicant to manufacture schedule I controlled substances), § 823(b) (providing criteria for Attorney General to consider [* *1719] when determining whether to register an applicant to distribute schedule I controlled substances), § 823(f) (providing procedures for becoming a government- approved research project), § 826 (establishing production quotas for schedule 1 drugs). Moreover, [ *493] the Cooperative offers no convincing explanation for why drugs that Congress placed on schedule I should be subject to fewer controls than the drugs that the Attorney General placed on the schedule. Indeed, the Cooperative argues that, in placing marijuana and other drugs on schedule 1, Congress "wished to assert the most restrictive level of controls created by the [Controlled Substances Act]." Brief for Respondents 24. If marijuana should be subject to the most restrictive level of controls, it should not be treated any less restrictively than other schedule I drugs. [ * * *LEdHR1F] [IF] [ ..LEdHR6A] [6A]The Cooperative further argues that use of schedule I drugs generally -- whether placed in schedule I by Congress or the Attorney General -- can be medically necessary, notwithstanding that they have "no currently accepted medical use." According to the Cooperative, a drug may not yet have achieved general acceptance as a medical treatment but may nonetheless have medical benefits to a particular patient or class of patients. We decline to parse the statute in this manner. It is clear from the text of the Act that Congress has made a determination that marijuana has no medical benefits worthy of an exception. The statute expressly contemplates that many drugs "have a useful and legitimate medical purpose and are necessary to maintain the health and general welfare of the American people," § 801(1), but it includes no exception at all for any medical use of marijuana. Unwilling to view this omission as an accident, and unable in any event to override a legislative determination manifest in a statute, we reject the Cooperative's argument. n6 [' *'LEdHR6B] [6B] 532 U.S. 483,'; 121 S. Ct. 1711, * *; 149 L. Ed. 2d 722, ** *; 2001 U.S. LEXIS 3518 n6 The Government argues that the 1998 "sense of the Congress" resolution, 112 Stat. 2681 -760 to 2681 -761, supports its position that Congress has foreclosed the medical necessity defense. Entitled "Not Legalizing Marijuana for Medicinal Use," the resolution declares that "Congress continues to support the existing Federal legal process for determining the safety and efficacy of drugs and opposes efforts to circumvent this process by legalizing marijuana, and other Schedule I drugs, for medicinal use without valid scientific evidence and the approval of the Food and Drug Administration." Because we conclude that the Controlled Substances Act cannot sustain the medical necessity defense, we need not consider whether the 1998 "sense of the Congress resolution" is additional evidence of a legislative determination to eliminate the defense. [*494] [* **LEdHR7] [7] [ * **LEdHR8] [8]17inally, the Cooperative contends [ ** *734] that we should construe the Controlled Substances Act to include a medical necessity defense in order to avoid what it considers to be difficult constitutional questions. In particular, the Cooperative asserts that, shorn of a medical necessity defense, the statute exceeds Congress' Commerce Clause powers, violates the substantive due process rights of patients, and offends the fundamental liberties of the people under the Fifth, Ninth, and Tenth Amendments. As the Cooperative acknowledges, however, the canon of constitutional avoidance has no application in the absence of statutory ambiguity. Because we have no doubt that the Controlled Substances Act cannot bear a medical necessity defense to distributions of marijuana, we do not find guidance in this avoidance principle. Nor do we consider the underlying constitutional issues today, Because the Court of Appeals did not address these claims, we decline to do so in the first instance. [* * *LEd]IRIG] [IG] [ * *'LEdlIR9A] [9A] [ *'*LEdHRIOA] [IOA]For these reasons, we hold that medical necessity is not a defense to manufacturing and distributing marijuana. n7 [**1720] The [*495] Court of Appeals erred when it held that medical necessity is a "legally cognizable defense." 190 F.3d at 1114. It further erred when it instructed the District Court on remand to consider "the criteria for a medical necessity exemption, and, should it modify the injunction, to set forth those criteria in the modification order." Id. at 1 1 15. [ * * *LEdHR9B] 19131 Page 6 n7 Lest there be any confusion, we clarify that nothing in our analysis, or the statute, suggests that a distinction should be drawn between the prohibitions on manufacturing and distributing and the other prohibitions in the Controlled Substances Act. Furthermore, the very point of our holding is that there is no medical necessity exception to the prohibitions at issue, even when the patient is "seriously ill" and lacks alternative avenues for relief. Indeed, it is the Cooperative's argument that its patients are "seriously ill," see, e.g., Brief for Respondents 11, 13, 17, and lacking "alternatives," see, e.g., id. at 13. We reject the argument that these factors warrant a medical necessity exception. If we did not, we would be affirming instead of reversing the Court of Appeals. Finally, we share JUSTICE STEVENS' concern for "showing respect for the sovereign States that comprise our Federal Union." Post, at 3 (opinion concurring in judgment). However, we are "construing an Act of Congress, not drafting it." United States v. Bailey, 444 U.S. 394, 415, n. 11, 62 L. Ed. 2d 575, 100 S. Ct. 624 (1980). Because federal courts interpret, rather than author, the federal criminal code, we are not at liberty to rewrite it. Nor are we passing today on a constitutional question, such as whether the Controlled Substances Act exceeds Congress' power under the Commerce Clause. [ * **LEdHRI IA] [1 IA]The Cooperative contends that, even if the Controlled Substances Act forecloses the medical necessity defense, there is an alternative ground for affirming the Court of Appeals. This case, the Cooperative reminds us, arises from a motion to modify an injunction to permit distributions that are medically necessary. According to the Cooperative, the Court of Appeals was correct that the District Court had "broad equitable discretion" to tailor the injunctive relief to account for medical necessity, irrespective of whether there is a legal defense of necessity in the statute. Id. at 1114. To sustain [ ** *7351 the judgment below, the argument goes, we need only reaffirm that federal courts, in the exercise of their equity jurisdiction, have discretion to modify an injunction based upon a weighing of the public interest. n8 [** *LFdl]R11B] [1113] 000045 532 U.S. 483, *; 121 S. Ct. 1711, * *; 149 L. Ed. 2d 722, * * *; 2001 U.S. LEXIS 3518 n8 Notwithstanding JUSTICE STEVENS' concerns, post, at 4, it is appropriate for us to address this issue because this case arises from a motion to modify the injunction, because the Court of Appeals held that the District Court misconstrued its equitable discretion, and because the Cooperative offers this conclusion as an alternative ground for affirmance. [ * * *LEdHR10B] [10B] [ * * *LEdHR12A] [12A]We disagree. Although district courts whose equity powers have been properly invoked indeed have discretion in fashioning injunctive relief (in the absence of a statutory restriction), the Court of Appeals erred concerning the factors that the district courts may consider in exercising such discretion. [ *4961 A [ * * *LEdHR12B] [12B]As an initial matter, the Cooperative is correct that, when district courts are properly acting as courts of equity, they have discretion unless a statute clearly provides otherwise. For "several hundred years," courts of equity have enjoyed "sound discretion" to consider the "necessities of the public interest" when fashioning injunctive relief. Hecht Co. v. Bowles, 321 U.S. 321, 329 -330, 88 L. Ed. 754, 64 S. Ct. 587 (1944). See also id. at 329 ( "The essence of equity jurisdiction has been the power of the Chancellor to do equity and to mould each decree to the necessities of the particular case. Flexibility rather than rigidity has distinguished it "); Weinberger v. Romero - Barcelo, 456 U.S. 305, 312, 72 L. Ed. 2d 91, 102 S. Ct. 1798 (1982) ( "In exercising their sound discretion, courts of equity should pay particular regard for the public consequences in employing the extraordinary remedy of injunction "). Such discretion is displaced only by a "clear and valid legislative command." Porter v. Warner Holding Co., 328 U.S. 395, 398, 90 L. Ed. 1332, 66 S. Ct. 1086 (1946). See also Romero - Barcelo, supra, at 313 ( "Of course, Congress may intervene and guide [ ** 17211 or control the exercise of the courts' discretion, but we do not lightly assume that Congress has intended to depart from established principles "). [ * * *LEdlIR13] 113 ]The Cooperative is also correct that the District Court in this case had discretion. The Controlled Substances Act vests district courts with jurisdiction to enjoin violations of the Act, 21 U.S.C. § 882(a). But a "grant of jurisdiction to issue [equitable relief) hardly suggests an absolute duty to do so under any and all circumstances," Hecirr, supra, at 329 (emphasis omitted). Because the District Court's use of equitable power is not textually required by any "clear Page 7 and valid legislative command," the court did not have to issue an injunction. TVA v. Hill, 437 U.S. 153, 57 L. Ed. 2d 117, 98 S. Ct. 2279 (1978), does not support the Government's contention that the District Court lacked discretion in fashioning injunctive relief. In Hill, the Court held that the Endangered Species Act of 1973 required the [ *497] District Court to enjoin completion of a dam, whose operation would either eradicate the known population of the snail darter or destroy its critical habitat. Id. at 193- 195. [* *•736] The District Court lacked discretion because an injunction was the "only means of ensuring compliance." Romero - Barcelo, supra, at 314 (explaining why the District Court in Hill lacked discretion). Congress order of priorities," as expressed in the statute, would be deprived of effect if the District Court could choose to deny injunctive relief. Hill, supra, at 194. In effect, the District Court had only a Hobson's choice. By contrast, with respect to the Controlled Substances Act, criminal enforcement is an alternative, and indeed the customary, means of ensuring compliance with the statute. Congress' resolution of the policy issues can be (and usually is) upheld without an injunction. B [* * *1,EdHRIOC] 110C]But the mere fact that the District Court had discretion does not suggest that the District Court, when evaluating the motion to modify the injunction, could consider any and all factors that might relate to the public interest or the conveniences of the parties, including the medical needs of the Cooperative's patients. On the contrary, a court sitting in equity cannot "ignore the judgment of Congress, deliberately expressed in legislation." Virginian R. Co. v. Railway F,mplayees, 300 U.S. 515, 551 (1937). A district court cannot, for example, override Congress' policy choice, articulated in a statute, as to what behavior should be prohibited. "Once Congress, exercising its delegated powers, has decided the order of priorities in a given area, it is ... for the courts to enforce them when enforcement is sought." Hill, 437 U.S. 153, 194. Courts of equity cannot, in their discretion, reject the balance that Congress has struck in a statute. Id. at 194 -195. Their choice (unless there is statutory language to the contrary) is simply whether a particular means of enforcing the statute should be chosen over another permissible [ *498] means; their choice is not whether enforcement is preferable to no enforcement at all. n9 Consequently, [* *1722] when a court of equity exercises its discretion, it may not consider the advantages and disadvantages of nonenforcement of the statute, but only the advantages and disadvantages of "employing the extraordinary remedy of injunction," Romero - Barcelo, 456 U.S. at 311, over the other available methods of enforcement. 000046 532 U.S. 483,'; 121 S. Ct. 1711, * *; 149 L. Ed. 2d 722, * * *; 2001 U.S. LEXIS 3518 [* **7371 CC id. at 316 (referring to "discretion to rely on remedies other than an immediate prohibitory injunction ") To the extent the district court considers the public interest and the conveniences of the parties, the court is limited to evaluating how such interest and conveniences are affected by the selection of an injunction over other enforcement mechanisms. n9 Hecht Co. v. Bowles, 321 U.S. 321, 88 L. Ed. 754, 64 S. Ct. 587 (1944), for example, held that the District Court was not required to issue an injunction to restrain violations of the Emergency Price Control Act of 1942 and regulations thereunder when "some 'other order' might be more appropriate, or at least so appear to the court." Id. at 328 (quoting statutory provision that enabled district court to issue an injunction, a restraining order, "or other order "). Weinberger v. Romero- Barcelo, 456 U.S. 305, 72 L. Ed. 2d 91, 102 S. Ct. 1798 (1982), held that a District Court had discretion not to issue an injunction precluding the United States Navy from releasing ordnance into water, but to rely on other means of ensuring compliance, including ordering the Navy to obtain a permit. Id. at 314- 318. See also Amoco Production Co. v. Gambell, 480 U.S. 531, 544 -546, 94 L. Ed. 2d 542, 107 S. Ct. 1396 (1987) (holding that a District Court did not err in declining to issue an injunction to bar exploratory drilling on Alaskan public lands, because the district court's decision "did not undermine" the policy of the Alaska National Interest Lands Conservation Act, 16 U.S.C. § 3120, and because the Secretary of the interior had other means of meaningfully complying with the statute). C In this case, the Court of Appeals erred by considering relevant the evidence that some people have "serious medical conditions for whom the use of cannabis is necessary in order to treat or alleviate those conditions or their symptoms," that these people "will suffer serious harm if they are denied cannabis," and that "there is no legal alternative to cannabis [ *499] for the effective treatment of their medical conditions." 190 F.3d at 1115. As explained above, in the Controlled Substances Act, the balance already has been struck against a medical necessity exception. Because the statutory prohibitions cover even those who have what could be termed a medical necessity, the Act precludes consideration of this evidence. It was thus error for the Court of Appeals to instruct the District Court on remand to consider "the criteria for a medical necessity Page 8 exemption, and, should it modify the injunction, to set forth those criteria in the modification order." Ibid. The judgment of the Court of Appeals is reversed, and the case is remanded for further proceedings consistent with this opinion. It is so ordered. JUSTICE BREYER took no part in the consideration or decision of this case. CONCURBY: STEVENS CONCUR: JUSTICE STEVENS, with whom JUSTICE SOUTER and JUSTICE GINSBURG join, concurring in the judgment. Lest the Court's narrow holding be lost in its broad dicta, let me restate it here: "We hold that medical necessity is not a defense to manufacturing and distributing marijuana." Ante, at 10 (emphasis added). This confined holding is consistent with our grant of certiorari, which was limited to the question "whether the Controlled Substances Act, 21 U.S.C. 801 et seq., forecloses a medical necessity defense to the Act's prohibition against manufacturing and distributing marijuana, a Schedule 1 controlled substance." Pet. for Cert. (1) (emphasis added). And, at least with respect to distribution, this holding is consistent with how the issue was raised and litigated below. As stated by the District Court, the question before it was "whether [respondents'] admitted distribution of marijuana for use by seriously [ *500] ill persons upon a physician's recommendation violates federal law," and if so, whether such distribution "should be enjoined pursuant to the injunctive relief provisions of the federal Controlled Substances Act." United States v. Cannabis Cultivators Club, 5 F. Supp. 2d 1086, 1091 (ND Cal. 1998) (emphasis added). Accordingly, in the lower courts as well as here, respondents have raised the medical necessity defense as a justification for distributing marijuana to cooperative members, and it 1 ** *738] was in that context that 1* *17231 the Ninth Circuit determined that respondents had "a legally cognizable defense." 190 F.3d 1109, 1114 (1999). The Court is surely correct to reverse that determination. Congress' classification of marijuana as a schedule I controlled substance — that is, one that cannot be distributed outside of approved research projects, see 21 U.S.C. § § 812, 823(f), 829 -- makes it clear that "the Controlled Substances Act cannot bear a medical necessity defense to distributions of marijuana," ante, at 10 (emphasis added)). n 000047 532 U.S. 483, *; 121 S. Ct. 1711, * *; 149 L. Ed. 2d 722, * * *; 2001 U.S. LEXIS 3518 nl In any event, respondents do not fit the paradigm of a defendant who may assert necessity. The defense "traditionally covered the situation where physical forces beyond the actor's control rendered illegal conduct the lesser of two evils." United States v. Bailey, 444 U.S. 394, 410, 62 L. Ed. 2d 575, 100 S. C1. 624 (1980); see generally 1 W. LaFave & A. Scott, Substantive Criminal Law § 5.4, pp. 627 -640 (1986). Respondents, on the other hand, have not been forced to confront a choice of evils -- violating federal law by distributing marijuana to seriously ill patients or letting those individuals suffer -- but have thrust that choice upon themselves by electing to become distributors for such patients. Of course, respondents also cannot claim necessity based upon the choice of evils facing seriously ill patients, as that is not the same choice respondents face. Apart from its limited holding, the Court takes two unwarranted and unfortunate excursions that prevent me from joining its opinion. First, the Court reaches beyond its holding, and beyond the facts of the case, by suggesting that the defense of necessity is unavailable for anyone under the [ *501) Controlled Substances Act. Ante, at 6 -9, 10, n. 7, 15. Because necessity was raised in this case as a defense to distribution, the Court need not venture an opinion on whether the defense is available to anyone other than distributors. Most notably, whether the defense might be available to a seriously ill patient for whom there is no alternative means of avoiding starvation or extraordinary suffering is a difficult issue that is not presented here. n2 n2 As a result, perhaps the most glaring example of the Court's dicta is its footnote 7, where it opines that "nothing in our analysis, or the statute, suggests that a distinction should be drawn between the prohibitions on manufacturing and distributing and the other prohibitions in the Controlled Substances Act." Ante, at 10, n. 7. Second, the Court gratuitously casts doubt on "whether necessity can ever be a defense" to any federal statute that does not explicitly provide for it, calling such a defense into question by a misleading reference to its existence as an "open question." Ante, at 5, 6. By contrast, our precedent has expressed no doubt about the viability of the common -law defense, even in the context of federal criminal statutes that do not provide for it in so many words. See, e.g., United States v. Bailey, 444 U.S. Page 9 394, 4I5, 62 L. Ed. 2d 575, 100 S. Ct. 624 (1980) ( "We therefore hold that, where a criminal defendant is charged with escape and claims that he is entitled to an instruction on the theory of duress or necessity, he must proffer evidence of a bona fide effort to surrender or return to custody as soon as the claimed duress or necessity had lost its coercive force "); id. at 415, n. I 1 ( "Our principal difference with the dissent, therefore, is not as to the existence of such a defense but as to the importance of surrender as an element of it" (emphasis added)). Indeed, the Court's comment on the general availability [ ** *739] of the necessity defense is completely unnecessary because the Government has made no such suggestion. Cf. Brief for Petitioner 17 -18 (narrowly arguing that necessity defense cannot succeed if legislature has [ *502] already "canvassed the issue" and precluded it for a particular statute (internal quotation marks omitted)). The Court's opinion on this point is pure dictum. The overbroad language of the Court's opinion is especially unfortunate given the importance of showing respect for the sovereign States that comprise our Federal Union. That respect imposes a duty on federal courts, whenever possible, to avoid [* *1724] or minimize conflict between federal and state law, particularly in situations in which the citizens of a State have chosen to "serve as a laboratory" in the trial of "novel social and economic experiments without risk to the rest of the country." New State ke Co. Y. l iebmann, 285 U.S. 262, 311, 76 L. Ed. 747, 52 S. Ct. 371 (1932) (Brandeis, J., dissenting). In my view, this is such a case. n3 By passing Proposition 215, California voters have decided that seriously ill patients and their primary caregivers should be exempt from prosecution under state laws for cultivating and possessing marijuana if the patient's physician recommends using the drug for treatment. n4 This case does not call upon the Court to deprive all such patients of the benefit of the necessity defense to federal prosecution, when the case itself does not involve any such patients. n3 Cf. Feeney, Bush Backs States' Rights on Marijuana: He Opposes Medical Use But Favors Local Control, Dallas Morning News, Oct. 20, 1999, p. 6 A. 1999 WL 28018944 (then - Governor Bush supporting state self - determination on medical marijuana use). n4 Since 1996, six other States -- Alaska, Colorado, Maine, Nevada, Oregon, and Washington -- have passed medical marijuana initiatives, and Hawaii has enacted a similar measure through its legislature. See Alaska Stat. Ann. § § 11.71 .090, 17.37.010 to 17.37.080 Page 10 532 U.S. 483, "; 121 S. Ct. 1711, •'; 149 L. Ed. 2d 722,'•"; 2001 U.S. LEXIS 3518 (2000); Colo. Const., Art. XVIII, § 14; Haw. Substances Act. I do not, however, join the dicta in the Rev. Stat. § § 329 -121 to 329 -128 (Supp. 2000); Court's opinion. Me. Rev. Stat. Ann., Tit. 22, § 2383 -8(5) (2000); Nev. Const., Art. 4, § 38; Ore. Rev. Stat. § § REFERENCES: Return To Full Text Opinion 475.300 to 475.346 (1999); Wash. Rev. Code § § 69,51A.005 to 69.51A.902 (1997 and Supp. 2000 - 2001). Go to Supreme Court Brief(s) Go to Oral Argument Transcript An additional point deserves emphasis. This case does not require us to rule on the scope of the District Court's discretion to enjoin, or to refuse to enjoin, the possession of marijuana or other potential violations of the Controlled ['5031 Substances Act by a seriously ill patient for whom the drug may be a necessity. Whether it would be an abuse of discretion for the District Court to refuse to enjoin those sorts of violations, and whether the District Court may consider the availability of the necessity defense for that sort of violator, are questions that should be decided on the authority of cases such as Hecht Co. v. Bowles, 321 U.S. 321, 88 L. Ed. 754, 64 S. Ct. 587 (1944), and Weinberger v. Romero- Barcelo, 456 U.S. 305, 72 L. Ed. 2d 91, 102 S. Ct. 1798 (1982), and that properly should be left "open" by this case. join the Court's judgment of reversal because I agree that a distributor of marijuana does not have a medical necessity defense under the Controlled 25 Am Jur 2d, Drugs and Controlled Substances 65, 130, 153, 180, 200 21 USCS 841(a) L Ed Digest, Courts 92.3; Drugs, Narcotics, and Poisons 6 L Ed Index, Marijuana Annotation References: Sufficiency of evidence that possessor of marijuana had intent to distribute it, so as to violate 21 USCS 841(a)(1). 79 ALR Fed 113. 000049 EXHIBIT B LEXSTAT CAL. HEALTH & SAF CODE 11362.5 DEERING'S CALIFORNIA CODES ANNOTATED Copyright (c) 2005 by Matthew Bender & Company, Inc. a member of the LexisNexis Group. All rights reserved. ••' THIS DOCUMENT REFLECTS ALL URGENCY LEGISLATION ENACTED "•» THROUGH 2005 CH. 14, APPROVED 6/17/2005 "•• HEALTH AND SAFETY CODE DIVISION 10. Uniform Controlled Substances Act CHAPTER 6. Offenses and Penalties ARTICLE 2. Marijuana CO TO CALIFORNIA CODES ARCHIVE DIRECTORY Cal Health & Saf Code § 11362.5 (2005) § 11362.5. Use of marijuana for medical purposes (a) "Phis section shall be known and may be cited as the Compassionate Use Act of 1996. (b)(l) The people of the State of California hereby find and declare that the purposes of the Compassionate Use Act of 1996 are as follows: (A) To ensure that seriously ill Californians have the right to obtain and use marijuana for medical purposes where that medical use is deemed appropriate and has been recommended by a physician who has determined that the person's health would benefit from the use of marijuana in the treatment of cancer, anorexia, AIDS, chronic pain, spasticity, glaucoma, arthritis, migraine, or any other illness for which marijuana provides relief. (13) To ensure that patients and their primary caregivers who obtain and use marijuana for medical purposes upon the recommendation of a physician are not subject to criminal prosecution or sanction. (C) To encourage the federal and state governments to implement a plan to provide for the safe and affordable distribution of marijuana to all patients in medical need of marijuana. (2) Nothing in this section shall be construed to supersede legislation prohibiting persons from engaging in conduct that endangers others, nor to condone the diversion of marijuana for nonmedical purposes. (c) Notwithstanding any other provision of law, no physician in this state shall be punished, or denied any right or privilege, for having recommended marijuana to a patient for medical purposes. (d) Section 11357, relating to the possession of marijuana, and Section 11358, relating to the cultivation of marijuana, shall not apply to a patient, or to a patient's primary caregiver, who possesses or cultivates marijuana for the personal medical purposes of the patient upon the written or oral recommendation or approval of a physician. (e) For the purposes of this section, "primary caregiver" means the individual designated by the person exempted under this section who has consistently assumed responsibility for the housing, health, or safety of that person. 000050 Page 2 Cal Health & Saf Code § 11362.5 HISTORY: Adopted by the voters, Prop. 215 § I, effective November 6, 1996. NOTES: Note: Proposition 215 (1996) provides: SECTION. 2. If any provision of this measure or the application thereof to any person or circumstance is held invalid, that invalidity shall not affect other provisions or applications of the measure that can be given effect without the invalid provision or application, and to this end the provisions of his measure are severable. Related Statutes & Rules: Medical Marijuana Program: H & S C § § 11362.7 et seq.Collateral References: Cal Criminal Defense Practice (Matthew Bender) ch 145 "Narcotics and Alcohol Offenses" § 145.01(3). Law Review Articles: Good Cop, Bad Cop: Federal Prosecution of State - Legalized Medical Marijuana Use After United States v. Lopez. 88 Cal LR 1575. The Growing Debate on Medical Marijuana: Federal Power vs. States Rights. 37 Cal Western LR 369. Proposition 215: legal strategies for the medicinal use of marijuana. 21 LA Law, No. 5, p. 21. "Silence Is a Fence Around Wisdom ": How Conant V. Walters Broke down the Fence by Securing Physicians' First Amendment Right to Recommend Medical Marijuana to 'Their Patients. 37 Loy. L.A. L. Rev. 1771. Raich v. Ashcroft: Medical Marijuana and the Revival of Federalism. 41 San Diego L. Rev. 1873. Medical Marijuana: State Law Undermines Federal Marijuana Policy -- Is the Establishment Going to Pot? 7 San Joaquin Agricultural Law Review 73. Notes of Decisions: 0.5. Constitutionality 1, In General 2. Particular Applications 3. Burden of Proof 4. Return of Seized Marijuana 0.5. Constitutionality California residents who suffered from a variety of serious medical conditions sought to avail themselves of medical marijuana pursuant to the terms of the Compassionate Use Act, H & S C § 11352, and subsequently federal Drug Enforcement Administration (DEA) agents seized and destroyed the residents' cannabis plants; the residents sought injunctive and declaratory relief prohibiting enforcement of the federal Controlled Substances Act (CSA), 21 U.S.C.S. § 801 et seq., to the extent it prevented them from possessing, obtaining, or manufacturing cannabis for their personal medical use; the US Supreme Court held that the power vested in Congress by US Const. Art. 1, § 8, included the power to prohibit the local cultivation and use of marijuana, even though such cultivation and use was in compliance with California law. Gonzales v. Raich, 2005 U.S. LF,XIS 4656. 1. In General The Compassionate Use Act of 1996 (Health & Saf. Code, § 11362.5) (marijuana for medical purposes), which was enacted while defendant's appeal from convictions for possessing and transporting marijuana was pending, could be applied retroactively to provide, if its terms and the applicable facts permitted, a defense to defendant. The Legislature is presumed to have extended to defendants whose appeals are pending the benefits of intervening statutory amendments that decriminalize formerly illicit conduct or reduce the punishment for acts that remain unlawful. No different rule applies to an affirmative defense to the crime for which a defendant was convicted, which defense was enacted during the pendency of his or her appeal. Since Health & Saf. Code, § 11362.5, contains no savings clause, it may operate retrospectively to defend against criminal liability, in whole or in part, for some who are appealing convictions for possessing, cultivating, and using marijuana. People v Trippet (1997, 1st Dist) 56 Cal App 4th 1532, 66 Cal Rptr 2d 559. Health & Saf. Code, § 1 1362.5 (Prop. 215; "Medical Use of Marijuana" initiative), provides a partial defense to charges of possession of marijuana, but not to charges of selling marijuana or possessing marijuana for sale. People ex rel. Lungren v Peron (1997, 1 st Dist) 59 Cal App 4th 1383, 70 Cal Rptr 2d 20. Although the sale and distribution of marijuana remain criminal offenses under Ilealth & Saf. Code, § 11360, bona fide primary caregivers, as defined by the "Medical Use of Marijuana" initiative (Prop. 215; Health & Saf. Code, § 1 1362.5), should not be precluded from receiving bona fide reimbursement for their actual expense of cultivating and furnishing marijuana for the patient's approved medical treatment. Consistently assuming responsibility for the housing, health, or safety of a patient does not preclude the caregiver from charging the patient for such services. However, Prop. 000051 Page 3 Cal Health & Saf Code § 11362.5 215 provides a defense for patients and primary caregivers only, to prosecution for two criminal offenses only: possession (Health & Saf. Code, § 11357), and cultivation (Health & Saf. Code, § 11358). People ex rel. Lungren v Peron (1997, 1st Dist) 59 Cal App 4th 1383, 70 Cal Rptr 2d 20. In sentencing a defendant who pleaded guilty to cultivating marijuana, the trial court properly imposed a probation condition prohibiting him from using or possessing marijuana, without providing an exception for medical use. Although the Compassionate Use Act included language indicating a broad purpose to provide for the medical use of marijuana and to exempt patients from criminal sanction (H & S C § 11362.5), these provisions could not be read so broadly as to abrogate the trial court's traditional discretion to impose appropriate conditions of probation. Here the condition at issue was directly related to defendant's criminal offense and was reasonably related to the goal of ensuring that he did not commit subsequent criminal offenses under state law. The Compassionate Use Act did not condone the diversion of marijuana use for nonmedical purposes and defendant had apparently done just that in the past. People v Bianco (2001, 3rd Dist) 93 Cal App 4th 748, 113 Cal Rptr 2d 392. Diabetic criminally accused of possession and cultivation of marijuana at advice of his physician was allowed to raise his status as qualified patient under Compassionate Use Act of 1996 to move for dismissal of indictment; H & S C § 11362.5(d) provided that H & S C § 11357, criminalizing the possession of marijuana, and H & S C § 11358, criminalizing the cultivation of marijuana, did not apply to a patient, or to a patient's primary caregiver, who possessed Or cultivated marijuana for medical purposes. People v Mower (2002) 28 Cal 4th 457, 122 Cal Rptr 2d 326, 49 P3d 1067. For a defendant to be able to avoid criminal prosecution or sanction pursuant to H & S C § I I362.5(b)(1)(B), when charged with possession or cultivation of marijuana in violation of II & S C § § 11357, 11358, he or she must be able to defend on the ground that these provisions do not apply because he or she is a qualified patient or primary caregiver under H & S C § I I362.5(d). People v Mower (2002) 28 Cal 4th 457, 122 Cal Rptr 2d 326, 49 P3d 1067. Probable cause depends on all of the surrounding facts, including those that reveal a person's status as a qualified patient or primary caregiver under 11 & S C § I I362.5(d). The requirement that law enforcement officers have probable cause for an arrest does not mean that § I I362.5(d) must be interpreted to grant such persons immunity from arrest. People v Mower (2002) 28 Cal 4th 457, 122 Cal Rptr 2d 326, 49 P3d 1067. H & S C § 11362.5(d) grants a defendant a limited immunity from prosecution, which not only allows a defense at trial, but also permits a motion to set aside an indictment or information prior to trial. People v Mower (2002) 28 Cal 4th 457, 122 Cal Rptr 2d 326, 49 P3d 1067. H & S C § I I362.5(d)'s grant of limited immunity from prosecution does not operate, as does that of Ins C § 12924(b), for reasons extrinsic to the criminality of the underlying conduct. Rather, it operates, in the manner of Pen C § 602(n), to render noncriminal certain conduct that otherwise would be criminal. People v Mower (2002) 28 Cal 4th 457, 122 Cal Rptr 2d 326, 49 P3d 1067. Transportation of marijuana allegedly used or to be used for medical purposes was not exempted from prosecution under Cal. Proposition 215, nor was a medical necessity defense created for those possessing marijuana who were not patients or their primary caregivers. People v Galambos (2002, 3rd Dist) 104 Cal App 4th 1147, 128 Cal Rptr 2d 844. Medical necessity defense is not the measure of the right to obtain marijuana for medical purposes granted by H & S C § 11362.5. People v Tilehkooh (2003, 3rd Dist) 113 Cal App 4th 1433. Defendant may assert H & S C § 11362.5 as a defense to the criminal sanction of revocation of his probation where there is no claim that his conduct endangered others or that he diverted marijuana for nonmedical purposes as set forth in H & S C § 11365.5, nor does a probation condition which prohibits the lawful use of a prescription drug serve a rehabilitative purpose. People v Tilehkooh (2003, 3rd Dist) 113 Cal App 4th 1433. Since the federal marijuana law is given effect only by its incorporation in the state law as a probation condition, it is subject to the state law defense of H & S C § 11362.5. People v Tilehkooh (2003, 3rd Dist) 113 Cal App 4th 1433. California courts do not enforce the federal marijuana possession laws when defendants prosecuted for marijuana possession have a qualified immunity under H & S C § 11362.5; similarly, California courts should not enforce federal marijuana law for probationers who qualify for the immunity provided by § 11362.5. People v Tilehkooh (2003, 3rd Dist) 113 Cal App 4th 1433. Where defendants pled guilty to the federal offense of maintaining a place for the manufacturing of marijuana after a police raid of a commercially- leased building led to the seizure of at least 1,245 rooted plants, and defendants sought a downward sentencing departure on the basis that their conduct was permissible under H & S C § 1 1362.5, no downward departure was warranted because § 11362.5 did not immunize large -scale growing operations intended to distribute marijuana. United States v Landa (2003, ND Cal) 281 F Supp 2d 1139. Where medical marijuana users and growers challenged the constitutionality of the Controlled Substances Act (CSA), 21 U.S.C.S. § § 801 et seq., they were entitled to a preliminary injunction because they demonstrated a strong 000052 Page 4 Cal Health & Saf Code § 11362.5 likelihood of success on their claim that, as applied to them, the CSA was an unconstitutional exercise of Congress' Commerce Clause, U.S. Const. art. 1, § 8, cl. 3, authority. Reich v Ashcroft (2003, CA9 Cal) 2003 US App LEXIS 25317. Conviction for cultivating marijuana was reversed because the jury was erroneously instructed that for a compassionate use defense, defendant had to prove that he was "seriously ill." The question of whether the medical use of marijuana was appropriate was a determination that was to be made by a physician and that was not to be second - guessed by jurors. People v Spark (2004, Cal App 5th Dist) 2004 Cal App LEXIS 1261. 2. Particular Applications In a prosecution in which defendant was convicted of transporting marijuana and possession of more than 28.5 grams of marijuana, remand for a limited retrial was required for the trial court to determine whether the Compassionate Use Act of 1996 (H & S C § 11362.5) (marijuana for medical purposes), which was enacted while defendant's appeal was pending, and which applied retroactively, provided her with a partial defense to either or both of the charges against her. First, H & S C § 11362.5(d), provides that H & S C § 11357, relating to the possession of marijuana, does not apply to a patient who possesses marijuana for the personal medical purposes of the patient upon the written or oral recommendation or approval of a physician. Although, defendant could not show that her physician "recommended" marijuana to her to treat her migraine headaches, the record was unclear as to whether or not any physician had "approved" defendant's use of marijuana. It was possible that, on retrial, defendant could show that the quantity of marijuana possessed, and the form and manner in which it was possessed, was reasonably related to her current medical needs. Second, Health & Saf. Code, § 11362.5, does not exempt the transportation of marijuana allegedly used or to be used for medical purposes from prosecution under Health & Saf. Code, § 11360. However, if the quantity transported and the method, timing, and distance of the transportation are reasonably related to the patient's current medical needs, there can be an implied defense to a Health & Saf. Code, § 11360, charge. In this case, there was a remote possibility that defendant could establish that the two pounds of marijuana she was transporting at the time of her arrest met this test. People v Trippet (1997, 1 st Dist) 56 Cal App 4th 1532, 66 Cal Rptr 2d 559. The trial court erred when it modified a preliminary injunction that prohibited certain individuals from selling and furnishing marijuana at a "Cannabis Buyers' Club" that was open to the public in a large city, so as to allow the individuals to engage in nonprofit marijuana sales under the "Medical Use of Marijuana" initiative (Prop. 215; Health & Saf. Code, § 11362.5). The sale and possession for sale of marijuana continue to be proscribed by Health & Saf. Code, § § 11360, subd. (a), and 11359, following enactment of Prop. 215, and the lack of profit to the seller does not exempt such activities from prosecution. The laws prohibiting the distribution of controlled substances, including marijuana, do not distinguish between sales and gifts. Although Prop. 215 allows patients to cultivate their own medicinal marijuana, the analysis and arguments contained in the ballot pamphlet indicate that the drafters were aware of both state and federal law prohibiting such sales and did not seek to overrule those laws. People ex rel. Lungren v Peron (1997, 1 st Dist) 59 Cal App 4th 1383, 70 Cal Rptr 2d 20. The trial court erred when it modified a preliminary injunction that prohibited certain individuals from selling and furnishing marijuana at a "Cannabis Buyers' Club" that was open to the public in a large city, so as to allow the individuals to sell marijuana to persons who had designated the individuals as their "primary caregivers" under the "Medical Use of Marijuana" initiative (Prop. 215; Health & Saf. Code, § 11362.5). The thousands of persons who patronized the club, and who designated the marijuana sellers in the club as "primary caregivers" at the time of sale, did not thereby confer that status on the sellers. Prop. 215 defines "primary caregiver" as an individual "who has consistently assumed responsibility for the housing, health, or safety" of a patient for whom medicinal marijuana has been prescribed (Health & Saf. Code, § 11362.5, subd. (e)). Even though an individual may be a "primary caregiver" to more than one patient, a person purchasing marijuana for medicinal purposes cannot designate seriatim, and on an ad hoc basis, drug sellers as "primary caregivers." Thus, the "consistency" of these sellers' purported primary carcgiving was a myth. People ex rel. Lungren v Peron (1997, 1 st Dist) 59 Cal App 4th 1383, 70 Cal Rptr 2d 20. Where defendant was arrested for cultivation of marijuana the day before the effective date of the Compassionate Use Act of 1996 (H & S C § 11362.5) and, over three months later, he obtained a doctor's approval on a written prescription form for medical use of marijuana, the trial court did not err in ruling that approval three months after the arrest did not bring the case within § 11362.5. People v Rigo (1999, 1st Dist) 69 Cal App 4th 409, 81 Cal Rptr 2d 624. Defendant was properly convicted of transporting 135.3 grams of marijuana in his car, despite the claim the trial court erred in failing to instruct the jury on mistake of fact because defendant believed he was entitled to transport marijuana under the Compassionate Use Act of 1996 (H & S C § 11362.5). The Act, which on its face exempted only possession and cultivation from criminal sanctions for qualifying patients, did not provide defendant with a defense to the charge of 000053 Page 5 Cal Health & Saf Code § 1 1362.5 transportation of marijuana; accordingly, defendant's assumption that this defense applied to him was an inexcusable mistake of law, not a mistake of fact. People v Young (2001, 3rd Dist) 92 Cal App 4th 229, 111 Cal Rptr 2d 726. Law enforcement officers were not required to abandon a search for marijuana authorized by a search warrant, even though a resident of the premises to be searched produced documents that suggested he had a physician's permission to possess the marijuana pursuant to the Compassionate Use Act of 1996 (H & S C § 11362.5(d)). Nowhere in § 11362.5 was any criminal offense defined. Subdivision (d) did no more than refer to the offenses already defined in H & S C § § 11357, 11358, and created an exception to their applicability. Since the exception provided by subdivision (d) did not constitute any part of the definition of the offenses described by § § 11357, 11358, the exception constituted an affirmative defense to be proven by the defendant at trial. People v Fisher (2002, 3rd Dist) 96 Cal App 4th 1147, 117 Cal Rptr 2d 838. Defendant's probation could not be revoked on the ground that he violated a condition of his probation by possessing marijuana, where defendant gave his probation officer a notarized physician's certificate, signed by a doctor, that recommended cannabis for defendant's medical condition, where a card with defendant's picture and signature identified him as a medical marijuana user, and where there was no claim that his conduct endangered others or that he diverted marijuana foe nonmedical purposes. People v Tilthkooh (2443, 3rd Dist) 113 Cal App 4th 1433. Ina probation revocation proceeding, the People may not evade H & S C § 11362.5 on the ground that a defendant violated a probation condition that he obey the federal marijuana laws. People v Tilehkooh (2003, 3rd Dist) 113 Cal App 4th 1433. H & S C § 11362,5 provides a "defense in court" in a probation revocation proceeding because if successful it would obviate any need for the criminal sanction of revocation. People v Tilehkooh (2003, 3rd Dist) 113 Cal App 4th 1433. H & S C § 11362.5 provides a defense to a probation revocation based on marijuana possession or use. People v Tilehkooh (2003, 3rd Dist) 113 Cal App 4th 1433. H & S C § 11362.5 applied to any illness for which marijuana provides relief. People v Tilehkooh (2003, 3rd Dist) 113 Cal App 4th 1433. Motion to reinstate a complaint for cultivating marijuana was properly heard and denied by the superior court. Applying the substantial evidence standard to the trial court's finding that defendant was cultivating marijuana for personal medical use, the court found that defendant had the requisite medical authorization and several back injuries that caused him severe pain, which was impervious to traditional pain medications; although his garden was extremely healthy and could have possibly yielded up to one pound of marijuana for each of 12 plants, his previous two efforts had yielded no more than two to three ounces per plant. People v Arbacauskas (2004, 3rd Dist) 123 Cal App 4th 502, mod (Cal App 3rd Dist) 2004 Cal App LEXIS 1942. Where defendant asserted the compassionate use of marijuana defense, the trial court accurately instructed the jury on the meaning of the term "primary caregiver" under H & S C § 11362.5(e) by using an instruction that tracked the statutory language. People v Frazier (2005, 3rd Dist) 128 Cal App 4th 807. Because a federal court would not have jurisdiction in forfeiture proceedings against the subject marijuana, the court therefore improperly issued a seizure warrant and the federal government was ordered to return the marijuana to state custody where a California court had ordered the marijuana returned to a petitioner who possessed it pursuant to H & S C § 11362,5. In re Seizure of Approximately 28 Grams of Marijuana (2003, ND Cal) 2003 US Dist LEXIS 14853. As California's statutory defense of medical necessity was inapplicable to the charges against petitioner (possession of marijuana while in prison), the exclusion of evidence in support of such defense did not violate petitioner's constitutional right to present a defense; H & S C § 11362.5, which provided a defense to the possession of marijuana based on medical necessity, did not apply to charges under Pen C § 4573.6. Taylor v Hamlet (2003, ND Cal) 2003 US Dist LEXIS 19451. In a case regarding whether petitioner doctor indiscriminately recommended the medicinal use of marijuana to one of his patients, where the Medical Board of California obtained an order from respondent, and the Superior Court of Los Angeles County (California), directed the doctor to comply with the administrative subpoena for the patient's records, the appellate court granted the doctor's petition for a writ of mandate and ordered the trial court to vacate its order enforcing the subpoena for the patient's medical records; Medical Board failed to demonstrate sufficient facts to support a finding of good cause to invade the patient's right of privacy in his medical records. Bearman v Superior Court (2004, Cal App 2nd Dist) 2004 Cal App LEXIS 438. By showing park rangers a letter stating that he possessed marijuana for personal medical purposes pursuant to 14 &S C § 1 1362.5, the patient did not waive his right to privacy in his medical records under Cal Const Art 1, § 1 ; if he had not produced the record he would have been detained or arrested, and interpreting H & S C § 1 1362.5 as necessitating waiver of the fundamental right to privacy in order to enjoy its protection would hinder the intent of the statute. Bearman v Superior Court (2004, Cal App 2nd Dist) 2004 Cal App LEXIS 438. 000054 Page 6 Cal Health & Saf Code § 11362.5 Trial court erred in precluding defendant from relying on the compassionate use defense; the Compassionate Use Act can provide a defense to the charge of transporting marijuana when there is reasonable doubt as to whether the transportation was reasonably related to the defendant's medical needs. People v Wright (2004, Cal App 4th Dist) 2004 Cal App LEXIS 1450. 3. Burden of Proof Physician gives his or her "approval" of a patient's marijuana use within the meaning of the Compassionate Use Act if the physician expresses to the patient a favorable opinion of marijuana use for treatment of the patient's illness. When a Compassionate Use Act defense is the subject of a pretrial hearing under Evi C § 402, the defendant need only produce evidence sufficient to raise a reasonable doubt on that element of the defense. People v Jones (2003, 3rd Dist) 112 Cal App 4th 341. To meet the requirements of H & S C § 11362.5, it is a defendant's burden to show that he or she was a patient or primary caregiver, that he or she possessed or cultivated the marijuana in question for the personal medical purposes of a patient, and that he or she did so on the recommendation or approval of a physician. People v Tilehkooh (2003, 3rd Dist) 113 Cal App 4th 1433. Where defendant asserted the compassionate use of marijuana defense under H & S C § 11362.5(d), the use of Cal. Jury Instructions Crim. No. 12.24.1 (2003 rev.) was proper because it correctly identified the facts required to establish the defense and stated that defendant had the burden of raising a reasonable doubt concerning the facts underlying the defense. People v Frazier (2005, 3rd Dist) 128 Cal App 4th 807. Defendant has the burden of proof when it comes to establishing the compassionate use defense; however, to prevail at trial he need only raise a reasonable doubt, and so long as he presents the trial court with sufficient evidence to satisfy this standard, then the defense should go to the jury to decide. A defendant need not prove he is seriously ill to invoke the Compassionate Use Act; the question of whether the medical use of marijuana is appropriate for a patient's illness is a determination to be made by a physician, and the physician's determination on this medical issue is not to be second - guessed by jurors who might not deem the patient's condition to be sufficiently "serious." People v Wright (2004, Cal App 4th Dist) 2004 Cal App LEXIS 1450. 4. Return of Seized Marijuana Motion to return a portion of seized marijuana was properly denied, even though the State conceded that the petitioner was a qualified patient and even though the State had dismissed charges against him in the interests of justice, because the amount of marijuana seized (4.5 pounds dried, 10 pounds drying, and 46 plants) confirmed that the petitioner was not in lawful possession. H & S C § § 11473.5 and 11475 required the destruction of the marijuana, destruction did not violate the Compassionate Use Act, and the court was without authority to return contraband to the individual from whom it was seized. Chavez v Superior Court (2004, 4th Dist) 123 Cal App 4th 104. 000055 EXHIBIT C Senate Sill No. 420 CHAPTER 875 An act to add Article 2.5 (commencing with Section 11362.7) to Chapter 6 of Division 10 of the Health and Safety Code, relating to controlled substances. IApproved by Governor October 12. 2003. Filed with Secretary of State October 12, 2003.1 LEGISL,\TIVF. COUNSEL'S DIGEST SB 420, Vasconcellos. Medical marijuana. Existing law, the Compassionate Use Act of 1996, prohibits any physician from being punished, or denied any right or privilege, for having recommended marijuana to a patient for medical purposes. The act prohibits the provisions of law making unlawful the possession or cultivation of marijuana from applying to a patient, or to a patient's primary caregiver, who possesses or cultivates marijuana for the personal medical purposes of the patient upon the written or oral recommendation or approval of a physician. This bill would require the State Department of Health Services to establish and maintain a voluntary program for the issuance of identification cards to qualified patients and would establish procedures under which a qualified patient with an identification card may use marijuana for medical purposes. The bill would specify the department's duties in this regard, including developing related protocols and forms, and establishing application and renewal fees for the program. The bill would impose various duties upon county health departments relating to the issuance of identification cards, thus creating a state - mandated local program. The bill would create various crimes related to the identification card program, thus imposing a state- mandated local program. This bill would authorize the Attorney General to set forth and clarify details concerning possession and cultivation limits, and other regulations, as specified. The bill would also authorize the Attorney General to recommend modifications to the possession or cultivation limits set forth in the bill. The bill would require the Attorney General to develop and adopt guidelines to ensure the security and nondiversion of marijuana grown for medical use, as specified. The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that 93 000056 Ch. 875 —2— reimbursement, including the creation of a State Mandates Claims Fund to pay the costs of mandates that do not exceed $1,000,000 statewide and other procedures for claims whose statewide costs exceed 51,000,000. This bill would provide that no reimbursement is required by this act for specified reasons. The people of the State of California do enact as follows: SECTION 1. (a) The Legislature finds and declares all of the following: (1) On November 6, 1996, the people of the State of California enacted the Compassionate Use Act of 1996 (hereafter the act), codified in Section 11362.5 of the Health and Safety Code, in order to allow seriously ill residents of the state, who have the oral or written approval or recommendation of a physician, to use marijuana for medical purposes without fear of criminal liability under Sections 11357 and 11358 of the Health and Safety Code. (2) However, reports from across the state have revealed problems and uncertainties in the act that have impeded the ability of law enforcement officers to enforce its provisions as the voters intended and, therefore, have prevented qualified patients and designated primary caregivers from obtaining the protections afforded by the act. (3) Furthermore, the enactment of this law, as well as other recent legislation dealing with pain control, demonstrates that more information is needed to assess the number of individuals across the state who are suffering from serious medical conditions that are not being adequately alleviated through the use of conventional medications. (4) In addition, the act called upon the state and the lederal government to develop a plan for the safe and affordable distribution of marijuana to all patients in medical need thereof. (b) It is the intent of the legislature, therefore, to do all of the following: (1) Clarifv the scope of the application of the act and facilitate the prompt identification of qualified patients and their designated primary caregivers in order to avoid unnecessary arrest and prosecution of these individuals and provide needed guidance to law enforcement officers. (2) Promote uniform and consistent application of the act among the counties within the state. (3) Enhance the access of patients and caregivers to medical marijuana through collective, cooperative cultivation projects. (c) It is also the intent of the Legislature to address additional issues that were not included within the act, and that must be resolved in order to promote the fair and orderly implementation of the act. 93 000057 -3— Ch. 875 (d) The Legislature further finds and declares both of the following: (1) A state identification card program will further the goals outlined in this section. (2) With respect to individuals, the identification system established pursuant to this act must be wholly voluntary, and a patient entitled to the protections of Section 11362.5 of the Health and Safety Code need not possess an identification card in order to claim the protections afforded by that section. (e) The Legislature further finds and declares that it enacts this act pursuant to the powers reserved to the State of California and its people under the Tenth Amendment to the United States Constitution. SEC. 2. Article 2.5 (commencing with Section 11362.7) is added to Chapter 6 of Division 10 of the Health and Safety Code, to read: Article 2.5. Medical Marijuana Program 11362.7. For purposes of this article, the following definitions shall apply: (a) "Attending physician" means an individual who possesses a license in good standing to practice medicine or osteopathy issued by the Medical Board of California or the Osteopathic Medical Board of California and who has taken responsibility for an aspect of the medical care, treatment, diagnosis, counseling, or referral of a patient and who has conducted a medical examination of that patient before recording in the patient's medical record the physician's assessment of whether the patient has a serious medical condition and whether the medical use of marijuana is appropriate. (b) "Department" means the State Department of Health Services. (e) "Person with an identification card" means an individual who is a qualified patient who has applied for and received a valid identification card pursuant to this article. (d) "Primary caregiver" means the individual, designated by a qualified patient or by a person with an identification card, who has consistently assumed responsibility for the housing, health, or safety of that patient or person, and may include any of the following: (1) In any case in which a qualified patient or person with an identification card receives medical care or supportive services, or both, from a clinic licensed pursuant to Chapter 1 (commencing with Section 1200) of Division 2, a health care facility licensed pursuant to Chapter 2 (commencing with Section 1250) of Division 2, a residential care facility for persons with chronic life- threatening illness licensed pursuant to Chapter 3.01 (commencing with Section 1568.01) of Division 2, a residential care facility for the elderly licensed pursuant to 93 Ch. 875 —4— Chapter 3.2 (commencing with Section 1569) of Division 2, a hospice, or a home health agency licensed pursuant to Chapter 8 (commencing with Section 1725) of Division 2, the owner or operator, or no more than three employees who are designated by the owner or operator, of the clinic, facility, hospice, or home health agency, if designated as a primary caregiver by that qualified patient or person with an identification card. (2) An individual who has been designated as a primary caregiver by more than one qualified patient or person with an identification card, if every qualified patient or person with an identification card who has designated that individual as a primary caregiver resides in the same city or county as the primary caregiver. (3) An individual who has been designated as a primary caregiver by a qualified patient or person with an identification card who resides in a city or county other than that of (lie primary caregiver, if the individual has not been designated as a primary caregiver by any other qualified patient or person with an identification card. (e) A primary caregiver shall be at least 18 years of age, unless the primary caregiver is the parent of a minor child who is a qualified patient or a person with an identification card or the primary caregiver is a person otherwise entitled to make medical decisions under state law pursuant to Sections 6922, 7002, 7050, or 7120 of the Family Code. (f) "Qualified patient" means a person who is entitled to the protections of Section 1] 362.5, but who does not have an identification card issued pursuant to this article. (g) "Identification card" means a document issued by the State Department of Health Services that document identifies a person authorized to engage in the medical use of marijuana and the person's designated primary caregiver, if any. (h) "Serious medical condition" means all of the following medical conditions: (1) Acquired immune deficiency syndrome (AIDS). (2) Anorexia. (3) Arthritis. (4) Cachexia. (5) Cancer. (6) Chronic pain. (7) Glaucoma. (8) Migraine. (9) Persistent muscle spasms, including, but not limited to, spasms associated with multiple sclerosis. (10) Seizures, including, but not limited to, seizures associated with epilepsy. 93 F 000059 -5— Ch. 875 (11) Severe nausea. (12) Any other chronic or persistent medical symptom that either: (A) Substantially limits the ability of the person to conduct one or more major life activities as defined in the Americans with Disabilities Act of 1990 (Public Law 101 -336). (B) If not alleviated, may cause serious harm to the patient's safety or physical or mental health. (i) "Written documentation" means accurate reproductions of those portions of a patient's medical records that have been created by the attending physician, that contain the information required by paragraph (2) of subdivision (a) of Section 11362.715, and that the patient may submit to a county health department or the county's designee as part of an application for an identification card. 11362.71. (a) (1) The department shall establish and maintain a voluntary program for the issuance of identification cards to qualified patients who satisfy the requirements of this article and voluntarily apply to the identification card program. (2) The department shall establish and maintain a 24 -hour, toll -free telephone number that will enable state and local law enforcement officers to have immediate access to information necessary to verify the validity of an identification card issued by the department, until a cost - effective Internet Web -based system can be developed for this purpose. (b) Every county health department, or the county's designee, shall do all of the following: (1) Provide applications upon request to individuals seeking to join the identification card program. (2) Receive and process completed applications in accordance with Section 11362.72. (3) Maintain records of identification card programs. (4) Utilize protocols developed by the department pursuant to paragraph (1) of subdivision (d). (5) Issue identification cards developed by the department to approved applicants and designated primary caregivers. (c) The county board of supervisors may designate another health- related governmental or nongovernmental entity or organization to perform the functions described in subdivision (b), except for an entity or organization that cultivates or distributes marijuana. (d) The department shall develop all of the following: (1) Protocols that shall be used by a county health department or the county's designee to implement the responsibilities described in subdivision (b), including, but not limited to, protocols to confirm the 93 Ch. 875 —6— accuracy of information contained in an application and to protect the confidentiality of program records. (2) Application forms that shall be issued to requesting applicants. (3) An identification card that identifies a person authorized to engage in the medical use of marijuana and an identification card that identifies the person's designated primary caregiver, if any. The two identification cards developed pursuant to this paragraph shall be easily distinguishable from each other. (e) No person or designated primary caregiver in possession of a valid identification card shall be subject to arrest for possession, transportation, delivery, or cultivation of medical marijuana in an amount established pursuant to this article, unless there is reasonable cause to believe that the information contained in the card is false or falsified, the card has been obtained by means of fraud, or the person is otherwise in violation of the provisions of this article. (f) It shall not be necessary for a person to obtain an identification card in order to claim the protections of Section 11362.5. 11362.715. (a) A person who seeks an identification card shall pay the fee, as provided in Section 11362.755, and provide all of the following to the county health department or the county's designee on a form developed and provided by the department: (1) The name of the person, and proof of his or her residency within the county. (2) Written documentation by the attending physician in the person's medical records stating that the person has been diagnosed with a serious medical condition and that the medical use of marijuana is appropriate. (3) The name, office address, office telephone number, and California medical license number of the person's attending physician. (4) The name and the duties of the primary caregiver. (5) A government- issued photo identification card of the person and of the designated primary caregiver, if any. If the applicant is a person under 18 years of' age, a certified copy of a birth certificate shall be deemed sufficient proof of identity. (b) If the person applying for an identification card lacks the capacity to make medical decisions, the application may be made by the person's legal representative, including, but not limited to, any of the following: (1) A conservator with authority to make medical decisions. (2) An attorney -in -fact under a durable power of attorney for health care or surrogate decisionmaker authorized tinder another advanced health care directive. (3) Any other individual authorized by statutory or decisional law to make medical decisions for the person. 93 000061 -7— Ch. 875 (c) The legal representative described in subdivision (b) may also designate in the application an individual, including himself or herself, to serve as a primary caregiver for the person, provided that the individual meets the definition of a primary caregiver. (d) The person or legal representative submitting the written information and documentation described in subdivision (a) shall retain a copy thereof. 1 1362.72. (a) Within 30 days of receipt of an application for an identification card, a county health department or the county's designee shall do all of the following: (1) For purposes of processing the application, verify that the information contained in the application is accurate. If the person is less than 18 years of age, the county health department or its designee shall also contact the parent with legal authority to make medical decisions, legal guardian, or other person or entity with legal authority to make medical decisions, to verify the information. (2) Verify with the Medical Board of California or the Osteopathic Medical Board of California that the attending physician has a license in good standing to practice medicine or osteopathy in the state. (3) Contact the attending physician by facsimile, telephone, or mail to confirm that the medical records submitted by the patient are a true and correct copy of those contained in the physician's office records. When contacted by a county health department or the county's designee, the attending physician shall confirm or deny that the contents of the medical records are accurate. (4) Take a photograph or otherwise obtain an electronically transmissible image of the applicant and of the designated primary caregiver, if any. (5) Approve or deny the application. If an applicant who meets the requirements of Section 11362.715 can establish that an identification card is needed on an emergency basis, the county or its designee shall issue a temporary identification card that shall be valid for 30 days from the date of issuance. The county, or its designee, may extend the temporary identification card for no more than 30 days at a time, so long as the applicant continues to meet the requirements of this paragraph. (b) If the county health department or the county's designee approves the application, it shall, within 24 hours, or by the end of the next working day of approving the application, electronically transmit the following information to the department: (1) A unique user identification number of the applicant. (2) The date of expiration of the identification card. (3) The name and telephone number of the county health department or the county's designee that has approved the application. 93 000062 Ch. 875 —8— (c) The county health department or the county's designee shall issue an identification card to the applicant and to his or her designated primary caregiver, if any, within five working days of approving the application. (d) In any case involving an incomplete application, the applicant shall assume responsibility for rectifying the deficiency. The county shall have 14 days from the receipt of information from the applicant pursuant to this subdivision to approve or deny the application. 11362.735. (a) An identification card issued by the county health department shall be serially numbered and shall contain all of the following. (1) A unique user identification number of the cardholder. (2) The date of expiration of the identification card. (3) The name and telephone number of the county health department or the county's designee that has approved the application. (4) A 24 -hour, toll -free telephone number, to be maintained by the department, that will enable state and local law enfomemem officers to have immediate access to information necessary to verify the validity of the card. (5) Photo identification of the cardholder. (b) A separate identification card shall be issued to the person's designated primary caregiver, if any, and shall include a photo identification of the caregiver. 11362.74. (a) The county health department or the county's designee may deny an application only for any of the following reasons: (1) The applicant did not provide the information required by Section 11362.715, and upon notice of the deficiency pursuant to subdivision (d) of Section 11362.72, did not provide the information within 30 days. (2) The county health department or the county's designee determines that the information provided was false. (3) The applicant does not meet the criteria set forth in this article. (b) Any person whose application has been denied pursuant to subdivision (a) may not reapply for six months from the date of denial unless otherwise authorized by the county health department or the county's designee or by a court of competent jurisdiction. (c) Any person whose application has been denied pursuant to subdivision (a) may appeal that decision to the department. The county health department or the county's designee shall make available a telephone number or address to which the denied applicant can direct an appeal. 11362.745. (a) An identification card shall be valid for a period of one year. 93 000063 Ch. 875 (b) Upon annual renewal of an identification card, the county health department or its designee shall verify all new information and may verify any other information that has not changed. (c) The county health department or the county's designee shall transmit its determination of approval or denial of a renewal to the department. 11362.755. (a) The department shall establish application and renewal fees for persons seeking to obtain or renew identification cards that are sufficient to cover the expenses incurred by the department, including the startup cost, the cost of reduced fees for Medi -Cal beneficiaries in accordance with subdivision (b), the cost of identifying and developing a cost - effective Internet Web -based system, and the cost of maintaining the 24 -hour toll -free telephone number. Each county health department or the county's designee may charge an additional fee for all costs incurred by the county or the county's designee for administering the program pursuant to this article. (b) Upon satisfactory proof of participation and eligibility in the Medi -Cal program, a Medi -Cal beneficiary shall receive a 50 percent reduction in the fees established pursuant to this section. 11362.76. (a) A person who possesses an identification card shall: (1) Within seven days, notify the county health department or the county's designee of any change in the person's attending physician or designated primary caregiver, if any. (2) Annually submit to the county health department or the county's designee the following: (A) Updated written documentation of the person's serious medical condition. (B) The name and duties of the person's designated primary caregiver, if any, for the forthcoming year. (b) If a person who possesses an identification card fails to comply with this section, the card shall be deemed expired. If an identification card expires, the identification card of any designated primary caregiver of the person shall also expire. (c) If the designated primary caregiver has been changed, the previous primary caregiver shall return his or her identification card to the department or to the county health department or the county's designee. (d) If the owner or operator or an employee of the owner or operator of a provider has been designated as a primary caregiver pursuant to paragraph (1) of subdivision (d) of Section 11362.7, of the qualified patient or person with an identification card, the owner or operator shall notify the county health department or the county's designee, pursuant 93 • • Ch. 875 _10— to Section 11362.715, if a change in the designated primary caregiver has occurred. 11362.765. (a) Subject to the requirements of this article, the individuals specified in subdivision (b) shall not be subject, on that sole basis, to criminal liability under Section 11357, 11358, 11359, 11360, 11366, 11366.5, or 11570. However, nothing in this section shall authorize the individual to smoke or otherwise consume marijuana unless otherwise authorized by this article, nor shall anything in this section authorize any individual or group to cultivate or distribute marijuana for profit. (b) Subdivision (a) shall apply to all of the following: (1) A qualified patient or a person with an identification card who transports or processes marijuana for his or her own personal medical use. (2) A designated primary caregiver who transports, processes, administers, delivers, or gives away marijuana for medical purposes, in amounts not exceeding those established in subdivision (a) of Section 11362.77, only to the qualified patient of the primary caregiver, or to the person with an identification card who has designated the individual as a primary caregiver. (3) Any individual who provides assistance to a qualified patient or a person with an identification card, or his or her designated primary caregiver, in administering medical marijuana to the qualified patient or person or acquiring the skills necessary to cultivate or administer marijuana for medical purposes to the qualified patient or person. (c) A primary caregiver who receives compensation for actual expenses, including reasonable compensation incurred for services provided to an eligible qualified patient or person with an identification card to enable that person to use marijuana under this article, or for payment for out -of- pocket expenses incurred in providing those services, or both, shall not, on the sole basis of that fact, be subject to prosecution or punishment under Section 11359 or 11360. 11362.77. (a) A qualified patient or primary caregiver may possess no more than eight ounces of dried marijuana per qualified patient. In addition, a qualified patient or primary caregiver may also maintain no more than six mature or 12 irnmaturc marijuana plants per qualified patient. (b) If a qualified patient or primary caregiver has a doctor's recommendation that this quantity does not meet the qualified patient's medical needs, the qualified patient or primary caregiver may possess an amount of marijuana consistent with the patient's needs. 93 F 000065 11 — Ch. 875 (c) Counties and cities may retain or enact medical marijuana guidelines allowing qualified patients or primary caregivers to exceed the state limits set forth in subdivision (a). (d) Only the dried mature processed flowers of female cannabis plant or the plant conversion shall be considered when determining allowable quantities of marijuana under this section. (e) The Attorney General may recommend modifications to the possession or cultivation limits set forth in this section. These recommendations, if any, shall be made to the Legislature no later than December 1, 2005, and may be made only after public comment and consultation with interested organizations, including, but not limited to, patients, health care professionals, researchers, law enforcement, and local governments. Any recommended modification shall be consistent with the intent of this article and shall be based on currently available scientific research. (f) A qualified patient or a person holding a valid identification card, or the designated primary caregiver of that qualified patient or person, may possess amounts of marijuana consistent with this article. 11362.775. Qualified patients, persons with valid identification cards, and the designated primary caregivers of qualified patients and persons with identification cards, who associate within the State of California in order collectively or cooperatively to cultivate marijuana for medical purposes, shall not solely on the basis of that fact be subject to state criminal sanctions under Section 11357, 11358, 11359, 11360, 1 1366, 11366.5, or 11570. 11362.78. A state or local law enforcement agency or officer shall not refuse to accept an identification card issued by the department unless the state or local law enforcement agency or officer has reasonable cause to believe that the information contained in the card is false or fraudulent, or the card is being used fraudulently. 11362.785. (a) Nothing in this article shall require any accornmodation of any medical use of marijuana on the property or premises of any place of employment or during the hours of employment or on the property or premises of any jail, correctional facility, or other type of penal institution in which prisoners reside or persons under arrest are detained. (b) Notwithstanding subdivision (a), a person shall not be prohibited or prevented from obtaining and submitting the written information and documentation necessary to apply for an identification card on the basis that the person is incarcerated in a jail, correctional facility, or other penal institution in which prisoners reside or persons under arrest are detained. 93 Ch. 875 —12— (c) Nothing in this article shall prohibit a jail, correctional facility, or other penal institution in which prisoners reside or persons under arrest are detained, from permitting a prisoner or a person under arrest who has an identification card, to use marijuana for medical purposes under circumstances that will not endanger the health or safety of other prisoners or the security of the facility. (d) Nothing in this article shall require a governmental, private, or any other health insurance provider or health care service plan to be liable for any claim for reimbursement for the medical use of marijuana. 11362.79. Nothing in this article shall authorize a qualified patient or person with an identification card to engage in the smoking of medical marijuana under any of the following circumstances: (a) In any place where smoking is prohibited by law. (b) In or within 1,000 feet of the grounds of a school, recreation center, or youth center, unless the medical use occur% within a residence. (c) On a schoolbus. (d) While in a motor vehicle that is being operated. (e) While operating a boat. 11362.795. (a) (1) Any criminal defendant who is eligible to use marijuana pursuant to Section 11362.5 may request that the court confirm that he or she is allowed to use medical marijuana while he or she is on probation or released on bail. (2) The court's decision and the reasons for the decision shall be stated on the record and an entry stating those reasons shall be made in the minutes of the court. (3) During the period of probation or release on bail, if a physician recommends that the probationer or defendant use medical marijuana, the probationer or defendant may request a modification of the conditions of probation or bail to authorize the use of medical marijuana. (4) The court's consideration of the modification request authorized by this subdivision shall comply with the requirements of this section. (b) (1) Any person who is to be released on parole from a jail, state prison, school, road camp, or other state or local institution of confinement and who is eligible to use medical marijuana pursuant to Section 11362.5 may request that he or she be allowed to use medical marijuana during the period he or she is released on parole. A parolee's written conditions of parole shall reflect whether or not a request for a modification of the conditions of his or her parole to use medical marijuana was made, and whether the request was granted or denied. (2) During the period of the parole, where a physician recommends that the parolee use medical marijuana, the parolee may request a modification of the conditions of the parole to authorize the use of medical marijuana. 93 F 000067 13— Ch. 875 (3) Any parolee whose request to use medical marijuana while on parole was denied may pursue an administrative appeal of the decision. Any decision on the appeal shall be in writing and shall reflect the reasons for the decision. (4) The administrative consideration of the modification request authorized by this subdivision shall comply with the requirements of this section. 11362.8. No professional licensing board may impose a civil penalty or take other disciplinary action against a licensee based solely on the fact that the licensee has performed acts that are necessary or appropriate to carry out the licensee's role as a designated primary caregiver to a person who is a qualified patient or who possesses a lawful identification card issued pursuant to Section 11362.72. However, this section shall not apply to acts performed by a physician relating to the discussion or recommendation of the medical use of marijuana to a patient. These discussions or recommendations, or both, shall be governed by Section 11362.5. 11362.81. (a) A person specified in subdivision (b) shall be subject to the following penalties: (1) For the first offense, imprisonment in the county jail for no more than six months or a fine not to exceed one thousand dollars ($1,000), or both. (2) For a second or subsequent offense, imprisonment in the county jail for no more than one year, or a fine not to exceed one thousand dollars ($1,000), or both. (b) Subdivision (a) applies to any of the following: (1) A person who fraudulently represents a medical condition or fraudulently provides any material misinformation to a physician, county health department or the county's designee, or state or local law enforcement agency or officer, for the purpose of falsely obtaining an identification card. (2) A person who steals or fraudulently uses any person's identification card in order to acquire, possess, cultivate, transport, use, produce, or distribute marijuana. (3) A person who counterfeits, tampers with, or fraudulently produces an identification card. (4) A person who breaches the confidentiality requirements of this article to information provided to, or contained in the records of, the department or of a county health department or the county's designee pertaining to an identification card program. (c) In addition to the penalties prescribed in subdivision (a), any person described in subdivision (b) may be precluded from attempting 93 F �III.4b Ch. 875 —14 to obtain, or obtaining or using, an identification card for a period of up to six months at the discretion of the court. (d) In addition to the requirements of this article, the Attorney General shall develop and adopt appropriate guidelines to ensure the security and nondiversion of marijuana grown for medical use by patients qualified under the Compassionate Use Act of 1996. 11362.82. If any section, subdivision, sentence, clause, phrase, or portion of this article is for any reason held invalid or unconstitutional by any court of competent jurisdiction, that portion shall be deemed a separate, distinct, and independent provision, and that holding shall not affect the validity of the remaining portion thereof. 11362.83. Nothing in this article shall prevent a city or other local governing body from adopting and enforcing laws consistent with this article. SEC. 3. No reimbursement is required by this act pursuant to Section 6 of Article XIII B of the California Constitution for certain costs that may be incurred by a local agency or school district because in that regard this act creates a new crime or infraction, eliminates a crime or infraction, or changes the penalty for a crime or infraction. within the meaning of Section 17556 of the Government Code, or changes the definition of a crime within the meaning of Section 6 of Article XIII B of the California Constitution. In addition, no reimbursement is required by this act pursuant to Section 6 of Article XIII B of the California Constitution for other costs mandated by the state because this act includes additional revenue that is specifically intended to fund the costs of' the state mandate in an amount sufficient to fund the cost of the state mandate, within the meaning of Section 17556 of the Government Code. U 93 F • J EXHIBIT D LEXSEE 2005 U.S. LEXIS 4656 ALBERTO R. GONZALES, ATTORNEY GENERAL, ET AL., PETITIONERS v. ANGEL MCCLARY RAICH ET AL. No. 03 -1454 SUPREME COURT OF THE UNITED STATES 2005 U.S. LEXIS 4656 November 29, 2004, Argued June 6, 2005, Decided NOTICE: [' I ] This preliminary LEXIS version is unedited and subject to revision. The LEXIS pagination of this document is subject to change pending release of the final published version. PRIOR HISTORY: ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT. DISPOSITION: 352 F.3d 1222, vacated and remanded. SYLLABUS: California's Compassionate Use Act authorizes limited marijuana use for medicinal purposes. Respondents Raich and Monson are California residents who both use doctor - recommended marijuana for serious medical conditions. After federal Drug Enforcement Administration (DEA) agents seized and destroyed all six of Monson's cannabis plants, respondents brought this action seeking injunctive and declaratory relief prohibiting the enforcement of the federal Controlled Substances Act (CSA) to the extent it prevents them from possessing, obtaining, or manufacturing cannabis for their personal medical use. Respondents claim that enforcing [ "2] the CSA against them would violate the Commerce Clause and other constitutional provisions. The District Court denied respondents' motion for a preliminary injunction, but the Ninth Circuit reversed, finding that they had demonstrated a strong likelihood of success on the claim that the CSA is an unconstitutional exercise of Congress' Commerce Clause authority as applied to the intrastate, noncommercial cultivation and possession of cannabis for personal medical purposes as recommended by a patient's physician pursuant to valid California state law. Tlie court relied heavily on United States v. Lopez, 514 U.S. 549, and United Stares v. Morrison, 529 U.S. 598, to hold that this separate class of purely local activities was beyond the reach of federal power. Held: Congress' Commerce Clause authority includes the power to prohibit the local cultivation and use of marijuana in compliance with California law. Pp. 6 -31. (a) For the purposes of consolidating various drug laws into a comprehensive statute, providing meaningful regulation over legitimate sources of drugs to prevent diversion into illegal channels, and strengthening law ['31 enforcement tools against international and interstate drug trafficking, Congress enacted the Comprehensive Drug Abuse Prevention and Control Act of 1970, Title II of which is the CSA. To effectuate the statutory goals, Congress devised a closed regulatory system making it unlawful to manufacture, distribute, dispense, or possess any controlled substance except as authorized by the CSA. 21 U.S.C. § § 841(a)(] ), 844(a). All controlled substances are classified into five schedules, § 812, based on their accepted medical uses, their potential for abuse, and their psychological and physical effects on the body, § § 811, 812. Marijuana is classified as a Schedule 1 substance, § 812(c), based on its high potential for abuse, no accepted medical use, and no accepted safety for use in medically supervised treatment, § 812(b)(I ). This CADocumcnts and Sell ings\Poner- S \Dcsklop \Gonzales v. Raich doc \111-111 �1 Page 2 2005 U.S. LEXIS 4656, * classification renders the manufacture, distribution, or possession of marijuana a criminal offense. § § 841(a)() ), 844(a). Pp. 6 -11. (b) Congress' power to regulate purely local activities that are part of an economic "class of activities" that have a substantial effect on interstate commerce is firmly established. See, e.g., Perez v. United States, 402 U.S. 146, 151. [ *41 If Congress decides that the "'total incidence "' of a practice poses a threat to a national market, it may regulate the entire class, See, e.g., id., at 154 -155. Of particular relevance here is Wickard v. Filburn, 317 U.S. 111, 127 -128, where, in rejecting the appellee farmer's contention that Congress' admitted power to regulate the production of wheat for commerce did not authorize federal regulation of wheat production intended wholly for the appellee's own consumption, the Court established that Congress can regulate purely intrastate activity that is not itself "commercial," i.e., not produced for sale, if it concludes that failure to regulate that class of activity would undercut the regulation of the interstate market in that commodity. The similarities between this case and Wickard are striking. In both cases, the regulation is squarely within Congress' commerce power because production of the commodity meant for home consumption, be it wheat or marijuana, has a substantial effect on supply and demand in the national market for that commodity. In assessing the scope of Congress' Commerce Clause authority, the Court need not determine [ *51 whether respondents' activities, taken in the aggregate, substantially affect interstate commerce in fact, but only whether a "rational basis" exists for so concluding. E.g., Lopez, 514 U.S., at 557. Given the enforcement difficulties that attend distinguishing between marijuana cultivated locally and marijuana grown elsewhere, 21 U.S.C. § 801(5), and concerns about diversion into illicit channels, the Court has no difficulty concluding that Congress had a rational basis for believing that failure to regulate the intrastate manufacture and possession of marijuana would leave a gaping hole in the CSA. Pp. 12 -20. (c) Respondents' heavy reliance on Lopez and Morrison overlooks the larger context of modern -era Commerce Clause jurisprudence preserved by those cases, while also reading those cases far too broadly. The statutory challenges at issue there were markedly different from the challenge here. Respondents ask the Court to excise individual applications of a concededly valid comprehensive statutory scheme. In contrast, in both Lopez and Morrison, the parties asserted that a particular statute or provision fell outside Congress' [ *61 commerce power in its entirety. This distinction is pivotal for the Court has often reiterated that "where the class of activities is regulated and that class is within the reach of federal power, the courts have no power 'to excise, as trivial, individual instances' of the class." Perez, 402 U.S., at 154. Moreover, the Court emphasized that the laws at issue in Lopez and Morrison had nothing to do with "commerce" or any sort of economic enterprise. See Lopez, 514 U.S., at 561; Morrison, 529 U.S., at 610. In contrast, the CSA regulates quintessentially economic activities: the production, distribution, and consumption of commodities for which there is an established, and lucrative, interstate market. Prohibiting the intrastate possession or manufacture of an article of commerce is a rational means of regulating commerce in that product. The Ninth Circuit cast doubt on the CSA's constitutionality by isolating a distinct class of activities that it held to be beyond the reach of federal power: the intrastate, noncommercial cultivation, possession, and use of marijuana for personal medical purposes on the advice of a physician [ *71 and in accordance with state law. However, Congress clearly acted rationally in determining that this subdivided class of activities is an essential part of the larger regulatory scheme. The case comes down to the claim that a locally cultivated product that is used domestically rather than sold on the open market is not subject to federal regulation. Given the CSA's findings and the undisputed magnitude of the commercial market for marijuana, Wickard and its progeny foreclose that claim. Pp. 20 -30. 352 F.3d 1222, vacated and remanded. JUDGES: STEVENS, J., delivered the opinion of the Court, in which KENNEDY, SOUTER, GINSBURG, and BREYER, JJ., joined. SCALIA, J., filed an opinion concurring in the judgment. O'CONNOR, J., filed a dissenting opinion, in which REHNQUIST, C. J., and THOMAS, J., joined as to all but Part 111. THOMAS, J., filed a dissenting opinion. OPINIONBY: STEVENS OPINION: JUSTICE STEVENS delivered the opinion of the Court. CADocuments and SettingslPorter- S1Desktop \Gonzales v. Reich doe 000071 Page 3 2005 U.S. LEXIS 4656, * California is one of at least nine States that authorize the use of marijuana for medicinal purposes. nl The question presented in this case is whether the power vested in Congress by Article I, § 8, of the Constitution "to make all Laws [ *8] which shall be necessary and proper for carrying into Execution" its authority to "regulate Commerce with foreign Nations, and among the several States" includes the power to prohibit the local cultivation and use of marijuana in compliance with California law. nl See Alaska Stat. § § 11.71.090, 17.37.010- 17.37.080 (Lexis 2004); Colo. Const., Art. XVIII, § 14, Colo, Rev, Stat. § 18- 18406.3 (Lexis 2004); Haw. Rev. Stat. § § 329 -121 to 329 -128 (2004 Cum. Supp.); Me. Rev. Stat. Ann., Tit. 22, § 2383 -B(5) (West 2004); Nev. Const., Art. 4, § 38, Nev. Rev. Stat. § § 453A.010- 453A.810 (2003); Ore. Rev. Stat. § § 475.300- 475.346 (2003); Vt. Stat. Ann., Tit. 18, § § 447244744 (Supp. 2004); Wash. Rev. Code § § 69.51.010- 69.51.080 (2004); see also Ariz. Rev. Stat. Ann. § 13- 3412.01 (West Supp. 2004) (voter initiative permitting physicians to prescribe Schedule I substances for medical purposes that was purportedly repealed in 1997, but the repeal was rejected by voters in 1998). In November 2004, Montana voters approved Initiative 148, adding to the number of States authorizing the use of marijuana for medical purposes. [ *9j California has been a pioneer in the regulation of marijuana. In 1913, California was one of the first States to prohibit the sale and possession of marijuana, n2 and at the end of the century, California became the first State to authorize limited use of the drug for medicinal purposes. In 1996, California voters passed Proposition 215, now codified as the Compassionate Use Act of 1996. n3 The proposition was designed to ensure that "seriously ill" residents of the State have access to marijuana for medical purposes, and to encourage Federal and State Governments to take steps towards ensuring the safe and affordable distribution of the drug to patients in need. n4 The Act creates an exemption from criminal prosecution for physicians, n5 as well as for patients and primary caregivers who possess or cultivate marijuana for medicinal purposes with the recommendation or approval of a physician. n6 A "primary caregiver" is a person who has consistently assumed responsibility for the housing, health, or safety of the patient. n7 n2 1913 Cal. Stats. ch. 324, § 8a; see also Gieringer, The Origins of Cannabis Prohibition in California, Contemporary Drug Problems, 21 -23 (rev. 2005). [*101 n3 Cal. Health & Safety Code Ann. § 11362.5 (West Supp. 2005). The California Legislature recently enacted additional legislation supplementing the Compassionate Use Act. § § 11362.7-11362.9 (West Supp. 2005). n4 "The people of the State of California hereby find and declare that the purposes of the Compassionate Use Act of 1996 are as follows: "(A) To ensure that seriously ill Californians have the right to obtain and use marijuana for medical purposes where that medical use is deemed appropriate and has been recommended by a physician who has determined that the person's health would benefit from the use of marijuana in the treatment of cancer, anorexia, AIDS, chronic pain, spasticity, glaucoma, arthritis, migraine, or any other illness for which marijuana provides relief. "(B) To ensure that patients and their primary caregivers who obtain and use marijuana for medical purposes upon the recommendation of a physician are not subject to criminal prosecution or sanction. "(C) To encourage the federal and state governments to implement a plan to provide for the safe and affordable distribution of marijuana to all patients in medical need of marijuana." § 1 I362.5(b)(1) (West Supp. 2005). [ *11] C'13oeuments and SettingskPorter- S\Desktopkoon7eles Y. Raich.doc 0000'72 Page 4 2005 U.S. LEX1S 4656,' n5 "Notwithstanding any other provision of law, no physician in this state shall be punished, or denied any right or privilege, for having recommended marijuana to a patient for medical purposes." § 11362.5(c) (West Supp. 2005). n6 "Section 11357, relating to the possession of marijuana, and Section 11358, relating to the cultivation of marijuana, shall not apply to a patient, or to a patient's primary caregiver, who possesses or cultivates marijuana for the personal medical purposes of the patient upon the written or oral recommendation or approval of a physician." § I I362.5(d) (West Supp. 2005). n7§ 11362.5(e) (West Supp. 2005). Respondents Angel Raich and Diane Monson are California residents who suffer from a variety of serious medical conditions and have sought to avail themselves of medical marijuana pursuant to the terms of the Compassionate Use Act. They are being treated by licensed, board - certified family practitioners, who have concluded, after prescribing a host of conventional medicines to treat respondents' conditions and to alleviate their associated symptoms, that [• 121 marijuana is the only drug available that provides effective treatment. Both women have been using marijuana as a medication for several years pursuant to their doctors' recommendation, and both rely heavily on cannabis to function on a daily basis. Indeed, Raich's physician believes that forgoing cannabis treatments would certainly cause Raich excruciating pain and could very well prove fatal. Respondent Monson cultivates her own marijuana, and ingests the drug in a variety of ways including smoking and using a vaporizer. Respondent Raich, by contrast, is unable to cultivate her own, and thus relies on two caregivers, litigating as "John Does," to provide her with locally grown marijuana at no charge. These caregivers also process the cannabis into hashish or keif, and Raich herself processes some of the marijuana into oils, balms, and foods for consumption. On August 15, 2002, county deputy sheriffs and agents from the federal Drug Enforcement Administration (DEA) came to Monson's home. After a thorough investigation, the county officials concluded that her use of marijuana was entirely lawful as a matter of California law. Nevertheless, after a 3 -hour standoff, the federal agents ['13] seized and destroyed all six of her cannabis plants. Respondents thereafter brought this action against the Attorney General of the United States and the head of the DEA seeking injunctive and declaratory relief prohibiting the enforcement of the federal Controlled Substances Act (CSA), 84 Stat. 1242, 21 U.S.C. § 801 et seq., to the extent it prevents them from possessing, obtaining, or manufacturing cannabis for their personal medical use. In their complaint and supporting affidavits, Raich and Monson described the severity of their afflictions, their repeatedly futile attempts to obtain relief with conventional medications, and the opinions of their doctors concerning their need to use marijuana. Respondents claimed that enforcing the CSA against them would violate the Commerce Clause, the Due Process Clause of the Fifth Amendment, the Ninth and Tenth Amendments of the Constitution, and the doctrine of medical necessity. The District Court denied respondents' motion for a preliminary injunction. Raich v. Ashcroft, 248 F. Supp. 2d 918 (ND Cal. 2003). Although the court found that the federal enforcement interests "waned" when compared [' 14] to the harm that California residents would suffer if denied access to medically necessary marijuana, it concluded that respondents could not demonstrate a likelihood of success on the merits of their legal claims. Id., at 931. A divided panel of the Court of Appeals for the Ninth Circuit reversed and ordered the District Court to enter a preliminary injunction. n8 Raich v. Ashcroft, 352 F.3d 1222 (2003). The court found that respondents had "demonstrated a strong likelihood of success on their claim that, as applied to them, the CSA is an unconstitutional exercise of Congress' Commerce Clause authority." Id., at 1227. "The Court of Appeals distinguished prior Circuit cases upholding the CSA in the face of Commerce Clause challenges by focusing on what it deemed to be the "separate and distinct class of activities" at issue in this case: "the intrastate, noncommercial cultivation and possession of cannabis for personal medical purposes as recommended by a patient's physician pursuant to valid California state law." Id., at 1228. The court found the latter class of activities "different in kind from drug trafficking" [' 151 because interposing a physician's recommendation raises different health and safety concerns, and because "this limited use is clearly distinct from the broader illicit drug market -- as well as any broader commercial market for medicinal marijuana -- insofar as the medicinal marijuana at issue in this case is not intended for, nor does it enter, the stream of commerce." Ibid. CADocuments and Settings\Porter -S \Desktop \Gonzales v Raich doc 0000'73 Page 5 2005 U.S. LEXIS 4656, • n8 On remand, the District Court entered a preliminary injunction enjoining petitioners "'from arresting or prosecuting Plaintiffs Angel McClary Raich and Diane Monson, seizing their medical cannabis, forfeiting their property, or seeking civil or administrative sanctions against them with respect to the intrastate, non - commercial cultivation, possession, use, and obtaining without charge of cannabis for personal medical purposes on the advice of a physician and in accordance with state law, and which is not used for distribution, sale, or exchange. "' Brief for Petitioners 9. The majority placed heavy reliance on our decisions in United States v. Lopez, 514 U.S. 549 (1995), [' 161 and United States v. Morrison, 529 U.S. 598 (2000), as interpreted by recent Circuit precedent, to hold that this separate class of purely local activities was beyond the reach of federal power. In contrast, the dissenting judge concluded that the CSA, as applied to respondents, was clearly valid under Lopez and Morrison; moreover, he thought it "simply impossible to distinguish the relevant conduct surrounding the cultivation and use of the marijuana crop at issue in this case from the cultivation and use of the wheat crop that affected interstate commerce in Wickard v. Filburn." 352 F.3d at 1235 (Beam, J., dissenting) (citation omitted). The obvious importance of the case prompted our grant of certiorari. 542 U.S. 936 (2004). The case is made difficult by respondents' strong arguments that they will suffer irreparable harm because, despite a congressional finding to the contrary, marijuana does have valid therapeutic purposes. The question before us, however, is not whether it is wise to enforce the statute in these circumstances; rather, it is whether Congress' power to regulate interstate markets for medicinal substances [• 171 encompasses the portions of those markets that are supplied with drugs produced and consumed locally. Well- settled law controls our answer. The CSA is a valid exercise of federal power, even as applied to the troubling facts of this case. We accordingly vacate the judgment of the Court of Appeals. 11 Shortly after taking office in 1969, President Nixon declared a national "war on drugs." n9 As the first campaign of that war, Congress set out to enact legislation that would consolidate various drug laws on the books into a comprehensive statute, provide meaningful regulation over legitimate sources of drugs to prevent diversion into illegal channels, and strengthen law enforcement tools against the traffic in illicit drugs. n10 That effort culminated in the passage of the Comprehensive Drug Abuse Prevention and Control Act of 1970, 84 Stat. 1236. n9 See D. Musto & P. Korsmeyer, The Quest for Drug Control 60 (2002) (hereinafter Musto & Korsmeyer). n10 H. R. Rep, No. 91 -1444, pt. 2, p. 22 (1970) (hereinafter H. R. Rep.); 26 Congressional Quarterly Almanac 531 (1970) (hereinafter Almanac); Musto & Korsmeyer 56 -57. •18 This was not, however, Congress' first attempt to regulate the national market in drugs. Rather, as early as 1906 Congress enacted federal legislation imposing labeling regulations on medications and prohibiting the manufacture or shipment of any adulterated or misbranded drug traveling in interstate commerce. n I I Aside from these labeling restrictions, most domestic drug regulations prior to 1970 generally came in the guise of revenue laws, with the Department of the Treasury serving as the Federal Government's primary enforcer. nl2 For example, the primary drug control law, before being repealed by the passage of the CSA, was the Harrison Narcotics Act of 1914, 38 Stat. 785 (repealed 1970). The Harrison Act sought to exert control over the possession and sale of narcotics, specifically cocaine and opiates, by requiring producers, distributors, and purchasers to register with the Federal Government, by assessing taxes against parties so registered, and by regulating the issuance of prescriptions. n13 n 1 1 Pure Food and Drug Act of 1906, ch. 3915, 34 Stat. 768, repealed by Act of June 25, 1938, ch. 675, § 902(a), 52 Stat. 1059. ["191 CADocuments and Settings \Porter -S \Desktop \Gonzales v Raich.doc 0000'74 Page 6 2005 U.S. LEXIS 4656,' n12 See United States Y. Doremus, 249 U.S. 86 (1919); Leary v. United States, 395 U.S. 6, 14 -16 (1969). n 13 See Doremus, 249 U.S., at 90 -93. Marijuana itself was not significantly regulated by the Federal Government until 1937 when accounts of marijuana's addictive qualities and physiological effects, paired with dissatisfaction with enforcement efforts at state and local levels, prompted Congress to pass the Marihuana Tax Act, Pub. L. 75 -238, 50 Stat. 551 (repealed 1970). n14 Like the Harrison Act, the Marihuana "Tax Act did not outlaw the possession or sale of marijuana outright. Rather, it imposed registration and reporting requirements for all individuals importing, producing, selling, or dealing in marijuana, and required the payment of annual taxes in addition to transfer taxes whenever the drug changed hands, n 15 Moreover, doctors wishing to prescribe marijuana for medical purposes were required to comply with rather burdensome administrative requirements. nl6 Noncompliance exposed traffickers to severe federal penalties, whereas ['20] compliance would often subject them to prosecution under state law, n17 Thus, while the Marihuana Tax Act did not declare the drug illegal per se, the onerous administrative requirements, the prohibitively expensive taxes, and the risks attendant on compliance practically curtailed the marijuana trade. n14 R. Bonnie & C. Whitebread, The Marijuana Conviction 154 -174 (1999); L. Grinspoon & J. Bakalar, Marihuana, the Forbidden Medicine 7 -8 (rev. ed. 1997) (hereinafter Grinspoon & Bakalar). Although this was the Federal Government's first attempt to regulate the marijuana trade, by this time all States had in place some form of legislation regulating the sale, use, or possession of marijuana. R. Isralowitz, Drug Use, Policy, and Management 134 (2d ed. 2002). n15 Leary, 395 U.S., at 14 -16. n16 Grinspoon & Bakalar 8. n17 Leary, 395 U.S., at 16 -18. Then in 1970, after declaration of the national "war on drugs," federal drug policy underwent a significant transformation. ['21 ] A number of noteworthy events precipitated this policy shift. First, in Leary v. United States, 395 U.S. 6 (1969), this Court held certain provisions of the Marihuana Tax Act and other narcotics legislation unconstitutional. Second, at the end of his term, President Johnson fundamentally reorganized the federal drug control agencies. The Bureau of Narcotics, then housed in the Department of Treasury, merged with the Bureau of Drug Abuse Control, then housed in the Department of Health, Education, and Welfare (HEW), to create the Bureau of Narcotics and Dangerous Drugs, currently housed in the Department of Justice. n18 Finally, prompted by a perceived need to consolidate the growing number of piecemeal drug laws and to enhance federal drug enforcement powers, Congress enacted the Comprehensive Drug Abuse Prevention and Control Act. n19 nl8 Musto & Korsmeyer 32 -35; 26 Almanac 533. In 1973, the Bureau of Narcotics and Dangerous Drugs became the Drug Enforcement Administration (DEA). See Reorg. Plan No. 2 of 1973, § I, 28 CFR § 0.100 (1973). n19 The Comprehensive Drug Abuse Prevention and Control Act of 1970 consists of three titles. Title I relates to the prevention and treatment of narcotic addicts through HEW (now the Department of Health and Iluman Services). 84 Stat. 1238. Title 11, as discussed in more detail above, addresses drug control and enforcement as administered by the Attorney General and the DEA. Id., at 1242. Title III concerns the import and export of controlled substances. Id., at 1285. '22 Title Il of that Act, the CSA, repealed most of the earlier antidrug laws in favor of a comprehensive regime to combat the international and interstate traffic in illicit drugs. The main objectives of the CSA were to conquer drug abuse and to control the legitimate and illegitimate traffic in controlled substances, n20 Congress was particularly concerned with the need to prevent the diversion of drugs from legitimate to illicit channels. n21 C.UOcuments and SettmgsToner- S Desk top\Gonzales v. Raich.doc 000075 Page 7 2005 U.S. LEX1S 4656, * n20 In particular, Congress made the following findings: "(1) Many of the drugs included within this subchapter have a useful and legitimate medical purpose and are necessary to maintain the health and general welfare of the American people. "(2) The illegal importation, manufacture, distribution, and possession and improper use of controlled substances have a substantial and detrimental effect on the health and general welfare of the American people. "(3) A major portion of the traffic in controlled substances flows through interstate and foreign commerce. Incidents of the traffic which are not an integral part of the interstate or foreign flow, such as manufacture, local distribution, and possession, nonetheless have a substantial and direct effect upon interstate commerce because - "(A) after manufacture, many controlled substances are transported in interstate commerce, "(B) controlled substances distributed locally usually have been transported in interstate commerce immediately before their distribution, and "(C) controlled substances possessed commonly flow through interstate commerce immediately prior to such possession. "(4) Local distribution and possession of controlled substances contribute to swelling the interstate traffic in such substances. "(5) Controlled substances manufactured and distributed intrastate cannot be differentiated from controlled substances manufactured and distributed interstate. Thus, it is not feasible to distinguish, in terms of controls, between controlled substances manufactured and distributed interstate and controlled substances manufactured and distributed intrastate. "(6) Federal control of the intrastate incidents of the traffic in controlled substances is essential to the effective control of the interstate incidents of such traffic." 21 U.S.C. § § 801(1) -(6). [ *231 n21 See United States v. Moore, 423 U.S. 122, 135 (1975); see also H. R. Rep., at 22. To effectuate these goals, Congress devised a closed regulatory system making it unlawful to manufacture, distribute, dispense, or possess any controlled substance except in a manner authorized by the CSA. 21 U.S.C. § § 841(a)(1), 844(a). The CSA categorizes all controlled substances into five schedules. § 812. The drugs are grouped together based on their accepted medical uses, the potential for abuse, and their psychological and physical effects on the body. § § 811, 812. Each schedule is associated with a distinct set of controls regarding the manufacture, distribution, and use of the substances listed therein. § § 821 -830. The CSA and its implementing regulations set forth strict requirements regarding registration, labeling and packaging, production quotas, drug security, and recordkeeping. /bid. 21 CFR § 1301 et seq. (2004). In enacting the CSA, Congress classified marijuana as a Schedule 1 drug. 21 U.S.C. § 812(c). This preliminary [ *241 classification was based, in part, on the recommendation of the Assistant Secretary of HEW "that marihuana be retained within schedule 1 at least until the completion of certain studies now underway." n22 Schedule 1 drugs are categorized as such because of their high potential for abuse, lack of any accepted medical use, and absence of any accepted safety for use in medically supervised treatment. § 812(b)(I). These three factors, in varying gradations, are also used to categorize drugs in the other four schedules. For example, Schedule 11 substances also have a high potential for abuse which may lead to severe psychological or physical dependence, but unlike Schedule I drugs, they have a currently accepted medical use. § 812(b)(2). By classifying marijuana as a Schedule I drug, as opposed to listing it on a lesser schedule, the manufacture, distribution, or possession of marijuana became a criminal offense, with the sole exception being use of the drug as part of a Food and Drug Administration pre - approved research study. § § 823(f), 841(a)(1), 844(a); see also United States v. Oakland Cannabis Buyers' Cooperative, 532 U.S. 483, 490 (2001). C:\Documents and Settings \Porter -S \Desktop \Gonzales Y. Raich.doc 0000'76 Page 8 2005 U.S. LEXIS 4656,' n22 H. R. Rep., at 61 (quoting letter from Roger E. Egeberg, M. D. to Hon. Harley O. Staggers (Aug. 14, 1970)). 1'251 The CSA provides for the periodic updating of schedules and delegates authority to the Attorney General, after consultation with the Secretary of Health and Human Services, to add, remove, or transfer substances to, from, or between schedules. § 81 1. Despite considerable efforts to reschedule marijuana, it remains a Schedule I drug. n23 n23 Starting in 1972, the National Organization for the Reform of Marijuana Laws (NORML) began its campaign to reclassify marijuana. Grinspoon & Bakalar 13 -17. After some fleeting success in 1988 when an Administrative Law Judge (ALJ) declared that the DEA would be acting in an "unreasonable, arbitrary, and capricious" manner if it continued to deny marijuana access to seriously ill patients, and concluded that it should be reclassified as a Schedule IIl substance, Grinspoon v. DEA, 828 F.2d 881, 883 -884 (CAI 1987), the campaign has proved unsuccessful. The DEA Administrator did not endorse the ALJ's findings, 54 Fed. Reg. 53767 (1989), and since that time has routinely denied petitions to reschedule the drug, most recently in 2001. 66 Fed. Reg. 20038 (2001). The Court of Appeals for the District of Columbia Circuit has reviewed the petition to reschedule marijuana on five separate occasions over the course of 30 years, ultimately upholding the Administrator's final order. See Alliance for Cannabis Therapeutics v. DEA, 15 F.3d 1131, 1133 (1994). '261 111 Respondents in this case do not dispute that passage of the CSA, as part of the Comprehensive Drug Abuse Prevention and Control Act, was well within Congress' commerce power. Brief for Respondents 22, 38. Nor do they contend that any provision or section of the CSA amounts to an unconstitutional exercise of congressional authority. Rather, respondents' challenge is actually quite limited; they argue that the CSA's categorical prohibition of the manufacture and possession of marijuana as applied to the intrastate manufacture and possession of marijuana for medical purposes pursuant to California law exceeds Congress' authority under the Commerce Clause. In assessing the validity of congressional regulation, none of our Commerce Clause cases can be viewed in isolation. As charted in considerable detail in United Slates v. Lopez, our understanding of the reach of the Commerce Clause, as well as Congress' assertion of authority thereunder, has evolved over time. n24 The Commerce Clause emerged as the Framers' response to the central problem giving rise to the Constitution itself. the absence of any federal commerce power under the Articles of Confederation. n25 For the first ['271 century of our history, the primary use of the Clause was to preclude the kind of discriminatory state legislation that had once been permissible. n26 Then, in response to rapid industrial development and an increasingly interdependent national economy, Congress "ushered in a new era of federal regulation under the commerce power," beginning with the enactment of the Interstate Commerce Act in 1887, 24 Stat. 379, and the Sherman Antitrust Act in 1890, 26 Stat. 209, as amended, 15 U.S.C. § 2 et seq. n27 n24 United States v. Lopez, 514 U.S. 549, 552 -558 (1995); id., at 568 -574 (KENNEDY, J., concurring); id., at 604 -607 (SOUTER, J., dissenting). n25 See Gibbons v. Ogden, 9 Wheat. 1, 224 (1824) (opinion of Johnson, J.); Stern, That Commerce Which Concerns More States Than One, 47 Harv. L. Rev. 1335, 1337, 1340 -1341 (1934); G. Gunther, Constitutional Law 127 (9th ed. 1975). n26 See Lopez, 514 U.S., at 553 -554; id., at 568 -569 (KENNEDY, J., concurring); see also Granholm v. Heald, 544 U.S. _, _, (2005) (slip op., at 8 -9). 1 *28] n27 Lopez, 514 U.S., at 554; see also Wickard v. Filburn, 317 U.S. 1 11, 121 (1942) ( "It was not until 1887, with the enactment of the Interstate Commerce Act, that the interstate commerce power began to exert positive influence in American law and life. This first important federal resort to the commerce power was followed in CADocumenis and SettingslPorter- S1Desklop\Gonzales v Raich.doc 00007 Page 9 2005 U.S. LEXIS 4656, * 1890 by the Sherman Anti -Trust Act and, thereafter, mainly after 1903, by many others. These statutes ushered in new phases of adjudication, which required the Court to approach the interpretation of the Commerce Clause in the light of an actual exercise by Congress of its power thereunder" (footnotes omitted)). Cases decided during that "new era," which now spans more than a century, have identified three general categories of regulation in which Congress is authorized to engage under its commerce power. First, Congress can regulate the channels of interstate commerce. Perez v. United Stales, 402 U.S. 146, 150 (1971). Second, Congress has authority to regulate and protect the instrumentalities of interstate commerce, [ *29] and persons or things in interstate commerce. Ibid. Third, Congress has the power to regulate activities that substantially affect interstate commerce. Ibid.; NLRB v. Jones & Laughlin Steel Corp., 301 U.S. 1, 37 (1937). Only the third category is implicated in the case at hand. Our case law firmly establishes Congress' power to regulate purely local activities that are part of an economic "class of activities" that have a substantial effect on interstate commerce. See, e.g., Perez, 402 U.S., at 151; Wickard v. Filburn, 317 U.S. 111, 128 -129 (1942). As we stated in Wickard, "even if appellee's activity be local and though it may not be regarded as commerce, it may still, whatever its nature, be reached by Congress if it exerts a substantial economic effect on interstate commerce." Id., at 125. We have never required Congress to legislate with scientific exactitude. When Congress decides that the "'total incidence "' of a practice poses a threat to a national market, it may regulate the entire class. See Perez, 402 U.S., at 154 -155 (quoting Westfall v. United States, 274 U.S. 256, 259 (1927) [ *30] ( "When it is necessary in order to prevent an evil to make the law embrace more than the precise thing to be prevented it may do so ")). In this vein, we have reiterated that when "'a general regulatory statute bears a substantial relation to commerce, the de minimis character of individual instances arising under that statute is of no consequence. "' E.g., Lopez, 514 U.S., at 558 (emphasis deleted) (quoting Maryland v. Wirtz, 392 U.S. 183, 196, n. 27 (1968)). Our decision in Wickard, 317 U.S. 111, is of particular relevance. In Wickard, we upheld the application of regulations promulgated under the Agricultural Adjustment Act of 1938, 52 Stat. 31, which were designed to control the volume of wheat moving in interstate and foreign commerce in order to avoid surpluses and consequent abnormally low prices. The regulations established an allotment of 11.1 acres for Filburn's 1941 wheat crop, but he sowed 23 acres, intending to use the excess by consuming it on his own farm. Filburn argued that even though we had sustained Congress' power to regulate the production of goods for commerce, that power did not authorize "federal 1*31 ] regulation [of) production not intended in any part for commerce but wholly for consumption on the farm." Wickard, 317 U.S., at 118. Justice Jackson's opinion for a unanimous Court rejected this submission. He wrote: "The effect of the statute before us is to restrict the amount which may be produced for market and the extent as well to which one may forestall resort to the market by producing to meet his own needs. That appellee's own contribution to the demand for wheat may be trivial by itself is not enough to remove him from the scope of federal regulation where, as here, his contribution, taken together with that of many others similarly situated, is far from trivial." Id., at 127 -128. Wickard thus establishes that Congress can regulate purely intrastate activity that is not itself "commercial," in that it is not produced for sale, if it concludes that failure to regulate that class of activity would undercut the regulation of the interstate market in that commodity. The similarities between this case and Wickard are striking. Like the farmer in Wickard, respondents are cultivating, for home consumption, a fungible [ *32] commodity for which there is an established, albeit illegal, interstate market. n28 Just as the Agricultural Adjustment Act was designed "to control the volume [of wheat] moving in interstate and foreign commerce in order to avoid surpluses ... " and consequently control the market price, id., at 115, a primary purpose of the CSA is to control the supply and demand of controlled substances in both lawful and unlawful drug markets. See nn. 20 -21, supra. In Wickard, we had no difficulty concluding that Congress had a rational basis for believing that, when viewed in the aggregate, leaving home - consumed wheat outside the regulatory scheme would have a substantial influence on price and market conditions. Here too, Congress had a rational basis for concluding that leaving home - consumed marijuana outside federal control would similarly affect price and market conditions. n28 Even respondents acknowledge the existence of an illicit market in marijuana; indeed, Raich has personally participated in that market, and Monson expresses a willingness to do so in the future. App. 59, 74, C:1Documents and Settings \Porter- S�Desktop\Gonzeles v. Raich doc Page 10 2005 U.S. LEXIS 4656, * 87. See also Department of Revenue of Mont. v. Kurth Ranch, 511 U.S. 767, 770, 774, n. 12, and 780, n. 17 (1994) (discussing the "market value" of marijuana); id., at 790 (REHNQUIST, C. J., dissenting); id, at 792 (O'CONNOR, J., dissenting); Whalen v. Roe, 429 U.S. 589, 591 (1977) (addressing prescription drugs "for which there is both a lawful and an unlawful market "); Turner v. United States, 396 U.S. 398, 417, n. 33 (1970) (referring to the purchase of drugs on the "retail market "). *33 More concretely, one concern prompting inclusion of wheat grown for home consumption in the 1938 Act was that rising market prices could draw such wheat into the interstate market, resulting in lower market prices. Wickard, 317 U.S., at 128. The parallel concern making it appropriate to include marijuana grown for home consumption in the CSA is the likelihood that the high demand in the interstate market will draw such marijuana into that market. While the diversion of homegrown wheat tended to frustrate the federal interest in stabilizing prices by regulating the volume of commercial transactions in the interstate market, the diversion of homegrown marijuana tends to frustrate the federal interest in eliminating commercial transactions in the interstate market in their entirety. In both cases, the regulation is squarely within Congress' commerce power because production of the commodity meant for home consumption, be it wheat or marijuana, has a substantial effect on supply and demand in the national market for that commodity. n29 n29 To be sure, the wheat market is a lawful market that Congress sought to protect and stabilize, whereas the marijuana market is an unlawful market that Congress sought to eradicate. This difference, however, is of no constitutional import. It has long been settled that Congress' power to regulate commerce includes the power to prohibit commerce in a particular commodity. Lopez, 514 U.S., at 571 (KENNEDY, J., concurring) ( "In the Lottery Case, 188 U.S. 321 (1903), the Court rejected the argument that Congress lacked [the] power to prohibit the interstate movement of lottery tickets because it had power only to regulate, not to prohibit "), see also Wickard, 317 U.S., at 128 ( "The stimulation of commerce is a use of the regulatory function quite as definitely as prohibitions or restrictions thereon "). [ *34] Nonetheless, respondents suggest that Wickard differs from this case in three respects: (I ) the Agricultural Adjustment Act, unlike the CSA, exempted small farming operations; (2) Wickard involved a "quintessential economic activity" -- a commercial farm -- whereas respondents do not sell marijuana; and (3) the Wickard record made it clear that the aggregate production of wheat for use on farms had a significant impact on market prices. Those differences, though factually accurate, do not diminish the precedential force of this Court's reasoning. The fact that Wickard's own impact on the market was "trivial by itself " was not a sufficient reason for removing him from the scope of federal regulation. 317 U.S., at 127. That the Secretary of Agriculture elected to exempt even smaller farms from regulation does not speak to his power to regulate all those whose aggregated production was significant, nor did that fact play any role in the Court's analysis. Moreover, even though Wickard was indeed a commercial farmer, the activity he was engaged in -- the cultivation of wheat for home consumption -- was not treated by the Court as part of his commercial farming [ *35] operation. n30 And while it is true that the record in the Wickard case itself established the causal connection between the production for local use and the national market, we have before us findings by Congress to the same effect. n30 See Wickard, 317 U.S., at 125 (recognizing that Wickard's activity "may not be regarded as commerce "). Findings in the introductory sections of the CSA explain why Congress deemed it appropriate to encompass local activities within the scope of the CSA. See n. 20, supra. The submissions of the parties and the numerous amici all seem to agree that the national, and international, market for marijuana has dimensions that are fully comparable to those defining the class of activities regulated by the Secretary pursuant to the 1938 statute. n31 Respondents nonetheless insist that the CSA cannot be constitutionally applied to their activities because Congress did not make a specific finding that the intrastate cultivation and possession of marijuana for [ 436] medical purposes based on the recommendation of a physician would substantially affect the larger interstate marijuana market. Be that as it may, we CADocuments and Settings \Poner•S \tksktop \Canzales v Raich doe 0000'79 Page I I 2005 U.S. LEXIS 4656,'° have never required Congress to make particularized findings in order to legislate, see Lopez, 514 U.S., at 562; Perez, 402 U.S., at 156, absent a special concern such as the protection of free speech, see, e.g., Turner Broadcasting System, Inc. v. FCC, 512 U.S. 622, 664 -668 (1994) (plurality opinion). While congressional findings are certainly helpful in reviewing the substance of a congressional statutory scheme, particularly when the connection to commerce is not self- evident, and while we will consider congressional findings in our analysis when they are available, the absence of particularized findings does not call into question Congress' authority to legislate. n32 n31 The Executive Office of the President has estimated that in 2000 American users spent S 10.5 billion on the purchase of marijuana. Office of Nat. Drug Control Policy, Marijuana Fact Sheet 5 (Feb. 2004), available at http: / /www.whitehousedrugpoIicy.gov/ publications /factsht/marijuana/index.htmI (all Internet materials as visited June 2, 2005, and available in Clerk of Court's case file). [`37] n32 Moreover, as discussed in more detail above, Congress did make findings regarding the effects of intrastate drug activity on interstate commerce. See n. 20, supra. Indeed, even the Court of Appeals found that those findings "weighed in favor" of upholding the constitutionality of the CSA. 352 F.3d 1222, 1232 (CA9 2003) (case below). The dissenters, however, would impose a new and heightened burden on Congress (unless the litigants can garner evidence sufficient to cure Congress' perceived "inadequacies ") -- that legislation must contain detailed findings proving that each activity regulated within a comprehensive statute is essential to the statutory scheme. Post, at 13 -15 (O'CONNOR, 1., dissenting); post, at 8 (THOMAS, J., dissenting). Such an exacting requirement is not only unprecedented, it is also impractical. Indeed, the principal dissent's critique of Congress for "not even" including "declarations" specific to marijuana is particularly unpersuasive given that the CSA initially identified 80 other substances subject to regulation as Schedule I drugs, not to mention those categorized in Schedules 11 -V. Post, at 14 (O'CONNOR, J., dissenting). Surely, Congress cannot be expected (and certainly should not be required) to include specific findings on each and every substance contained therein in order to satisfy the dissenters' unfounded skepticism. "38 In assessing the scope of Congress' authority under the Commerce Clause, we stress that the task before us is a modest one. We need not determine whether respondents' activities, taken in the aggregate, substantially affect interstate commerce in fact, but only whether a "rational basis" exists for so concluding. Lopez, 514 U.S., at 557; see also Hodel v. Yrrgrnia Surface Mining & Reclamation Assn., Inc., 452 U.S. 264, 276 -280 (1981); Perez, 402 U.S., at 155 -156; Katzenbach v. McClung, 379 U.S. 294, 299 -301 (1964); Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241, 252 -253 (1964). Given the enforcement difficulties that attend distinguishing between marijuana cultivated locally and marijuana grown elsewhere, 21 U.S.C. § 801(5), and concerns about diversion into illicit channels, n33 we have no difficulty concluding that Congress had a rational basis for believing that failure to regulate the intrastate manufacture and possession of marijuana would leave a gaping hole in the CSA. Thus, as in Wickard, when it enacted comprehensive legislation to regulate ['39] the interstate market in a fungible commodity, Congress was acting well within its authority to "make all Laws which shall be necessary and proper" to "regulate Commerce ... among the several States." U.S. Const., Art. 1, § 8. That the regulation ensnares some purely intrastate activity is of no moment. As we have done many times before, we refuse to excise individual components of that larger scheme. n33 See n. 21, supra (citing sources that evince Congress' particular concern with the diversion of drugs from legitimate to illicit channels). 1V To support their contrary submission, respondents rely heavily on two of our more recent Commerce Clause cases. In their myopic focus, they overlook the larger context of modern-era Commerce Clause jurisprudence preserved by those cases. Moreover, even in the narrow prism of respondents' creation, they read those cases far too broadly. Those two cases, of course, are Lopez, 514 U.S. 549, and Morrison, 529 U.S. 598. As an initial 1'40] matter, the statutory challenges at issue in those cases were markedly different from the challenge respondents pursue in the case at hand. CADocuments and Settings \Porter -S \Desktop \Gonzales v. Raich.doc Page 12 2005 U.S. LEX1S 4656, Ilere, respondents ask us to excise individual applications of a concededly valid statutory scheme. In contrast, in both Lopez and Morrison, the parties asserted that a particular statute or provision fell outside Congress' commerce power in its entirety. This distinction is pivotal for we have often reiterated that "where the class of activities is regulated and that class is within the reach of federal power, the courts have no power 'to excise, as trivial, individual instances' of the class." Perez, 402 U.S., at 154 (emphasis deleted) (quoting Wirtz, 392 U.S., at 193); see also Hodel, 452 U.S., at 308. At issue in Lopez, 514 U.S. 549, was the validity of the Gun -Free School Zones Act of 1990, which was a brief, single- subject statute making it a crime for an individual to possess a gun in a school zone. 104 Stat. 48444845, 18 U.S.C. § 922(q)(1)(A). The Act did not regulate any economic activity and did not contain any requirement that the possession [•41 ] of a gun have any connection to past interstate activity or a predictable impact on future commercial activity. Distinguishing our earlier cases holding that comprehensive regulatory statutes may be validly applied to local conduct that does not, when viewed in isolation, have a significant impact on interstate commerce, we held the statute invalid. We explained: "Section 922(q) is a criminal statute that by its terms has nothing to do with 'commerce' or any sort of economic enterprise, however broadly one might define those terms. Section 922(q) is not an essential pan of a larger regulation of economic activity, in which the regulatory scheme could be undercut unless the intrastate activity were regulated. It cannot, therefore, be sustained under our cases upholding regulations of activities that arise out of or are connected with a commercial transaction, which viewed in the aggregate, substantially affects interstate commerce." 514 U.S., at 561. The statutory scheme that the Government is defending in this litigation is at the opposite end of the regulatory spectrum. As explained above, the CSA, enacted in 1970 as part of the Comprehensive Drug Abuse Prevention ['42] and Control Act, 84 Stat. 1242 -1284, was a lengthy and detailed statute creating a comprehensive framework for regulating the production, distribution, and possession of five classes of "controlled substances." Most of those substances -- those listed in Schedules 11 through V -- "have a useful and legitimate medical purpose and are necessary to maintain the health and general welfare of the American people." 21 U.S.C. § 801(1). The regulatory scheme is designed to foster the beneficial use of those medications, to prevent their misuse, and to prohibit entirely the possession or use of substances listed in Schedule 1, except as a part of a strictly controlled research project. While the statute provided for the periodic updating of the five schedules, Congress itself made the initial classifications. It identified 42 opiates, 22 opium derivatives, and 17 hallucinogenic substances as Schedule I drugs. 84 Stat. 1248. Marijuana was listed as the I Oth item in the third subcategory. That classification, unlike the discrete prohibition established by the Gun -Free School Zones Act of 1990, was merely one of many "essential parts of a larger regulation of economic activity, [043] in which the regulatory scheme could be undercut unless the intrastate activity were regulated." Lopez, 514 U.S., at 561. n34 Our opinion in Lopez casts no doubt on the validity of such a program. n34 The principal dissent asserts that by "seizing upon our language in Lopez," post, at 5 (opinion of O'CONNOR, J.), i.e., giving effect to our well- established case law, Congress will now have an incentive to legislate broadly. Even putting aside the political checks that would generally curb Congress' power to enact a broad and comprehensive scheme for the purpose of targeting purely local activity, there is no suggestion that the CSA constitutes the type of "evasive" legislation the dissent fears, nor could such an argument plausibly be made. Post, at 6 (O'CONNOR, J., dissenting). Nor does this Court's holding in Morrison, 529 U.S. 598. The Violence Against Women Act of 1994, 108 Stat. 1902, created a federal civil remedy for the victims of gender - motivated [*44] crimes of violence. 42 U.S.C. § 13981. The remedy was enforceable in both state and federal courts, and generally depended on proof of the violation of a state law. Despite congressional findings that such crimes had an adverse impact on interstate commerce, we held the statute unconstitutional because, like the statute in Lopez, it did not regulate economic activity. We concluded that "the noneconomic, criminal nature of the conduct at issue was central to our decision" in Lopez, and that our prior cases had identified a clear pattern of analysis: "'Where economic activity substantially affects interstate commerce, legislation regulating that activity will be sustained. "' n35 Morrison, 529 U.S., at 610. CADocuments and Servings \Porter -S \Desktop \Gonzales v. Raich.doc Page 13 2005 U.S. LEXIS 4656,' n35 Lopez, 514 U.S., at 560; see also id., at 573 -574 (KENNEDY, J., concurring) (stating that Lopez did not alter our "practical conception of commercial regulation" and that Congress may "regulate in the commercial sphere on the assumption that we have a single market and a unified purpose to build a stable national economy "). ['45] Unlike those at issue in Lopez and Morrison, the activities regulated by the CSA are quintessentially economic. "Economics" refers to "the production, distribution, and consumption of commodities." Webster's Third New International Dictionary 720 (1966). The CSA is a statute that regulates the production, distribution, and consumption of commodities for which there is an established, and lucrative, interstate market. Prohibiting the intrastate possession or manufacture of an article of commerce is a rational (and commonly utilized) means of regulating commerce in that product, n36 Such prohibitions include specific decisions requiring that a drug be withdrawn from the market as a result of the failure to comply with regulatory requirements as well as decisions excluding Schedule 1 drugs entirely from the market. Because the CSA is a statute that directly regulates economic, commercial activity, our opinion in Morrison casts no doubt on its constitutionality. n36 See 16 U.S.C. § 668(a) (bald and golden eagles); 18 U.S.C. § 175(a) (biological weapons); § 83l(a) (nuclear material); § 842(n)(1) (certain plastic explosives); § 2342(a) (contraband cigarettes). •46 The Court of Appeals was able to conclude otherwise only by isolating a "separate and distinct" class of activities that it held to be beyond the reach of federal power, defined as "the intrastate, noncommercial cultivation, possession and use of marijuana for personal medical purposes on the advice of a physician and in accordance with state law." 352 F.3d at 1229. The court characterized this class as "different in kind from drug trafficking." Id., at 1228. The differences between the members of a class so defined and the principal traffickers in Schedule I substances might be sufficient to justify a policy decision exempting the narrower class from the coverage of the CSA. The question, however, is whether Congress' contrary policy judgment, i.e., its decision to include this narrower "class of activities" within the larger regulatory scheme, was constitutionally deficient. We have no difficulty concluding that Congress acted rationally in determining that none of the characteristics making up the purported class, whether viewed individually or in the aggregate, compelled an exemption from the CSA; rather, the subdivided class of activities defined [•471 by the Court of Appeals was an essential part of the larger regulatory scheme. First, the fact that marijuana is used "for personal medical purposes on the advice of a physician" cannot itself serve as a distinguishing factor. 352 F.3d at 1229. The CSA designates marijuana as contraband for any purpose; in fact, by characterizing marijuana as a Schedule I drug, Congress expressly found that the drug has no acceptable medical uses. Moreover, the CSA is a comprehensive regulatory regime specifically designed to regulate which controlled substances can be utilized for medicinal purposes, and in what manner. Indeed, most of the substances classified in the CSA "have a useful and legitimate medical purpose." 21 U.S.C. § 801(1). Thus, even if respondents are correct that marijuana does have accepted medical uses and thus should be redesignated as a lesser schedule drug, n37 the CSA would still impose controls beyond what is required by California law. The CSA requires manufacturers, physicians, pharmacies, and other handlers of controlled substances to comply with statutory and regulatory provisions mandating registration with the DEA, compliance ['48] with specific production quotas, security controls to guard against diversion, recordkeeping and reporting obligations, and prescription requirements. See 21 U.S.C. § § 821 -830; 21 CFR § 1301 et seq. (2004). Furthermore, the dispensing of new drugs, even when doctors approve their use, must await federal approval. United States v. Rutherford, 442 U.S. 544 (1979). Accordingly, the mere fact that marijuana -- like virtually every other controlled substance regulated by the CSA -- is used for medicinal purposes cannot possibly serve to distinguish it from the core activities regulated by the CSA. n37 We acknowledge that evidence proffered by respondents in this case regarding the effective medical uses for marijuana, if found credible after trial, would cast serious doubt on the accuracy of the findings that require marijuana to be listed in Schedule 1. See, e.g., Institute of Medicine, Marijuana and Medicine: Assessing the Science Base 179 (J. Joy, S. Watson, & J. Benson eds. 1999) (recognizing that "scientific data indicate the potential therapeutic value of cannabinoid drugs, primarily THC [Tetrahydrocannabinoll for pain relief, control CADocuments and Settings \Poser -S \Desktop \Gonreles v. Raich.doc Page 14 2005 U.S. LEXIS 4656,' of nausea and vomiting, and appetite stimulation "); see also Conant v. Walters, 309 F.3d 629, 640 -643 (CA9 2002) (Kozinski, J., concurring) (chronicling medical studies recognizing valid medical uses for marijuana and its derivatives). But the possibility that the drug may be reclassified in the future has no relevance to the question whether Congress now has the power to regulate its production and distribution. Respondents' submission, if accepted, would place all homegrown medical substances beyond the reach of Congress' regulatory jurisdiction. ['49] Nor can it serve as an "objective marker" or "objective factor" to arbitrarily narrow the relevant class as the dissenters suggest, post, at 6 (O'CONNOR, J., dissenting); post, at 12 (THOMAS, J., dissenting). More fundamentally, if, as the principal dissent contends, the personal cultivation, possession, and use of marijuana for medicinal purposes is beyond the "'outer limits' of Congress' Commerce Clause authority," post, at I (O'CONNOR, J., dissenting), it must also be true that such personal use of marijuana (or any other homegrown drug) for recreational purposes is also beyond those "'outer limits, "' whether or not a State elects to authorize or even regulate such use. JUSTICE THOMAS' separate dissent suffers from the same sweeping implications. That is, the dissenters' rationale logically extends to place any federal regulation (including quality, prescription, or quantity controls) of any locally cultivated and possessed controlled substance for any purpose beyond the "'outer limits "' of Congress' Commerce Clause authority. One need not have a degree in economics to understand why a nationwide exemption for the vast quantity of marijuana (or other drugs) [450] locally cultivated for personal use (which presumably would include use by friends, neighbors, and family members) may have a substantial impact on the interstate market for this extraordinarily popular substance. The congressional judgment that an exemption for such a significant segment of the total market would undermine the orderly enforcement of the entire regulatory scheme is entitled to a strong presumption of validity. Indeed, that judgment is not only rational, but "visible to the naked eye," Lopez, 514 U.S., at 563, under any commonsense appraisal of the probable consequences of such an open -ended exemption. Second, limiting the activity to marijuana possession and cultivation "in accordance with state law" cannot serve to place respondents' activities beyond congressional reach. The Supremacy Clause unambiguously provides that if there is any conflict between federal and state law, federal law shall prevail. It is beyond peradventure that federal power over commerce is "'superior to that of the States to provide for the welfare or necessities of their inhabitants, "' however legitimate or dire those necessities may be. Wirtz, 392 U.S., at 196 [1511 (quoting Sanitary Dist. of Chicago v. United States, 266 U.S. 405, 426 (1925)). See also 392 U.S., at 195 -196; Wickard, 317 U.S., at 124 ( "'No form of state activity can constitutionally thwart the regulatory power granted by the commerce clause to Congress "'). Just as state acquiescence to federal regulation cannot expand the bounds of the Commerce Clause, see, e.g., Morrison, 529 U.S., at 661 -662 (BREYER, J., dissenting) (noting that 38 States requested federal intervention), so too state action cannot circumscribe Congress' plenary commerce power. See United States v. Darby, 312 U.S. 100, 114 (194 1) ( "That power can neither be enlarged nor diminished by the exercise or non - exercise of state power "). n38 n38 That is so even if California's current controls (enacted eight years after the Compassionate Use Act was passed) are "effective," as the dissenters would have us blindly presume, post, at 15 (O'CONNOR, J., dissenting); post, at 6, 12 (THOMAS, J., dissenting). California's decision (made 34 years after the CSA was enacted) to impose "strict controls" on the "cultivation and possession of marijuana for medical purposes," post, at 6 (THOMAS, J., dissenting), cannot retroactively divest Congress of its authority under the Commerce Clause. Indeed, JUSTICE. THOMAS' urgings to the contrary would turn the Supremacy Clause on its head, and would resurrect limits on congressional power that have long since been rejected. See post, at 8 (SCALIA, J., concurring in judgment) (quoting McCulloch v. Maryland, 4 Wheat. 316, 424 (1819)) ( "'To impose on [Congressl the necessity of resorting to means which it cannot control, which another government may furnish or withhold, would render its course precarious, the result of its measures uncertain, and create a dependence on other governments, which might disappoint its most important designs, and is incompatible with the language of the constitution "'). Moreover, in addition to casting aside more than a century of this Court's Commerce Clause jurisprudence, it is noteworthy that JUSTICE THOMAS' suggestion that States possess the power to dictate the extent of Congress' commerce power would have far- reaching implications beyond the facts of this case. For example, under his reasoning, Congress would be equally powerless to regulate, let alone prohibit, the intrastate possession, cultivation, and use of marijuana for recreational purposes, an activity which all States "strictly control." Indeed, his rationale seemingly would require Congress to cede its constitutional power to regulate CADocuments and Settings\Porter -S \Desktop \Gon7.ales v. Raich doe MORK Page 15 2005 U.S. LEXIS 4656, * commerce whenever a State opts to exercise its "traditional police powers to define the criminal law and to protect the health, safety, and welfare of their citizens." Post, at 9 -10 (dissenting opinion). *52 Respondents acknowledge this proposition, but nonetheless contend that their activities were not "an essential part of a larger regulatory scheme" because they had been "isolated by the State of California, and [are] policed by the State of California," and thus remain "entirely separated from the market." Tr, of Oral Arg. 27. The dissenters fall prey to similar reasoning. See n. 38, supra this page. The notion that California law has surgically excised a discrete activity that is hermetically sealed off from the larger interstate marijuana market is a dubious proposition, and, more importantly, one that Congress could have rationally rejected. Indeed, that the California exemptions will have a significant impact on both the supply and demand sides of the market for marijuana is not just "plausible" as the principal dissent concedes, post, at 16 (O'CONNOR, J., dissenting), it is readily apparent. The exemption for physicians provides them with an economic incentive to grant their patients permission to use the drug. In contrast to most prescriptions for legal drugs, which limit the dosage and duration of the usage, under California law the doctor's permission to recommend [ *53] marijuana use is open - ended. The authority to grant permission whenever the doctor determines that a patient is afflicted with "any other illness for which marijuana provides relief," Cal. Health & Safety Code Ann. § I I362.5(b)(1)(A) (West Supp. 2005), is broad enough to allow even the most scrupulous doctor to conclude that some recreational uses would be therapeutic. n39 And our cases have taught us that there are some unscrupulous physicians who overprescribe when it is sufficiently profitable to do so, n40 n39 California's Compassionate Use Act has since been amended, limiting the catchall category to "any other chronic or persistent medical symptom that either:... substantially limits the ability of the person to conduct one or more major life activities as defined" in the Americans with Disabilities Act of 1990, or "if not alleviated, may cause serious harm to the patient's safety or physical or mental health." Cal. Health & Safety Code Ann. § § 11362.7(h)(12)(A) to (12)(B) (West Supp. 2005). n40 See, e.g., United States v. Moore, 423 U.S. 122 (1975); United States v. Doremus, 249 U.S. 86 (1919) [ *54] 'The exemption for cultivation by patients and caregivers can only increase the supply of marijuana in the California market. n41 The likelihood that all such production will promptly terminate when patients recover or will precisely match the patients' medical needs during their convalescence seems remote; whereas the danger that excesses will satisfy some of the admittedly enormous demand for recreational use seems obvious. n42 Moreover, that the national and international narcotics trade has thrived in the face of vigorous criminal enforcement efforts suggests that no small number of unscrupulous people will make use of the California exemptions to serve their commercial ends whenever it is feasible to do so. n43 Taking into account the fact that California is only one of at least nine States to have authorized the medical use of marijuana, a fact JUSTICE O'CONNOR's dissent conveniently disregards in arguing that the demonstrated effect on commerce while admittedly "plausible" is ultimately "unsubstantiated," post, at 14, 16, Congress could have rationally concluded that the aggregate impact on the national market of all the transactions exempted from federal supervision is [ *55] unquestionably substantial. n41 'The state policy allows patients to possess up to eight ounces of dried marijuana, and to cultivate up to 6 mature or 12 immature plants. Cal. Health & Safety Code Ann. § I I362.77(a) (West Supp. 2005). However, the quantity limitations serve only as a floor. Based on a doctor's recommendation, a patient can possess whatever quantity is necessary to satisfy his medical needs, and cities and counties are given carte blanche to establish more generous limits. Indeed, several cities and counties have done just that. For example, patients residing in the cities of Oakland and Santa Cruz and in the counties of Sonoma and Tehama are permitted to possess up to 3 pounds of processed marijuana. Reply Brief for United States 19 (citing Proposition 215 Enforcement Guidelines). Putting that quantity in perspective, 3 pounds of marijuana yields roughly 3,000 joints or cigarettes. Executive Office of the President, Office of National Drug Control Policy, What America's Users Spend on illegal Drugs 24 (Dec. 2001), ht tp: / /www.whitehousedrugpoIicy.gov/ publications/ pdf /american_users_spend_2002.pdf And the street price C Documents and Senings \Porter -S \Desktop \Gonzales v Raich.doc 11TIT1T1L.i I Page 16 2005 U.S. LEXIS 4656, * for that amount can range anywhere from $ 900 to $ 24,000. DEA, Illegal Drug Price and Purity Report (Apr. 2003) (DEA- 02058). ['561 n42 For example, respondent Raich attests that she uses 2.5 ounces of cannabis a week. App. 82. Yet as a resident of Oakland, she is entitled to possess up to 3 pounds of processed marijuana at any given time, nearly 20 times more than she uses on a weekly basis. n43 See, e.g., People ex rel. Lungren v. Peron, 59 Cal. App. 4th 1383, 1386 -1387 (1997) (recounting how a Cannabis Buyers' Club engaged in an "indiscriminate and uncontrolled pattern of sale to thousands of persons among the general public, including persons who had not demonstrated any recommendation or approval of a physician and, in fact, some of whom were not under the care of a physician, such as undercover officers," and noting that "some persons who had purchased marijuana on respondents' premises were reselling it unlawfully on the street "). So, from the "separate and distinct" class of activities identified by the Court of Appeals (and adopted by the dissenters), we are left with "the intrastate, noncommercial cultivation, possession and use of marijuana." 352 F.3d at 1229. Thus the case [ *571 for the exemption comes down to the claim that a locally cultivated product that is used domestically rather than sold on the open market is not subject to federal regulation. Given the findings in the CSA and the undisputed magnitude of the commercial market for marijuana, our decisions in Wickard v. Filburn and the later cases endorsing its reasoning foreclose that claim. V Respondents also raise a substantive due process claim and seek to avail themselves of the medical necessity defense. These theories of relief were set forth in their complaint but were not reached by the Court of Appeals. We therefore do not address the question whether judicial relief is available to respondents on these alternative bases. We do note, however, the presence of another avenue of relief. As the Solicitor General confirmed during oral argument, the statute authorizes procedures for the reclassification of Schedule I drugs. But perhaps even more important than these legal avenues is the democratic process, in which the voices of voters allied with these respondents may one day be heard in the halls of Congress. Under the present state of the law, however, the judgment of the Court of Appeals [0581 must be vacated. The case is remanded for further proceedings consistent with this opinion. It is so ordered. CONCURBY: SCALIA CONCUR: JUSTICE SCALIA, concurring in the judgment. 1 agree with the Court's holding that the Controlled Substances Act (CSA) may validly be applied to respondents' cultivation, distribution, and possession of marijuana for personal, medicinal use. I write separately because my understanding of the doctrinal foundation on which that holding rests is, if not inconsistent with that of the Court, at least more nuanced. Since Perez v. United States, 402 U.S. 146 (1971), our cases have mechanically recited that the Commerce Clause permits congressional regulation of three categories: (1) the channels of interstate commerce; (2) the instrumentalities of interstate commerce, and persons or things in interstate commerce; and (3) activities that "substantially affect" interstate commerce. Id., at 150; see United States v. Morrison, 529 U.S. 598, 608 -609 (2000); United States v. Lopez, 514 U.S. 549, 558 -559 (1995); Hodel v, Virginia Surface Mining & Reclamation Assn., Inc., 452 U.S. 264, 276 -277 (1981). [ *591 The first two categories are self - evident, since they are the ingredients of interstate commerce itself. See Gibbons v. Ogden, 9 Wheat. 1, 189 -190 (1824). The third category, however, is different in kind, and its recitation without explanation is misleading and incomplete. It is misleading because, unlike the channels, instrumentalities, and agents of interstate commerce, activities that substantially affect interstate commerce are not themselves part of interstate commerce, and thus the power to regulate C \Documents and Settings \Porter- S \Lksktop \Gonzales v. Raich.doc iii: Page 17 2005 U.S. LEXIS 4656, * them cannot come from the Commerce Clause alone. Rather, as this Court has acknowledged since at least United States v. Coombs, 12 Pet. 72 (1838), Congress's regulatory authority over intrastate activities that are not themselves part of interstate commerce (including activities that have a substantial effect on interstate commerce) derives from the Necessary and Proper Clause. Id., at 78; Katzenbach v. McClung, 379 U.S. 294, 301 -302 (1964); United States v. Wrightwood Dairy Co., 315 U.S. 110, 119 (1942); Shreveport Rate Cases, 234 U.S. 342, 353 (1914); United States v. E. C. Knight Co., 156 U.S. 1, 39-40 (1895) [ *60] (Harlan, J., dissenting). n And the category of "activities that substantially affect interstate commerce," Lopez, supra, at 559, is incomplete because the authority to enact laws necessary and proper for the regulation of interstate commerce is not limited to laws governing intrastate activities that substantially affect interstate commerce. Where necessary to make a regulation of interstate commerce effective, Congress may regulate even those intrastate activities that do not themselves substantially affect interstate commerce. nl See also Garcia V. San Antonio Metropolitan Transit Authority, 469 U.S. 528, 584 -585 (1985) (O'CONNOR, J., dissenting) (explaining that it is through the Necessary and Proper Clause that "an intrastate activity 'affecting' interstate commerce can be reached through the commerce power "). Our cases show that the regulation of intrastate activities may be necessary to and proper for the regulation of interstate commerce in two general [ *61 ] circumstances. Most directly, the commerce power permits Congress not only to devise rules for the governance of commerce between States but also to facilitate interstate commerce by eliminating potential obstructions, and to restrict it by eliminating potential stimulants. See NLRB v. Jones & Laughlin Steel Corp., 301 U.S. 1, 36 -37 (1937). That is why the Court has repeatedly sustained congressional legislation on the ground that the regulated activities had a substantial effect on interstate commerce. See, e.g., Hodel, supra, at 281 (surface coal mining); Katzenbach, supra, at 300 (discrimination by restaurants); lleart of Atlanta Motel, Inc. v. United States, 379 U.S. 241, 258 (1964) (discrimination by hotels); Mandeville Island Farms v. American Crystal Sugar Co., 334 U.S. 219, 237 (1948) (intrastate price - fixing); Board of Trade of Chicago v. Olsen, 262 U.S. 1, 40 (1923) (activities of a local grain exchange); Stafford v. Wallace, 258 U.S. 495, 517, 524 -525 (1922) (intrastate transactions at stockyard). Lopez and Morrison recognized [ *62] the expansive scope of Congress's authority in this regard: "The pattern is clear. Where economic activity substantially affects interstate commerce, legislation regulating that activity will be sustained." Lopez, supra, at 560; Morrison, supra, at 610 (same). This principle is not without limitation, In Lopez and Morrison, the Court -- conscious of the potential of the "substantially affects" test to "'obliterate the distinction between what is national and what is local, "' Lopez, supra, at 566 -567 (quoting A. L. A. Schechter Poultry Corp. v. United States, 295 U.S. 495, 554 (1935)); see also Morrison, supra, at 615 -616 -- rejected the argument that Congress may regulate noneconomic activity based solely on the effect that it may have on interstate commerce through a remote chain of inferences. Lopez, supra, at 564 -566; Morrison, supra, at 617 -618. "If we were to accept [such] arguments," the Court reasoned in Lopez, "we are hard pressed to posit any activity by an individual that Congress is without power to regulate. [ *63] " Lopez, supra, at 564; see also Morrison, supra, at 615 -616. Thus, although Congress's authority to regulate intrastate activity that substantially affects interstate commerce is broad, it does not permit the Court to "pile inference upon inference," Lopez, supra, at 567, in order to establish that noneconomic activity has a substantial effect on interstate commerce. As we implicitly acknowledged in Lopez, however, Congress's authority to enact laws necessary and proper for the regulation of interstate commerce is not limited to laws directed against economic activities that have a substantial effect on interstate commerce. Though the conduct in Lopez was not economic, the Court nevertheless recognized that it could be regulated as "an essential part of a larger regulation of economic activity, in which the regulatory scheme could be undercut unless the intrastate activity were regulated." 514 U.S., at 561. This statement referred to those cases permitting the regulation of intrastate activities "which in a substantial way interfere with or obstruct the exercise of the granted power." Wrighrwood Dairy Co., 315 U.S., at 119; [ *64] see also United States v. Darby, 312 U.S. 100, 118 -119 (1941); Shreveport Rate Cases, 234 U.S., at 353. As the Court put it in Wrightwood Dairy, where Congress has the authority to enact a regulation of interstate commerce, "it possesses every power needed to make that regulation effective." 315 U.S., at 118 -119. Although this power "to make ... regulation effective" commonly overlaps with the authority to regulate economic activities that substantially affect interstate commerce, n2 and may in some cases have been confused with that authority, the two are distinct. The regulation of an intrastate activity may be essential to a comprehensive regulation of CADocuments and Settings \Porter -S \Desktop \Gorvales v. Raich doc Page 18 2005 U.S. LEXIS 4656, " interstate commerce even though the intrastate activity does not itself "substantially affect" interstate commerce. Moreover, as the passage from Lopez quoted above suggests, Congress may regulate even noneconomic local activity if that regulation is a necessary part of a more general regulation of interstate commerce. See Lopez, supra, at 561. The relevant question is simply whether the means chosen are "reasonably adapted" to the attainment of a legitimate [`651 end under the commerce power. See Darby, supra, at 121. n2 Wickard v. Filburn, 317 U.S. 111 (1942), presented such a case. Because the unregulated production of wheat for personal consumption diminished demand in the regulated wheat market, the Court said, it carried with it the potential to disrupt Congress's price regulation by driving down prices in the market. Id., at 127 -129. This potential disruption of Congress's interstate regulation, and not only the effect that personal consumption of wheat had on interstate commerce, justified Congress's regulation of that conduct, id., at 128 -129. [n Darby, for instance, the Court explained that "Congress, having ... adopted the policy of excluding from interstate commerce all goods produced for the commerce which do not conform to the specified labor standards," 312 U.S., at 121, could not only require employers engaged in the production of goods for interstate commerce [•661 to conform to wage and hour standards, id., at 119-12 1, but could also require those employers to keep employment records in order to demonstrate compliance with the regulatory scheme, id, at 125. While the Court sustained the former regulation on the alternative ground that the activity it regulated could have a "great effect" on interstate commerce, id., at 122 -123, it affirmed the latter on the sole ground that "the requirement for records even of the intrastate transaction is an appropriate means to a legitimate end," id., at 125. As the Court said in the Shreveport Rate Cases, the Necessary and Proper Clause does not give "Congress ... the authority to regulate the internal commerce of a State, as such," but it does allow Congress "to take all measures necessary or appropriate to" the effective regulation of the interstate market, "although intrastate transactions ... may thereby be controlled." 234 U.S., at 353; see also Jones & Laughlin Steel Corp., 301 U.S., at 38 (the logic of the Shreveport Rate Cases is not limited to instrumentalities of commerce). Today's [•671 principal dissent objects that, by permitting Congress to regulate activities necessary to effective interstate regulation, the Court reduces Lopez and Morrison to "little more than a drafting guide." Post, at 5 (opinion of O'CONNOR, J.). I think that criticism unjustified. Unlike the power to regulate activities that have a substantial effect on interstate commerce, the power to enact laws enabling effective regulation of interstate commerce can only be exercised in conjunction with congressional regulation of an interstate market, and it extends only to those measures necessary to make the interstate regulation effective. As Lopez itself states, and the Court affirms today, Congress may regulate noneconomic intrastate activities only where the failure to do so "could ... undercut" its regulation of interstate commerce. See Lopez, supra, at 561; ante, at 15, 21, 22. This is not a power that threatens to obliterate the line between "what is truly national and what is truly local." Lopez, supra, at 567 -568. Lopez and Morrison affirm that Congress may not regulate certain "purely local" activity within the States ['68] based solely on the attenuated effect that such activity may have in the interstate market. But those decisions do not declare noneconomic intrastate activities to be categorically beyond the reach of the Federal Government. Neither case involved the power of Congress to exert control over intrastate activities in connection with a more comprehensive scheme of regulation; Lopez expressly disclaimed that it was such a case, 514 U.S., at 561, and Morrison did not even discuss the possibility that it was. (The Court of Appeals in Morrison made clear that it was not. See Brzonkala v. Virginia Polytechnic Inst., 169 F.3d 820, 834 -835 (CA4 1999) (en bane).) To dismiss this distinction as "superficial and formalistic," see post, at 6 (O'CONNOR, J., dissenting), is to misunderstand the nature of the Necessary and Proper Clause, which empowers Congress to enact laws in effectuation of its enumerated powers that are not within its authority to enact in isolation. See McCulloch v. Maryland, 4 Wheat. 316, 421 -422 (1819). And there are other restraints upon the Necessary and Proper Clause authority. As Chief Justice Marshall ['691 wrote in McCulloch v. Maryland, even when the end is constitutional and legitimate, the means must be "appropriate" and "plainly adapted" to that end. Id., at 421. Moreover, they may not be otherwise "prohibited" and must be "consistent with the letter and spirit of the constitution." Ibid. These phrases are not merely hortatory. For example, cases such as Printz v. United States, 521 U.S. 898 (1997), and New York v. United States, 505 U.S. 144 (1992), affirm that a law is C:UMcuments and Settings \Porter -S \Desktop \Gonzales v. Raich doc Page 19 2005 U.S. LEXIS 4656, " not "'proper for carrying into Execution the Commerce Clause "' "when [it] violates [a constitutional] principle of state sovereignty." Printz, supra, at 923 -924; see also New York, supra, at 166. III The application of these principles to the case before us is straightforward. In the CSA, Congress has undertaken to extinguish the interstate market in Schedule 1 controlled substances, including marijuana. The Commerce Clause unquestionably permits this. The power to regulate interstate commerce "extends not only to those regulations which aid, foster and protect the commerce, but embraces those which prohibit [•70] it." Darby, 312 U.S., at 113. See also Nipolite Egg Co. v, United States, 220 U.S. 45, 58 (1911); lottery Case, 188 U.S. 321, 354 (1903). To effectuate its objective, Congress has prohibited almost all intrastate activities related to Schedule I substances -- both economic activities (manufacture, distribution, possession with the intent to distribute) and noneconomic activities (simple possession). See 21 U.S.C. § § 841(a), 844(a). That simple possession is a noneconomic activity is immaterial to whether it can be prohibited as a necessary part of a larger regulation. Rather, Congress's authority to enact all of these prohibitions of intrastate controlled - substance activities depends only upon whether they are appropriate means of achieving the legitimate end of eradicating Schedule I substances from interstate commerce. By this measure, I think the regulation must be sustained. Not only is it impossible to distinguish "controlled substances manufactured and distributed intrastate" from "controlled substances manufactured and distributed interstate," but it hardly makes sense to speak in such terms. Drugs [•71 ] like marijuana are fungible commodities. As the Court explains, marijuana that is grown at home and possessed for personal use is never more than an instant from the interstate market -- and this is so whether or not the possession is for medicinal use or lawful use under the laws of a particular State. n3 See ante, at 23 -30. Congress need not accept on faith that state law will be effective in maintaining a strict division between a lawful market for "medical" marijuana and the more general marijuana market. See id., at 26- 27, and n. 38. "To impose on [Congress] the necessity of resorting to means which it cannot control, which another government may furnish or withhold, would render its course precarious, the result of its measures uncertain, and create a dependence on other governments, which might disappoint its most important designs, and is incompatible with the language of the constitution." McCulloch, supra, at 424. n3 The principal dissent claims that, if this is sufficient to sustain the regulation at issue in this case, then it should also have been sufficient to sustain the regulation at issue in United States v. Lopez, 514 U.S. 549 (1995). See post, at 11 -12 (arguing that "we could have surmised in Lopez that guns in school zones are 'never more than an instant from the interstate market' in guns already subject to federal regulation, recast Lopez as a Necessary and Proper Clause case, and thereby upheld the Gun -Free School Zones Act "). This claim founders upon the shoals of Lopez itself, which made clear that the statute there at issue was "not an essential part of a larger regulation of economic activity." Lopez, supra, at 561 (emphasis added). On the dissent's view of things, that statement is inexplicable. Of course it is in addition difficult to imagine what intelligible scheme of regulation of the interstate market in guns could have as an appropriate means of effectuation the prohibition of guns within 1000 feet of schools (and nowhere else). The dissent points to a federal law, 18 U.S.C. § 922(b)(I ), barring licensed dealers from selling guns to minors, see post, at 12, but the relationship between the regulatory scheme of which § 922(b)(1) is a part (requiring all dealers in firearms that have traveled in interstate commerce to be licensed, see § 922(a)) and the statute at issue in Lopez approaches the nonexistent -- which is doubtless why the Government did not attempt to justify the statute on the basis of that relationship. *72 Finally, neither respondents nor the dissenters suggest any violation of state sovereignty of the sort that would render this regulation "inappropriate," id, at 421 -- except to argue that the CSA regulates an area typically left to state regulation. See post, at 6 -7, 11 (opinion of O'CONNOR, J.); post, at 8 -9 (opinion of THOMAS, J.); Brief for Respondents 39-42. That is not enough to render federal regulation an inappropriate means. The Court has repeatedly recognized that, if authorized by the commerce power, Congress may regulate private endeavors "even when [that regulation] may pre -empt express state -law determinations contrary to the result which has commended itself to the collective wisdom of Congress." National League of Cities v. Usery, 426 U.S. 833, 840 (1976); see Cleveland v. United States, 329 U.S. 14, 19 (1946); McCulloch, supra, at 424. At bottom, respondents' state - sovereignty argument reduces to the contention that federal regulation of the activities permitted by California's Compassionate Use Act is not C Documents and Settings \Porter- S\Desklop`,Gonzales v. Raich.doc Page 20 2005 U.S. LEX1S 4656,' sufficiently necessary to be "necessary and proper" to Congress's regulation of the interstate [ »73) market. For the reasons given above and in the Court's opinion, I cannot agree. I thus agree with the Court that, however the class of regulated activities is subdivided, Congress could reasonably conclude that its objective of prohibiting marijuana from the interstate market "could be undercut" if those activities were excepted from its general scheme of regulation. See Lopez, 514 U.S., at 561. That is sufficient to authorize the application of the CSA to respondents. DISSENTBY: O'CONNOR; THOMAS DISSENT.: JUSTICE O'CONNOR, with whom THE CHIEF JUSTICE and JUSTICE THOMAS join as to all but Part 111, dissenting. We enforce the "outer limits" of Congress' Commerce Clause authority not for their own sake, but to protect historic spheres of state sovereignty from excessive federal encroachment and thereby to maintain the distribution of power fundamental to our federalist system of government. United States v. Lopez, 514 U.S. 549, 557 (1995); .NLRB v. Jones & Laughlin Steel Corp., 301 U.S. 1, 37 (1937). One of federalism's chief virtues, of course, is that it promotes innovation by allowing for the possibility that "a single courageous [ »74] State may, if its citizens choose, serve as a laboratory; and try novel social and economic experiments without risk to the rest of the country." New State Ice Co. v. Liebmann, 285 U.S. 262, 311 (1932) (Brandeis, J., dissenting). This case exemplifies the role of States as laboratories. The States' core police powers have always included authority to define criminal law and to protect the health, safety, and welfare of their citizens. Brecht v. Abrahamson, 507 U.S. 619, 635 (1993); Whalen v. Roe, 429 U.S. 589, 603, n. 30 (1977). Exercising those powers, California (by ballot initiative and then by legislative codification) has come to its own conclusion about the difficult and sensitive question of whether marijuana should be available to relieve severe pain and suffering. Today the Court sanctions an application of the federal Controlled Substances Act that extinguishes that experiment, without any proof that the personal cultivation, possession, and use of marijuana for medicinal purposes, if economic activity in the first place, has a substantial effect on interstate commerce and is therefore an appropriate subject [ »75] of federal regulation. In so doing, the Court announces a rule that gives Congress a perverse incentive to legislate broadly pursuant to the Commerce Clause -- nestling questionable assertions of its authority into comprehensive regulatory schemes -- rather than with precision. That rule and the result it produces in this case are irreconcilable with our decisions in Lopez, supra, and United States v. Morrison, 529 U.S. 598 (2000). Accordingly I dissent. In Lopez, we considered the constitutionality of the Gun -Free School Zones Act of 1990, which made it a federal offense "for any individual knowingly to possess a firearm ... at a place the individual knows, or has reasonable cause to believe, is a school zone," 18 U.S.C. § 922(q)(2)(A). We explained that "Congress' commerce authority includes the power to regulate those activities having a substantial relation to interstate commerce ..., i.e., those activities that substantially affect interstate commerce." 514 U.S., a1558 -559 (citation omitted). This power derives from the conjunction of the Commerce Clause and the Necessary and Proper Clause. [ »76] Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528, 585 -586 (1985) (O'CONNOR, J., dissenting) (explaining that United States v. Darby, 312 U.S. 100 (1941), United States v. Wrightwood Dairy Co., 315 U.S. 110 (1942), and Wickard v. Fitburn, 317 U.S. 11 I (1942), based their expansion of the commerce power on the Necessary and Proper Clause, and that "the reasoning of these cases underlies every recent decision concerning the reach of Congress to activities affecting interstate commerce "); ante, at 2 (SCALIA, J., concurring in judgment). We held in Lopez that the Gun -Free School Zones Act could not be sustained as an exercise of that power. Our decision about whether gun possession in school zones substantially affected interstate commerce turned on four considerations. Lopez, supra, at 559 -567; see also Morrison, supra, at 609 -613, First, we observed that our "substantial effects" cases generally have upheld federal regulation of economic activity that affected interstate commerce, but that § 922(q) was a criminal statute having "nothing [ 077] to do with 'commerce' or any sort of economic enterprise." Lopez, 514 U.S., at 561. In this regard, we also noted that "section 922(q) is not an essential part of a larger regulation of economic activity, in which the regulatory scheme could be undercut unless the intrastate CADocuments and Senings\Porter -S \Desktop \Gonzales v. Raich.doc MMM-Mmell Page 21 2005 U.S. LEXIS 4656, activity were regulated. It cannot, therefore, be sustained under our cases upholding regulations of activities that arise out of or are connected with a commercial transaction, which viewed in the aggregate, substantially affects interstate commerce." Ibid. Second, we noted that the statute contained no express jurisdictional requirement establishing its connection to interstate commerce. /bid. Third, we found telling the absence of legislative findings about the regulated conduct's impact on interstate commerce. We explained that while express legislative findings are neither required nor, when provided, dispositive, findings "enable us to evaluate the legislative judgment that the activity in question substantially affects interstate commerce, even though no such substantial effect [is) visible to the naked eye." Id., at 563. Finally, we rejected as too attenuated ['781 the Government's argument that firearm possession in school zones could result in violent crime which in turn could adversely affect the national economy. Id., at 563 -567. The Constitution, we said, does not tolerate reasoning that would "convert congressional authority under the Commerce Clause to a general police power of the sort retained by the States." Id., at 567. Later in Morrison, supra, we relied on the same four considerations to hold that § 40302 of the Violence Against Women Act of 1994, 42 U.S.C. § 13 98 1, exceeded Congress' authority under the Commerce Clause. In my view, the case before us is materially indistinguishable from Lopez and Morrison when the same considerations are taken into account. 11 I1 What is the relevant conduct subject to Commerce Clause analysis in this case? The Court takes its cues from Congress, applying the above considerations to the activity regulated by the Controlled Substances Act (CSA) in general. The Court's decision rests on two facts about the CSA: (1) Congress chose to enact a single statute providing a comprehensive prohibition on the production, ['79] distribution, and possession of all controlled substances, and (2) Congress did not distinguish between various forms of intrastate noncommercial cultivation, possession, and use of marijuana. See 21 U.S.C. § § 841(a)(1), 844(a). Today's decision suggests that the federal regulation of local activity is immune to Commerce Clause challenge because Congress chose to act with an ambitious, all- encompassing statute, rather than piecemeal. In my view, allowing Congress to set the terms of the constitutional debate in this way, i.e., by packaging regulation of local activity in broader schemes, is tantamount to removing meaningful limits on the Commerce Clause. The Court's principal means of distinguishing Lopez from this case is to observe that the Gun -Free School Zones Act of 1990 was a "brief, single- subject statute," ante, at 20, see also ante, at 19, whereas the CSA is "a lengthy and detailed statute creating a comprehensive framework for regulating the production, distribution, and possession of five classes of'controlled substances, "' ibid. Thus, according to the Court, it was possible in Lopez to evaluate in isolation the constitutionality [•801 of criminalizing local activity (there gun possession in school zones), whereas the local activity that the CSA targets (in this case cultivation and possession of marijuana for personal medicinal use) cannot be separated from the general drug control scheme of which it is a part. Today's decision allows Congress to regulate intrastate activity without check, so long as there is some implication by legislative design that regulating intrastate activity is essential (and the Court appears to equate "essential" with "necessary") to the interstate regulatory scheme. Seizing upon our language in Lopez that the statute prohibiting gun possession in school zones was "not an essential part of a larger regulation of economic activity, in which the regulatory scheme could be undercut unless the intrastate activity were regulated," 514 U.S., at 561, the Court appears to reason that the placement of local activity in a comprehensive scheme confirms that it is essential to that scheme. Ante, at 21- 22. If the Court is right, then Lopez stands for nothing more than a drafting guide: Congress should have described the relevant crime as "transfer or possession of a firearm ['811 anywhere in the nation" -- thus including commercial and noncommercial activity, and clearly encompassing some activity with assuredly substantial effect on interstate commerce. Had it done so, the majority hints, we would have sustained its authority to regulate possession of firearms in school zones. Furthermore, today's decision suggests we would readily sustain a congressional decision to attach the regulation of intrastate activity to a pre- existing comprehensive (or even not -so- comprehensive) scheme. If so, the Court invites increased federal regulation of local activity even if, as it suggests, Congress would not enact a new interstate scheme exclusively for the sake of reaching intrastate activity, see ante, at 22, n. 33; ante, at 6 (SCALIA, J., concurring in judgment). CADocuments and Settings \Porter -S \Desktop \Gonzales v. Raich.doc Page 22 2005 U.S. LEXIS 4656, 1 cannot agree that our decision in Lopez contemplated such evasive or overbroad legislative strategies with approval. Until today, such arguments have been made only in dissent. See Morrison, 529 U.S., at 657 (BREYER, J., dissenting) (given that Congress can regulate an essential part of a larger regulation of economic activity, "' "can Congress save the present law by including [ "82] it, or much of it, in a broader'Safe Transport' or'Worker Safety' act ? "). Lopez and Morrison did not indicate that the constitutionality of federal regulation depends on superficial and formalistic distinctions. likewise 1 did not understand our discussion of the role of courts in enforcing outer limits of the Commerce Clause for the sake of maintaining the federalist balance our Constitution requires, see Lopez, 514 U.S., at 557; id., at 578 (KENNEDY, J., concurring), as a signal to Congress to enact legislation that is more extensive and more intrusive into the domain of state power. if the Court always defers to Congress as it does today, little may be left to the notion of enumerated powers. The hard work for courts, then, is to identify objective markers for confining the analysis in Commerce Clause cases. Here, respondents challenge the constitutionality of the CSA as applied to them and those similarly situated. l agree with the Court that we must look beyond respondents' own activities. Otherwise, individual litigants could always exempt themselves from Commerce Clause regulation merely by pointing to the obvious -- that their personal ['83] activities do not have a substantial effect on interstate commerce. See Maryland v. Wirtz, 392 U.S. 183, 193 (1968); Wickard, 317 U.S., at 127 -128. The task is to identify a mode of analysis that allows Congress to regulate more than nothing (by declining to reduce each case to its litigants) and less than everything (by declining to let Congress set the terms of analysis). The analysis may not be the same in every case, for it depends on the regulatory scheme at issue and the federalism concerns implicated. See generally Lopez, 514 U.S., at 567; id., at 579 (KENNEDY, J., concurring). A number of objective markers are available to confine the scope of constitutional review here. Both federal and state legislation -- including the CSA itself, the California Compassionate Use Act, and other state medical marijuana legislation -- recognize that medical and nonmedical (i.e., recreational) uses of drugs are realistically distinct and can be segregated, and regulate them differently. See 21 U.S.C. § 812; Cal. Health & Safety Code Ann. § 11362.5 (West Supp. 2005); ante, at I (opinion of [•84] the Court). Respondents challenge only the application of the CSA to medicinal use of marijuana, Cf. United Stares v. Raines, 362 U.S. 17, 20 -22 (1960) (describing our preference for as- applied rather than facial challenges). Moreover, because fundamental structural concerns about dual sovereignty animate our Commerce Clause cases, it is relevant that this case involves the interplay of federal and state regulation in areas of criminal law and social policy, where "States lay claim by right of history and expertise." Lopez, supra, at 583 (KENNEDY, J., concurring); see also Morrison, supra, at 617 -619; Lopez, supra, at 580 (KENNEDY, J., concurring) ( "The statute before us upsets the federal balance to a degree that renders it an unconstitutional assertion of the commerce power, and our intervention is required "); cf. Garcia, 469 U.S., at 586 (O'CONNOR, J., dissenting) ( "State autonomy is a relevant factor in assessing the means by which Congress exercises its powers" under the Commerce Clause). California, like other States, has drawn on its reserved powers to distinguish the regulation ['85] of medicinal marijuana. To ascertain whether Congress' encroachment is constitutionally justified in this case, then, I would focus here on the personal cultivation, possession, and use of marijuana for medicinal purposes. B Having thus defined the relevant conduct, we must determine whether, under our precedents, the conduct is economic and, in the aggregate, substantially affects interstate commerce. Even if intrastate cultivation and possession of marijuana for one's own medicinal use can properly be characterized as economic, and I question whether it can, it has not been shown that such activity substantially affects interstate commerce. Similarly, it is neither self - evident nor demonstrated that regulating such activity is necessary to the interstate drug control scheme. The Court's definition of economic activity is breathtaking. It defines as economic any activity involving the production, distribution, and consumption of commodities. And it appears to reason that when an interstate market for a commodity exists, regulating the intrastate manufacture or possession of that commodity is constitutional either because that intrastate activity is itself economic, or because regulating [ 086] it is a rational part of regulating its market. Putting to one side the problem endemic to the Court's opinion -- the shift in focus from the activity at issue in this case to the entirety of what the CSA regulates, see Lopez, supra, at 565 ( "depending on the level of generality, any activity can be looked upon as commercial ") -- the Court's definition of economic activity for purposes of Commerce Clause jurisprudence threatens to sweep all of productive human activity into federal regulatory reach. The Court uses a dictionary definition of economics to skirt the real problem of drawing a meaningful line between "what is national and what is local," Jones & Laughlin .Steel, 301 U.S., at 37. It will not do to say that Congress may regulate noncommercial activity simply because it may have an effect on the demand for commercial goods, or because C Occuments and Settings \Poner -S \Desktop \Gonzales v. Raich doc 000091 Page 23 2005 U.S. LEXIS 4656,' the noncommercial endeavor can, in some sense, substitute for commercial activity. Most commercial goods or services have some sort of privately producible analogue. Home care substitutes for daycare. Charades games substitute for movie tickets. Backyard or windowsill gardening substitutes for going to the [•87] supermarket. To draw the line wherever private activity affects the demand for market goods is to draw no line at all, and to declare everything economic. We have already rejected the result that would follow -- a federal police power. Lopez, supra, at 564. In Lopez and Morrison, we suggested that economic activity usually relates directly to commercial activity. See Morrison, 529 U.S., at 611, n. 4 (intrastate activities that have been within Congress' power to regulate have been "of an apparent commercial character "); Lopez, 514 U.S., at 561 (distinguishing the Gun -Free School Zones Act of 1990 from "activities that arise out of or are connected with a commercial transaction "). The homegrown cultivation and personal possession and use of marijuana for medicinal purposes has no apparent commercial character. Everyone agrees that the marijuana at issue in this case was never in the stream of commerce, and neither were the supplies for growing it. (Marijuana is highly unusual among the substances subject to the CSA in that it can be cultivated without any materials that have traveled in interstate commerce.) Lopez makes [•88] clear that possession is not itself commercial activity. Ibid. And respondents have not come into possession by means of any commercial transaction; they have simply grown, in their own homes, marijuana for their own use, without acquiring, buying, selling, or bartering a thing of value. Cf. id., at 583 (KENNEDY, J., concurring) ( "The statute now before us forecloses the States from experimenting ... and it does so by regulating an activity beyond the realm of commerce in the ordinary and usual sense of that term "). The Court suggests that Wickard, which we have identified as "perhaps the most far reaching example of Commerce Clause authority over intrastate activity," Lopez, supra, at 560, established federal regulatory power over any home consumption of a commodity for which a national market exists. I disagree. Wickard involved a challenge to the Agricultural Adjustment Act of 1938 (AAA), which directed the Secretary of Agriculture to set national quotas on wheat production, and penalties for excess production. 317 U.S., at 115-116. The AAA itself confirmed that Congress made an explicit choice not to reach -- and thus ['89] the Court could not possibly have approved of federal control over -- small - scale, noncommercial wheat farming. In contrast to the CSA's limitless assertion of power, Congress provided an exemption within the AAA for small producers. When Filburn planted the wheat at issue in Wickard, the statute exempted plantings less than 200 bushels (about six tons), and when he harvested his wheat it exempted plantings less than six acres. Id., at 130, n. 30. Wickard, then, did not extend Commerce Clause authority to something as modest as the home cook's herb garden. This is not to say that Congress may never regulate small quantities of commodities possessed or produced for personal use, or to deny that it sometimes needs to enact a zero tolerance regime for such commodities. It is merely to say that Wickard did not hold or imply that small -scale production of commodities is always economic, and automatically within Congress' reach. Even assuming that economic activity is at issue in this case, the Government has made no showing in fact that the possession and use of homegrown marijuana for medical purposes, in California or elsewhere, has a substantial effect on [090] interstate commerce. Similarly, the Government has not shown that regulating such activity is necessary to an interstate regulatory scheme. Whatever the specific theory of "substantial effects" at issue (i.e., whether the activity substantially affects interstate commerce, whether its regulation is necessary to an interstate regulatory scheme, or both), a concern for dual sovereignty requires that Congress' excursion into the traditional domain of States be justified. That is why characterizing this as a case about the Necessary and Proper Clause does not change the analysis significantly. Congress must exercise its authority under the Necessary and Proper Clause in a manner consistent with basic constitutional principles. Garcia, 469 U.S., at 585 (O'CONNOR, J., dissenting) ( "It is not enough that the 'end be legitimate'; the means to that end chosen by Congress must not contravene the spirit of the Constitution "). As JUSTICE SCALIA recognizes, see ante, at 7 (opinion concurring in judgment), Congress cannot use its authority under the Clause to contravene the principle of state sovereignty embodied in the Tenth Amendment. Ibid. Likewise, that authority [ "91 J must be used in a manner consistent with the notion of enumerated powers -- a structural principle that is as much pan of the Constitution as the Tenth Amendment's explicit textual command. Accordingly, something more than mere assertion is required when Congress purports to have power over local activity whose connection to an intrastate market is not self - evident. Otherwise, the Necessary and Proper Clause will always be a back door for unconstitutional federal regulation. Cf Printz v. United States, 521 U.S. 898, 923 (1997) (the Necessary and Proper Clause is "the last, best hope of those who defend ultra vires congressional action "). Indeed, if it were enough in "substantial effects" cases for the Court to supply conceivable justifications for intrastate regulation related to an interstate market, then we could have surmised in Lopez that guns in school zones are "never more than an instant from the interstate market" in guns already subject to extensive federal regulation, ante, at 8 ( SCALIA, J., concurring in judgment), recast Lopez as a Necessary and Proper Clause case, and thereby upheld the Gun -Free School Zones Act of 1990. (According to ['92] the Court's CADocuments and Settings \Porter- S \Msktop�Gonzales v. Raich.doc 000092 Page 24 2005 U.S. LEXIS 4656, * and the concurrence's logic, for example, the Lopez court should have reasoned that the prohibition on gun possession in school zones could be an appropriate means of effectuating a related prohibition on "selling" or "delivering" firearms or ammunition to "any individual who the licensee knows or has reasonable cause to believe is less than eighteen years of age." 18 U.S.C. § 922(b)(1) (1988 ed., Supp. II).) There is simply no evidence that homegrown medicinal marijuana users constitute, in the aggregate, a sizable enough class to have a discernable, let alone substantial, impact on the national illicit drug market -- or otherwise to threaten the CSA regime. Explicit evidence is helpful when substantial effect is not "visible to the naked eye." See Lopez, 514 U.S., at 563. And here, in part because common sense suggests that medical marijuana users may be limited in number and that California's Compassionate Use Act and similar state legislation may well isolate activities relating to medicinal marijuana from the illicit market, the effect of those activities on interstate drug traffic is not self - evidently substantial. In [ *931 this regard, again, this case is readily distinguishable from Wickard. To decide whether the Secretary could regulate local wheat farming, the Court looked to "the actual effects of the activity in question upon interstate commerce." 317 U.S., at 120. Critically, the Court was able to consider "actual effects" because the parties had "stipulated a summary of the economics of the wheat industry." Id., at 125. After reviewing in detail the picture of the industry provided in that summary, the Court explained that consumption of homegrown wheat was the most variable factor in the size of the national wheat crop, and that on -site consumption could have the effect of varying the amount of wheat sent to market by as much as 20 percent. Id., at 127. With real numbers at hand, the Wickard Court could easily conclude that "a factor of such volume and variability as home - consumed wheat would have a substantial influence on price and market conditions" nationwide. Id., at 128; see also id., at 128 -129 ( "This record leaves us in no doubt" about substantial effects). The Court recognizes that "the record in [ *941 the Wickard case itself established the causal connection between the production for local use and the national market" and argues that "we have before us findings by Congress to the same effect." Ante, at 17 (emphasis added). The Court refers to a series of declarations in the introduction to the CSA saying that (1) local distribution and possession of controlled substances causes "swelling" in interstate traffic; (2) local production and distribution cannot be distinguished from interstate production and distribution; (3) federal control over intrastate incidents "is essential to effective control" over interstate drug trafficking. 21 U.S.C. § § 801(1) -(6). These bare declarations cannot be compared to the record before the Court in Wickard. They amount to nothing more than a legislative insistence that the regulation of controlled substances must be absolute. They are asserted without any supporting evidence -- descriptive, statistical, or otherwise. "Simply because Congress may conclude a particular activity substantially affects interstate commerce does not necessarily make it so," Hodel v. Virginia Surface Mining & Reclamation Assn., Inc., 452 U.S. 264, 311 (198 1) [ *951 (REHNQUIST, J., concurring in judgment). Indeed, if declarations like these suffice to justify federal regulation, and if the Court today is right about what passes rationality review before us, then our decision in Morrison should have come out the other way. In that case, Congress had supplied numerous findings regarding the impact gender- motivated violence had on the national economy. 529 U.S., at 614; id., at 628 -636 (SOUTER, J., dissenting) (chronicling findings). But, recognizing that "' "whether particular operations affect interstate commerce sufficiently to come under the constitutional power of Congress to regulate them is ultimately a judicial rather than a legislative question, "' " we found Congress' detailed findings inadequate. Id, at 614 (quoting Lopez, supra, at 557, n. 2, in turn quoting Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241, 273 (1964) (Black, J., concurr ing)). If, as the Court claims, today's decision does not break with precedent, how can it be that voluminous findings, documenting extensive hearings about the specific topic of violence against women, [ *961 did not pass constitutional muster in Morrison, while the CSA's abstract, unsubstantiated, generalized findings about controlled substances do? In particular, the CSA's introductory declarations are too vague and unspecific to demonstrate that the federal statutory scheme will be undermined if Congress cannot exert power over individuals like respondents. The declarations are not even specific to marijuana. (Facts about substantial effects may be developed in litigation to compensate for the inadequacy of Congress' findings; in part because this case comes to us from the grant of a preliminary injunction, there has been no such development.) Because here California, like other States, has carved out a limited class of activity for distinct regulation, the inadequacy of the CSA's findings is especially glaring. The California Compassionate Use Act exempts from other state drug laws patients and their caregivers "who possess or cultivate marijuana for the personal medical purposes of the patient upon the written or oral recommendation of a physician" to treat a list of serious medical conditions. Cal. Health & Safety Code Ann. § § 11362.5(d), 11362.7(h) (West Supp. 2005) (emphasis [ *971 added). Compare ibid. with, e.g., § 11357(b) (West 1991) (criminalizing marijuana possession in excess of 28.5 grams); § CADocuments and Settings \Porter- S\Iksktop \Gonzales v Raich.doc 000093 Page 25 2005 U.S. LEXIS 4656, ` 11358 (criminalizing marijuana cultivation). The Act specifies that it should not be construed to supersede legislation prohibiting persons from engaging in acts dangerous to others, or to condone the diversion of marijuana for nonmedical purposes. § 11362.5(b)(2) (West Supp. 2005), To promote the Act's operation and to facilitate law enforcement, California recently enacted an identification card system for qualified patients. § § 11362.7-11362.83. We generally assume States enforce their laws, see Riley v. National Federation of Blind of N. C., Inc., 487 U.S. 781, 795 (1988), and have no reason to think otherwise here. The Government has not overcome empirical doubt that the number of Californians engaged in personal cultivation, possession, and use of medical marijuana, or the amount of marijuana they produce, is enough to threaten the federal regime. Nor has it shown that Compassionate Use Act marijuana users have been or are realistically likely to be responsible for the drug's seeping into the market in a significant way. The [`98] Government does cite one estimate that there were over 100,000 Compassionate Use Act users in California in 2004, Reply Brief for Petitioners 16, but does not explain, in terms of proportions, what their presence means for the national illicit drug market. See generally Wirtz, 392 U.S., at 196, n. 27 (Congress cannot use "a relatively trivial impact on commerce as an excuse for broad general regulation of state or private activities "); cf. General Accounting Office, Marijuana: Early Experience with Four States' Laws That Allow Use for Medical Purposes 21 -23 (Rep. No. 03 -189, Nov. 2002), http:// www .gao.gov /new.items /d03189.pdf (as visited June 3, 2005 and available in Clerk of Court's case file) (in four California counties before the identification card system was enacted, voluntarily registered medical marijuana patients were less than 0.5 percent of the population; in Alaska, Hawaii, and Oregon, statewide medical marijuana registrants represented less than 0.05 percent of the States' populations). It also provides anecdotal evidence about the CSA's enforcement. See Reply Brief for Petitioners 17 -18. The Court also offers some arguments about the effect of the Compassionate [`99] Use Act on the national market. It says that the California statute might be vulnerable to exploitation by unscrupulous physicians, that Compassionate Use Act patients may overproduce, and that the history of the narcotics trade shows the difficulty of cordoning off any drug use from the rest of the market. These arguments are plausible; if borne out in fact they could justify prosecuting Compassionate Use Act patients under the federal CSA. But, without substantiation, they add little to the CSA's conclusory statements about diversion, essentiality, and market effect. Piling assertion upon assertion does not, in my view, satisfy the substantiality test of Lopez and Morrison. III We would do well to recall how lames Madison, the father of the Constitution, described our system of joint sovereignty to the people of New York: "The powers delegated by the proposed constitution to the federal government are few and defined. Those which are to remain in the State governments are numerous and indefinite .... 'rhe powers reserved to the several States will extend to all the objects which, in the ordinary course of affairs, concern the lives, liberties, and properties of the people, [*100] and the internal order, improvement, and prosperity of the State." The Federalist No. 45, pp. 292 -293 (C. Rossiter ed. 1961). Relying on Congress' abstract assertions, the Court has endorsed making it a federal crime to grow small amounts of marijuana in one's own home for one's own medicinal use. This overreaching stifles an express choice by some States, concerned for the lives and liberties of their people, to regulate medical marijuana differently. If I were a California citizen, I would not have voted for the medical marijuana ballot initiative; if I were a California legislator 1 would not have supported the Compassionate Use Act. But whatever the wisdom of California's experiment with medical marijuana, the federalism principles that have driven our Commerce Clause cases require that room for experiment be protected in this case. For these reasons I dissent. JUSTICE THOMAS, dissenting. Respondents Diane Monson and Angel Raich use marijuana that has never been bought or sold, that has never crossed state lines, and that has had no demonstrable effect on the national market for marijuana. if Congress can regulate this under the Commerce Clause, then it can regulate virtually [* 101 ] anything -- and the Federal Government is no longer one of limited and enumerated powers. Respondents' local cultivation and consumption of marijuana is not "Commerce ... among the several States." U.S. Const., Art. 1, § 8, cl. 3. By holding that Congress may regulate activity that is neither interstate nor commerce under the Interstate Commerce Clause, the Court abandons any attempt to enforce the Constitution's limits on federal power. The majority supports this conclusion by invoking, without explanation, the Necessary and Proper Clause. Regulating respondents' conduct, however, is not "necessary and proper for carrying into Execution" Congress' restrictions on the C \Documents and Settings \Porter- S\Iksktop \Gonzsles v. Raich.doc Page 26 2005 U.S. LEXIS 4656, • interstate drug trade. Art. 1, § S, cl. IS. Thus, neither the Commerce Clause nor the Necessary and Proper Clause grants Congress the power to regulate respondents' conduct. A As 1 explained at length in United Stares v, Lopez, 514 U.S. 549 (1995), the Commerce Clause empowers Congress to regulate the buying and selling of goods and services trafficked across state lines. Id., at 586 -589 (concurring opinion). The Clause's text, structure, and history all indicate that, at [•102] the time of the founding, the term "'commerce' consisted of selling, buying, and bartering, as well as transporting for these purposes." Id, at 585 (THOMAS, J., concurring). Commerce, or trade, stood in contrast to productive activities like manufacturing and agriculture. Id., at 586 -587 (THOMAS, J., concurring). Throughout founding -era dictionaries, Madison's notes from the Constitutional Convention, The Federalist Papers, and the ratification debates, the term "commerce" is consistently used to mean trade or exchange -- not all economic or gainful activity that has some attenuated connection to trade or exchange. Ibid. (THOMAS, J., concurring); Barnett, The Original Meaning of the Commerce Clause, 68 U. Chi. L. Rev. 101, 112 -125 (2001). The term "commerce" commonly meant trade or exchange (and shipping for these purposes) not simply to those involved in the drafting and ratification processes, but also to the general public. Barnett, New Evidence of the Original Meaning of the Commerce Clause, 55 Ark. L. Rev. 847, 857 -862 (2003). Even the majority does not argue that respondents' conduct is itself "Commerce among the [*1031 several States." Art. 1, § 8, cl. 3. Ante, at 19, Monson and Raich neither buy nor sell the marijuana that they consume. They cultivate their cannabis entirely in the State of California -- it never crosses state lines, much less as part of a commercial transaction. Certainly no evidence from the founding suggests that "commerce" included the mere possession of a good or some purely personal activity that did not involve trade or exchange for value. In the early days of the Republic, it would have been unthinkable that Congress could prohibit the local cultivation, possession, and consumption of marijuana. On this traditional understanding of "commerce," the Controlled Substances Act (CSA), 21 U.S.C. § 801 et seq., regulates a great deal of marijuana trafficking that is interstate and commercial in character. The CSA does not, however, criminalize only the interstate buying and selling of marijuana. Instead, it bans the entire market -- intrastate or interstate, noncommercial or commercial -- for marijuana. Respondents are correct that the CSA exceeds Congress' commerce power as applied to their conduct, which is purely intrastate and noncommercial. [• 104] B More difficult, however, is whether the CSA is a valid exercise of Congress' power to enact laws that are "necessary and proper for carrying into Execution" its power to regulate interstate commerce. Art. 1, § 8, cl, 18. The Necessary and Proper Clause is not a warrant to Congress to enact any law that bears some conceivable connection to the exercise of an enumerated power, n I Nor is it, however, a command to Congress to enact only laws that are absolutely indispensable to the exercise of an enumerated power. n2 nl McCulloch v. Maryland, 4 Wheat. 316, 419-421 (1819); Madison, The Bank Bill, House of Representatives (Feb. 2, 1791), in 3 The Founders' Constitution 244 (P. Kurland & R. Lemer eds. 1987) (requiring "direct" rather than "remote" means -end fit); Hamilton, Opinion on the Constitutionality of the Bank (Feb. 23, 1791), in id, at 248, 250 (requiring "obvious" means -end fit, where the end was "clearly comprehended within any of the specified powers" of Congress). n2 McCulloch, supra, at 413415; D. Currie, The Constitution in the Supreme Court: The First Hundred Years 1789 -1888, p. 162 (1985). In McCulloch v. Maryland, 4 Wheat. 316 (1819), this Court, speaking through Chief Justice Marshall, set forth a test for determining when an Act of Congress is permissible under the Necessary and Proper Clause: "Let the end be legitimate, let it be within the scope of the constitution, and all means which are appropriate, which are plainly adapted to that end, which are not prohibited, but consist with the letter and spirit of the constitution, are constitutional." Id, at 421. C Documents and Settings\Portcr- S\Msktop \Gonzales v. Raich doc 000095 Page 27 2005 U.S. LEXiS 4656, " To act under the Necessary and Proper Clause, then, Congress must select a means that is "appropriate" and "plainly adapted" to executing an enumerated power; the means cannot be otherwise "prohibited" by the Constitution; and the means cannot be inconsistent with "the letter and spirit of the Constitution." /bid.; D. Currie, The Constitution in the Supreme Court: The First Hundred Years 1789 -1888, pp. 163 -164 (1985). The CSA, as applied to respondents' conduct, is not a valid exercise of Congress' power under the Necessary and Proper Clause. Congress has exercised its power over interstate commerce to criminalize trafficking in marijuana across state lines. [' 1061 The Government contends that banning Monson and Raich's intrastate drug activity is "necessary and proper for carrying into Execution" its regulation of interstate drug trafficking. Art. 1, § 8, cl. 18. See 21 U.S.C. § 801(6). However, in order to be "necessary," the intrastate ban must be more than "a reasonable means [ofJ effectuating the regulation of interstate commerce." Brief for Petitioners 14; see ante, at 19 (majority opinion) (employing rational -basis review). It must be "plainly adapted" to regulating interstate marijuana trafficking -- in other words, there must be an "obvious, simple, and direct relation" between the intrastate ban and the regulation of interstate commerce. Sabri v. United States, 541 U.S. 600, 613 (2004) (THOMAS, 1., concurring in judgment); see also United States v. Dewitt, 9 Wall. 41, 44 (1870) (finding ban on intrastate sale of lighting oils not "appropriate and plainly adapted means for carrying into execution" Congress' taxing power). On its face, a ban on the intrastate cultivation, possession and distribution of marijuana may be plainly adapted to stopping the interstate flow [" 1071 of marijuana. Unregulated local growers and users could swell both the supply and the demand sides of the interstate marijuana market, making the market more difficult to regulate. Ante, at 9 -10, 19 (majority opinion). But respondents do not challenge the CSA on its face. Instead, they challenge it as applied to their conduct. The question is thus whether the intrastate ban is "necessary and proper" as applied to medical marijuana users like respondents. n3 n3 Because respondents do not challenge on its face the CSA's ban on marijuana, 21 U.S.C. § § 841(a)(] ), 844(a), our adjudication of their as- applied challenge casts no doubt on this Court's practice in United States v. Lopez, 514 U.S. 549 (1995), and United States v. Morrison, 529 U.S. 598 (2000). In those cases, we held that Congress, in enacting the statutes at issue, had exceeded its Article I powers. Respondents are not regulable simply because they belong to a large class (local growers [' 108] and users of marijuana) that Congress might need to reach, if they also belong to a distinct and separable subclass (local growers and users of state - authorized, medical marijuana) that does not undermine the CSA's interstate ban. Ante, at 6 -7 (O'CONNOR, J., dissenting). The Court of Appeals found that respondents"' limited use is distinct from the broader illicit drug market," because "their medicinal marijuana ... is not intended for, nor does it enter, the stream of commerce." Raich v. Ashcroft, 352 F.3d 1222, 1228 (CA9 2003). if that is generally true of individuals who grow and use marijuana for medical purposes under state law, then even assuming Congress has "obvious" and "plain" reasons why regulating intrastate cultivation and possession is necessary to regulating the interstate drug trade, none of those reasons applies to medical marijuana patients like Monson and Raich. California's Compassionate Use Act sets respondents' conduct apart from other intrastate producers and users of marijuana. The Act channels marijuana use to "seriously ill Californians," Cal. Health & Safety Code Ann. § 11362.5(b)(1)(A) (West Supp. 2005), and prohibits "the diversion [ "109] of marijuana for nonmedical purposes," § 11362.5(b)(2). n4 California strictly controls the cultivation and possession of marijuana for medical purposes. To be eligible for its program, California requires that a patient have an illness that cannabis can relieve, such as cancer, AIDS, or arthritis, § l I362.5(b)(1)(A), and that he obtain a physician's recommendation or approval, § 11362.5(d). Qualified patients must provide personal and medical information to obtain medical identification cards, and there is a statewide registry of cardholders. § § 11362.715-.76. Moreover, the Medical Board of California has issued guidelines for physicians' cannabis recommendations, and it sanctions physicians who do not comply with the guidelines. See, e.g., People v. Spark, 121 Cal. App. 4th 259, 263, 16 Cal.Rptr. 3d 840, 843 (2004). n4 Other States likewise prohibit diversion of marijuana for nonmedical purposes. See, e.g., Colo. Const., Art. XV111, § 14(2)(d); Nev. Rev. Stat. § § 453A.300(I)(c )-(f) (2003); Ore. Rev. Stat. § § 475.316(lxc) -(d) (2003). C:1Documents and Settings \Porter -S \Desktop \Gonzales v Raich.doc \� � �� 2005 U.S. LEX1S 4656, * *110 Page 28 This class of intrastate users is therefore distinguishable from others. We normally presume that States enforce their own laws, Riley v. Nalional Federation of Blind of N. C., Inc., 487 U.S. 781, 795 (1988), and there is no reason to depart from that presumption here: Nothing suggests that California's controls are ineffective. "The scant evidence that exists suggests that few people -- the vast majority of whom are aged 40 or older -- register to use medical marijuana. General Accounting Office, Marijuana: Early Experiences with Four States' Laws That Allow Use for Medical Purposes 22 -23 (Rep. No. 03 -189, Nov. 2002), http: / /www.gao.gov /new.items /dOl389.pdf(all Internet materials as visited on June 3, 2005, and available in Clerk of Court's case file). In part because of the low incidence of medical marijuana use, many law enforcement officials report that the introduction of medical marijuana laws has not affected their law enforcement efforts. ki., at 32. These controls belie the Government's assertion that placing medical marijuana outside the CSA's reach "would prevent effective enforcement of the interstate ban on drug trafficking." Brief for Petitioners [*I 11 ] 33. Enforcement of the CSA can continue as it did prior to the Compassionate Use Act. Only now, a qualified patient could avoid arrest or prosecution by presenting his identification card to law enforcement officers. In the event that a qualified patient is arrested for possession or his cannabis is seized, he could seek to prove as an affirmative defense that, in conformity with state law, he possessed or cultivated small quantities of marijuana intrastate solely for personal medical use. People v. Mower, 28 Cal. 4th 457, 469-470, 49 P. 3d 1067, 1073 -1075 (2002); People v. Trippet, 56 Cal. App. 4th 1532, 1549 (1997). Moreover, under the CSA, certain drugs that present a high risk of abuse and addiction but that nevertheless have an accepted medical use -- drugs like morphine and amphetamines -- are available by prescription. 21 U.S.C. § § 812(b)(2)(A) -(B); 2I CFR § 1308.12 (2004). No one argues that permitting use of these drugs under medical supervision has undermined the CSA's restrictions. But even assuming that States' controls allow some seepage of medical marijuana into the illicit drug market, there is a multibillion - dollar [* 112] interstate market for marijuana. Executive Office of the President, Office of Nat. Drug Control Policy, Marijuana Fact Sheet 5 (Feb. 2004), http: / /www.whitchousedrugpoIicy.gov/ publ ications /factshUmarijuana/index.htm1. It is difficult to see how this vast market could be affected by diverted medical cannabis, let alone in a way that makes regulating intrastate medical marijuana obviously essential to controlling the interstate drug market. To be sure, Congress declared that state policy would disrupt federal law enforcement. It believed the across -the- board ban essential to policing interstate drug trafficking. 21 U.S.C. § 80] (6). But as JUSTICE O'CONNOR points out, Congress presented no evidence in support of its conclusions, which are not so much findings of fact as assertions of power. Ante, at 13 -14 (dissenting opinion). Congress cannot define the scope of its own power merely by declaring the necessity of its enactments. In sum, neither in enacting the CSA nor in defending its application to respondents has the Government offered any obvious reason why banning medical marijuana use is necessary to stem the tide of interstate drug trafficking. Congress' [* 113] goal of curtailing the interstate drug trade would not plainly be thwarted if it could not apply the CSA to patients like Monson and Raich. That is, unless Congress' aim is really to exercise police power of the sort reserved to the States in order to eliminate even the intrastate possession and use of marijuana. Even assuming the CSR's ban on locally cultivated and consumed marijuana is "necessary," that does not mean it is also "proper." The means selected by Congress to regulate interstate commerce cannot be "prohibited" by, or inconsistent with the "letter and spirit" of, the Constitution. McCulloch, 4 Wheat., at 421. In Lopez, I argued that allowing Congress to regulate intrastate, noncommercial activity under the Commerce Clause would confer on Congress a general "police power" over the Nation. 514 U.S., at 584, 600 (concurring opinion). This is no less the case if Congress ties its power to the Necessary and Proper Clause rather than the Commerce Clause. When agents from the Drug Enforcement Administration raided Monson's home, they seized six cannabis plants. If the Federal Government can regulate growing a half -dozen cannabis plants for [* 1141 personal consumption (not because it is interstate commerce, but because it is inextricably bound up with interstate commerce), then Congress' Article I powers -- as expanded by the Necessary and Proper Clause -- have no meaningful limits. Whether Congress aims at the possession of drugs, guns, or any number of other items, it may continue to "appropriate state police powers under the guise of regulating commerce." United States v. Morrison, 529 U.S. 598, 627 (2000) (THOMAS, J., concurring). CADocumenis and Settings \Porter- S\Desktop \Gonzales v. Raich doc 00009'7 Page 29 2005 U.S. LEXIS 4656,' Even if Congress may regulate purely intrastate activity when essential to exercising some enumerated power, see Dewitt, 9 Wall., at 44; but see Barnett, The Original Meaning of the Necessary and Proper Clause, 6 U. Pa. J. Const. L. 183, 186 (2003) (detailing statements by Founders that the Necessary and Proper Clause was not intended to expand the scope of Congress' enumerated powers), Congress may not use its incidental authority to subvert basic principles of federalism and dual sovereignty. Printz v. United States, 521 U.S. 898, 923 -924 (1997); Alden v. Maine, 527 U.S. 706, 732 -733 (1999); Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528, 585 (1985) [•115] (O'CONNOR, J., dissenting); The Federalist No. 33, pp. 204 -205 (J. Cooke ed. 1961) (A. Hamilton) (hereinafter The Federalist). Here, Congress has encroached on States' traditional police powers to define the criminal law and to protect the health, safety, and welfare of their citizens. n5 Brecht v. Abrahamson, 507 U.S. 619, 635 (1993); Hillsborough County v. Automated Medical Laboratories, Inc., 471 U.S. 707, 719 (1985). Further, the Government's rationale -- that it may regulate the production or possession of any commodity for which there is an interstate market -- threatens to remove the remaining vestiges of States' traditional police powers. See Brief for Petitioners 21 -22; cf. Ehrlich, The Increasing Federalization of Crime, 32 Ariz. St. L. J. 825, 826, 841 (2000) (describing both the relative recency of a large percentage of federal crimes and the lack of a relationship between some of these crimes and interstate commerce). This would convert the Necessary and Proper Clause into precisely what Chief Justice Marshall did not envision, a "pretext . .. for the accomplishment of objects not intrusted to the government." McCulloch, supra, at 423. [• 116] n5 In fact, the Anti - Federalists objected that the Necessary and Proper Clause would allow Congress, inter alia, to "constitute new Crimes, ... and extend [its] Power as far as [it] shall think proper; so that the State Legislatures have no Security for the Powers now presumed to remain to them; or the People for their Rights." Mason, Objections to the Constitution Formed by the Convention (1787), in 2 The Complete Anti - Federalist 11, 12 -13 (H. Storing ed. 198 1) (emphasis added). Hamilton responded that these objections were gross "misrepresentations." The Federalist No. 33, at 204. He termed the Clause "perfectly harmless," for it merely confirmed Congress' implied authority to enact laws in exercising its enumerated powers. Id., at 205; see also Lopez, 514 U.S., at 597, n. 6 (THOMAS, J., concurring) (discussing Congress' limited ability to establish nationwide criminal prohibitions); Cohens v. Virginia, 6 Wheat. 264, 426428 (1821) (finding it "clear that Congress cannot punish felonies generally," except in areas over which it possesses plenary power). According to Hamilton, the Clause was needed only "to guard against cavilling refinements" by those seeking to cripple federal power. The Federalist No. 33, at 205; id., No. 44, at 303 -304 (J. Madison). «117 The majority advances three reasons why the CSA is a legitimate exercise of Congress' authority under the Commerce Clause: First, respondents' conduct, taken in the aggregate, may substantially affect interstate commerce, ante, at 19; second, regulation of respondents' conduct is essential to regulating the interstate marijuana market, ante, at 21 -22; and, third, regulation of respondents' conduct is incidental to regulating the interstate marijuana market, ante, at 19 -20. JUSTICE O'CONNOR explains why the majority's reasons cannot be reconciled with our recent Commerce Clause jurisprudence. The majority's justifications, however, suffer from even more fundamental flaws. A The majority holds that Congress may regulate intrastate cultivation and possession of medical marijuana under the Commerce Clause, because such conduct arguably has a substantial effect on interstate commerce. The majority's decision is further proof that the "substantial effects" test is a "rootless and malleable standard" at odds with the constitutional design. Morrison, supra, at 627 (THOMAS, J., concurring). The majority's treatment of the substantial effects test is [' 118] rootless, because it is not tethered to either the Commerce Clause or the Necessary and Proper Clause. Under the Commerce Clause, Congress may regulate interstate commerce, not activities that substantially affect interstate commerce -- any more than Congress may regulate activities that do not fall within, but that affect, the subjects of its other Article I powers. Lopez, supra, at 589 (THOMAS, J., concurring). Whatever additional latitude the Necessary and Proper Clause affords, supra, at 9 -10, the question is whether Congress' legislation is essential to the regulation of interstate commerce itself -- not whether the legislation CADocuments and Settings \Porter- S \Desktop\Gonzates v. Ratch.doc Page 30 2005 U.S. LEXIS 4656,' extends only to economic activities that substantially affect interstate commerce. Supra, at 4; ante, at 5 (SCALIA, J., concurring in judgment). The majority's treatment of the substantial effects test is malleable, because the majority expands the relevant conduct. By defining the class at a high level of generality (as the intrastate manufacture and possession of marijuana), the majority overlooks that individuals authorized by state law to manufacture and possess medical marijuana exert no demonstrable effect on the[*] 19) interstate drug market. Supra, at 7 -8. The majority ignores that whether a particular activity substantially affects interstate commerce -- and thus comes within Congress' reach on the majority's approach -- can turn on a number of objective factors, like state action or features of the regulated activity itself. Ante, at 6 -7 (O'CONNOR, J., dissenting). For instance, here, if California and other States are effectively regulating medical marijuana users, then these users have little effect on the interstate drug trade. n6 n6 Remarkably, the majority goes so far as to declare this question irrelevant. It asserts that the CSA is constitutional even if California's current controls are effective, because state action can neither expand nor contract Congress' powers. Ante, at 27, n. 38. The majority's assertion is misleading. Regardless of state action, Congress has the power to regulate intrastate economic activities that substantially affect interstate commerce (on the majority's view) or activities that are necessary and proper to effectuating its commerce power (on my view). But on either approach, whether an intrastate activity falls within the scope of Congress' powers turns on factors that the majority is unwilling to confront. The majority apparently believes that even if States prevented any medical marijuana from entering the illicit drug market, and thus even if there were no need for the CSA to govern medical marijuana users, we should uphold the CSA under the Commerce Clause and the Necessary and Proper Clause. Finally, to invoke the Supremacy Clause, as the majority does, ibid., is to beg the question. The CSA displaces California's Compassionate Use Act if the CSA is constitutional as applied to respondents' conduct, but that is the very question at issue. [' 1201 The substantial effects test is easily manipulated for another reason. This Court has never held that Congress can regulate noneconomic activity that substantially affects interstate commerce. Morrison, 529 U.S., at 613 ( "Thus far in OUT Nation's history our cases have upheld Commerce Clause regulation of intrastate activity only where that activity is economic in nature" (emphasis added)); Lopez, supra, at 560. To evade even that modest restriction on federal power, the majority defines economic activity in the broadest possible terms as the the production, distribution, and consumption of commodities. "' n7 Ante, at 23 (quoting Webster's Third New International Dictionary 720 (1966) (hereinafter Webster's 3d). This carves out a vast swath of activities that are subject to federal regulation. See ante, at 8- 9 (O'CONNOR, J., dissenting). If the majority is to be taken seriously, the Federal Government may now regulate quilting bees, clothes drives, and potluck suppers throughout the 50 States. This makes a mockery of Madison's assurance to the people of New York that the "powers delegated" to the Federal Government are "few and defined, [• 1211 " while those of the States are "numerous and indefinite." The Federalist No. 45, at 313 (J. Madison). n7 Other dictionaries do not define the term "economic" as broadly as the majority does. See, e.g., The American Heritage Dictionary of the English Language 583 (3d ed. 1992) (defining "economic" as "of or relating to the production, development, and management of material wealth, as of a country, household, or business enterprise" (emphasis added)). The majority does not explain why it selects a remarkably expansive 40- year -old definition. Moreover, even a Court interested more in the modem than the original understanding of the Constitution ought to resolve cases based on the meaning of words that are actually in the document. Congress is authorized to regulate "Commerce," and respondents' conduct does not qualify under any definition of that term. n8 The majority's opinion only illustrates the steady drift away from the text of the Commerce Clause. "There is an inexorable expansion from "'commerce, [• 122] "' ante, at 1, to "commercial" and "economic" activity, ante, at 20, and finally to all "production, distribution, and consumption" of goods or services for which there is an "established ... interstate market," ante, at 23. Federal power expands, but never contracts, with each new locution. The majority is not interpreting the Commerce Clause, but rewriting it. C \Documents and Settings \Porter- S \Desktop\Gon»les v. Raich.doc Page 31 2005 U.S. LEX1S 4656, • n8 See, e.g., id., at 380 ( "the buying and selling of goods, especially on a large scale, as between cities or nations "); The Random House Dictionary of the English Language 411 (2d ed. 1987) ( "an interchange of goods or commodities, esp. on a large scale between different countries ... or between different parts of the same country"); Webster's 3d 456 ( "the exchange or buying and selling of commodities esp. on a large scale and involving transportation from place to place "). The majority's rewriting of the Commerce Clause seems to be rooted in the belief that, unless the Commerce Clause covers the entire web of human activity, [• 1231 Congress will be left powerless to regulate the national economy effectively. Ante, at 15 -16; Lopez, 514 U.S., at 573 -574 (KENNEDY, J., concurring). The interconnectedness of economic activity is not a modern phenomenon unfamiliar to the Framers. /d., at 590 -593 (THOMAS, J., concurring); Letter from J. Madison to S. Roane (Sept. 2, 1819), in 3 The Founders' Constitution 259 -260 (P. Kurland & R. Lemer eds. 1987). Moreover, the Framers understood what the majority does not appear to fully appreciate: There is a danger to concentrating too much, as well as too little, power in the Federal Government. This Court has carefully avoided stripping Congress of its ability to regulate interstate commerce, but it has casually allowed the Federal Government to strip States of their ability to regulate intrastate commerce -- not to mention a host of local activities, like mere drug possession, that are not commercial. One searches the Court's opinion in vain for any hint of what aspect of American life is reserved to the States. Yet this Court knows that the Constitution created a Federal Government of limited powers. "' New York v. United States, 505 U.S. 144, 155 (1992) [" 1241 (quoting Gregory v. Ashcroft, 501 L.S. 452, 457 (1991)). That is why today's decision will add no measure of stability to our Commerce Clause jurisprudence: This Court is willing neither to enforce limits on federal power, nor to declare the Tenth Amendment a dead letter. If stability is possible, it is only by discarding the stand -alone substantial effects test and revisiting our definition of "Commerce among the several States." Congress may regulate interstate commerce -- not things that affect it, even when summed together, unless truly "necessary and proper" to regulating interstate commerce. B The majority also inconsistently contends that regulating respondents' conduct is both incidental and essential to a comprehensive legislative scheme. Ante, at 19 -20, 21 -22. 1 have already explained why the CSA's ban on local activity is not essential. Supra, at 7 -8. However, the majority further claims that, because the CSA covers a great deal of interstate commerce, it "is of no moment" if it also "ensnares some purely intrastate activity." Ante, at 19. So long as Congress casts its net broadly over an interstate market, according to the majority, it [" 1251 is free to regulate interstate and intrastate activity alike. This cannot be justified under either the Commerce Clause or the Necessary and Proper Clause. If the activity is purely intrastate, then it may not be regulated under the Commerce Clause. And if the regulation of the intrastate activity is purely incidental, then it may not be regulated under the Necessary and Proper Clause. Nevertheless, the majority terms this the "pivotal" distinction between the present case and Lopez and Morrison. Ante, at 20. In Lopez and Morrison, the parties asserted facial challenges, claiming "that a particular statute or provision fell outside Congress' commerce power in its entirety." Ante, at 20. Here, by contrast, respondents claim only that the CSA falls outside Congress' commerce power as applied to their individual conduct. According to the majority, while courts may set aside whole statutes or provisions, they may not "excise individual applications of a concededly valid statutory scheme." Ante, at 20 -21; see also Perez v. United States, 402 U.S. 146, 154 (1971); Maryland v. Wirtz, 392 U.S. 183, 192 -193 (1968). [''126] It is true that if respondents' conduct is part of a "class of activities ... and that class is within the reach of federal power," Perez, supra, at 154 (emphases deleted), then respondents may not point to the de minimis effect of their own personal conduct on the interstate drug market, Wirtz, supra, at 196, n. 27. Ante, at 6 (O'CONNOR, 1., dissenting). But that begs the question at issue: whether respondents "'class of activities" is "within the reach of federal power," which depends in turn on whether the class is defined at a low or a high level of generality. Supra, at 5. If medical marijuana patients like Monson and Raich largely stand outside the interstate drug market, then courts must excise them from the CSA's coverage. Congress expressly provided that if "a provision [of the CSA] is held invalid in one of more of its applications, the provision shall remain in effect in all its valid applications that are severable." 21 U.S.C. § 901 (emphasis added); see also United States v. Booker, 543 U.S. _ _ (2005) (slip op., at 9, and n. 9) (THOMAS, J., dissenting in part). C:\Documents and Settings\Porler- S\Dcsktop \Gonzales v. Raich.doc 000100 Page 32 2005 U.S. LEXIS 4656, » Even in the [» 127] absence of an express severability provision, it is implausible that this Court could set aside entire portions of the United States Code as outside Congress' power in Lopez and Morrison, but it cannot engage in the more restrained practice of invalidating particular applications of the CSA that are beyond Congress' power. This Court has regularly entertained as- applied challenges under constitutional provisions, see United States v. Raines, 362 U.S. 17, 20 -21 (1960), including the Commerce Clause, see Katzenbach v. McClung, 379 U.S. 294, 295 (1964); Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241, 249 (1964); Wickard v. Filburn, 317 U.S. 111, 113 -114 (1942). There is no reason why, when Congress exceeds the scope of its commerce power, courts may not invalidate Congress' overreaching on a case -by -case basis. The CSA undoubtedly regulates a great deal of interstate commerce, but that is no license to regulate conduct that is neither interstate nor commercial, however minor or incidental. If the majority is correct that Lopez and Morrison are distinct because they were facial [» 1281 challenges to "particular statutes or provisions," ante, at 20, then congressional power turns on the manner in which Congress packages legislation. Under the majority's reasoning, Congress could not enact -- either as a single- subject statute or as a separate provision in the CSA -- a prohibition on the intrastate possession or cultivation of marijuana. Nor could it enact an intrastate ban simply to supplement existing drug regulations. However, that same prohibition is perfectly constitutional when integrated into a piece of legislation that reaches other regulable conduct. Lopez, 514 U.S., at 600- 601 (THOMAS, J., concurring). Finally, the majority's view — that because some of the CSA's applications are constitutional, they must all be constitutional -- undermines its reliance on the substantial effects test. The intrastate conduct swept within a general regulatory scheme may or may not have a substantial effect on the relevant interstate market. "One always can draw the circle broadly enough to cover an activity that, when taken in isolation, would not have substantial effects on commerce." Id., at 600 (THOMAS, J., concurring). [» 1291 The breadth of legislation that Congress enacts says nothing about whether the intrastate activity substantially affects interstate commerce, let alone whether it is necessary to the scheme. Because medical marijuana users in California and elsewhere are not placing substantial amounts of cannabis into the stream of interstate commerce, Congress may not regulate them under the substantial effects test, no matter how broadly it drafts the CSA. The majority prevents States like California from devising drug policies that they have concluded provide much - needed respite to the seriously ill. It does so without any serious inquiry into the necessity for federal regulation or the propriety of "displacing state regulation in areas of traditional state concern," id., at 583 (KENNEDY, J., concurring). The majority's rush to embrace federal power "is especially unfortunate given the importance of showing respect for the sovereign States that comprise our Federal Union." United States v. Oakland Cannabis Buyers' Cooperative, 532 U.S. 483, 502 (200 1) (STEVENS, J., concurring in judgment). Our federalist system, properly understood, allows California [» 130] and a growing number of other States to decide for themselves how to safeguard the health and welfare of their citizens. 1 would affirm the judgment of the Court of Appeals. I respectfully dissent. C1Documents and Settings \Poser- S\Desktop \Gonzales v Raich doc 000101 11R 2087 111 EXHIBIT E 109th CONGRESS I st Session II. R. 2087 To provide for the medical use of marijuana in accordance with the laws of the various States. IN THE HOUSE OF REPRESENTATIVES May 4, 2005 Mr. FRANK of Massachusetts (for himself, Mr. PALL, Mr. ROHRABACHER, Mr. FARR, Mr. SANDERS, Mr. KUCINICH, Mr. ABERCROMBIE, Mr. WEXLER, Mr. WAXMAN, Mr. HINCHEY, Mr. GEORGE MILLER of California, Mr. MCDERMOTT, Ms. SCHAKOWSKY, Ms. WOOLSEY, Mr. DEFAZIO, Mr. MCGOVERN, Mr. BLUMENAUER, Ms. LEE, Mr. CASE, Mr. GRIJALVA, Mr. UDALL of Colorado, Mr. STARK, Mr. CAPUANO, Ms. JACKSON -LEE of Texas, Ms. ESHOO, Mr. HONDA, Mr. OLVER, Mr. MORAN of Virginia, Mr. ANDREWS, Ms. LINDA T. SANCHEZ of California, and Ms. BALDWIN) introduced the following bill; which was referred to the Committee on Energy and Commerce A BILL To provide for the medical use of marijuana in accordance with the laws of the various States. Be it enacted by the Senate and House of Representatives of the United .States of America in Congress assembled, SECTION 1. SHORT TITLE. This Act may be cited as the 'States' Rights to Medical Marijuana Act'. SEC. 2. CONTROLLED SUBSTANCES ACT. (a) Schedule- Marijuana is moved from schedule I of the Controlled Substances Act to schedule 1I of such Act. (b) Prescription or Recommendation - (1) IN GENERAL- No provision of the Controlled Substances Act shall prohibit or otherwise restrict -- 000102 (A) the prescription or recommendation of marijuana by a physician for medical use, (B) an individual from obtaining and using marijuana from a prescription or recommendation of marijuana by a physician for medical use by such individual, or (C) a pharmacy from obtaining and holding marijuana for the prescription or recommendation of marijuana by a physician for medical use under applicable State law in a State in which marijuana may be prescribed or recommended by a physician for medical use under applicable State law. (2) PRODUCTION- No provision of the Controlled Substances Act shall prohibit or otherwise restrict an entity established by a State, in which marijuana may be prescribed or recommended by a physician for medical use, for the purpose of producing marijuana for prescription or recommendation by a physician for medical use from producing and distributing marijuana for such purpose. SEC. 3. FEDERAL FOOD, DRUG, AND COSMETIC ACT. (a) In General- No provision of the Federal Food, Drug, and Cosmetic Act shall prohibit or otherwise restrict- - (1) the prescription or recommendation of marijuana by a physician for medical use, (2) an individual from obtaining and using marijuana from a prescription or recommendation of marijuana by a physician for medical use by such individual, or (3) a pharmacy from obtaining and holding marijuana for the prescription or recommendation of marijuana by a physician for medical use, in a State in which marijuana may be prescribed or recommended by a physician for medical use under applicable State law. (b) Production- No provision of the Federal Food, Drug, and Cosmetic Act shall prohibit or otherwise restrict an entity established by a State, in which marijuana may be prescribed or recommended by a physician for medical use, for the purpose of producing marijuana for prescription or recommendation by a physician for medical use from producing and distributing marijuana for such purpose. SEC. 4. RELATION OF ACT TO CERTAIN PROHIBITIONS RELATING TO SMOKING. This Act does not affect any Federal, State, or local law regulating or prohibiting smoking in public. END 000103 ORDINANCE NO. AN INTERIM URGENCY ORDINANCE OF THE CITY COUNCIL OF THE MOORPARK, CALIFORNIA, MAKING FINDINGS AND EXTENDING A TEMPORARY MORATORIUM ON THE ESTABLISHMENT AND OPERATION OF MEDICAL MARIJUANA DISPENSARIES THE CITY COUNCIL OF THE CITY OF MOORPARK DOES ORDAIN AS FOLLOWS: SECTION 1. Findings A. In 1996, the voters of the State of California approved Proposition 215, which was codified as Health and Safety Code Section 11362.5, et seq., and entitled the Compassionate Use Act of 1996 ( "the Act "). B. The intent of Proposition 215 was to enable persons who are in need of medical marijuana for medical purposes to obtain and use it under limited, specified circumstances. C. On January 1, 2004, SB 420 went into effect. SB 420 was enacted by the Legislature to clarify the scope of the Act and to allow cities and counties to adopt and enforce rules and regulations consistent with SB 420 and the Act. D. On July 6, 2005, the City Council adopted a forty -five (45) day interim urgency ordinance to impose a moratorium on the issuance of any entitlement for any medical marijuana dispensary. The Moorpark Municipal Code, including the Moorpark Zoning Code, does not otherwise address or regulate in any manner the existence or location of medical marijuana dispensaries. E. After receiving inquiries from persons interested in establishing medical marijuana dispensaries, numerous other cities in the State of California have adopted ordinances prohibiting or heavily regulating such dispensaries. Because a significant number of cities, including cities in the County of Ventura such as the City of Simi Valley, have prohibited or heavily regulated medical marijuana dispensaries, there is a substantially increased likelihood that such establishments will seek to locate in the City of Moorpark, thus creating a current and immediate threat to the public health, safety, or welfare. F. Other California cities that have permitted the establishment of medical marijuana dispensaries have witnessed an increase in crime, such as burglaries, robberies, and sales of illegal drugs in the areas immediately surrounding such dispensaries. Recent examples from last year include: men who kicked in the window of a medical marijuana dispensary in Oakland CC ATTACHMENT 3 0001.04 Ordinance No. Page 2 and tried to burglarize the dispensary; in Alameda County, thieves broke into a medical marijuana dispensary, burglarized the safe and robbed persons present. Furthermore, the United States Department of Justice's California Medical Marijuana Information report has advised that large -scale drug traffickers have been posing as "care givers" to obtain and sell marijuana, thus increasing the likelihood that such parties would traffic in illegal drugs in the City, thereby endangering the public health, safety and welfare. G. The Supreme Court of the United States ruled in United States v. Oakland Cannabis Buyers' Cooperative, 532 US 483 (2001) that, notwithstanding California law, the federal Controlled Substances Act continues to prohibit marijuana use, distribution, and possession, and that no medical necessity exception exists to these prohibitions. H. The Supreme Court of the United States ruled in Gonzales v. Raich, U.S. LEXIS 4656 (2005), that pursuant to the commerce clause, the federal government has the power to prohibit the local cultivation and use of marijuana, even though such cultivation and use complies with California law. I. In Gonzales v. Raich, the Supreme Court of the United States did not indicate that California law was invalid, but rather, merely indicated that the federal government could continue to enforce its medical marijuana laws. J. Members of Congress continue to introduce bills which would, among other things, have the effect of legalizing the medical use of marijuana in California, or impose moratoriums on all federal government enforcing marijuana laws against users of marijuana for medical purposes. For example, on May 4, 2005, Representative Frank introduced HR 2087, with 36 co- sponsors, to provide for the medical use of marijuana in accordance with the laws of the various States. The most recent action on HR 2087 was taken May 13, 2005, when it was referred to the House Subcommittee on Health. K. Even though medical marijuana dispensaries violate federal law, these facilities continue to operate throughout California. Prior to the issuance of Gonzales v. Raich, the federal government has only infrequently enforced its anti -drug laws against medical marijuana dispensaries. For example, as of June 7, 2005, there were nine medical marijuana facilities operating in the City of West Hollywood. It is unclear whether, after Gonzales v. Raich, the federal government will strongly enforce its laws. 000105 Ordinance No. Page 3 L. To address the apparent conflict between federal and state law, as well as the community and statewide concerns regarding the establishment of medical marijuana dispensaries, and the fact that federal legislation and enforcement is currently in flux, it is necessary for the City of Moorpark to study the potential impacts such facilities may have on the public health, safety, and welfare. M. Based on the foregoing, the City Council finds that approving additional subdivisions, use permits, variances, building permits or any other applicable entitlement providing for the establishment and /or operation of medical marijuana dispensaries prior to (1) resolving whether federal law will be routinely enforced against medical marijuana dispensaries; (2) the City's completion of its study of the potential impact of such facilities; and (3) resolving any zoning conflicts based on the fact that no zoning currently exists in the City for such dispensaries; would result in the current and immediate threat to the public health, safety, and welfare. The City finds that a temporary moratorium on the issuance of such entitlements is therefore necessary. SECTION 2. Imposition of Moratorium A. In accordance with the authority granted the City of Moorpark under Government Code Section 65858, and pursuant to the findings stated herein, from and after the date of this ordinance, no use permit, variance, building permit, business license or other applicable entitlement shall be approved or issued for the establishment or operation of a medical marijuana dispensary for a period of twenty two (22) months and fifteen (15) days. B. "Medical marijuana dispensary" includes any site, facility, location, use, cooperative or business which distributes, sells, exchanges, processes, delivers, gives away, or cultivates marijuana for medical purposes to qualified patients, health care providers, patients' primary caregivers, or physicians pursuant to Proposition 215, Health & Safety Code § 11362.5 et seq. or any State regulations adopted in furtherance thereof. Marijuana shall also mean cannabis and all parts of that plant. C. This ordinance is an extension of the existing forty - five (45) day interim urgency ordinance, is adopted pursuant to the authority granted to the City of Moorpark by Government Code Section 65858, and is for the immediate preservation of the 000106 Ordinance No. Page 4 public health, safety, and welfare. The facts constituting the urgency are: (1) California cities that have permitted the establishment of medical marijuana dispensaries have found that such dispensaries have resulted in negative and harmful secondary effects, such as an increase in crime, including robberies, burglaries, and sales of illegal drugs in the areas immediately surrounding medical marijuana dispensaries; (2) after receiving inquiries from persons interested in establishing medical marijuana dispensaries, numerous other cities in California, including cities in the County of Ventura, have adopted ordinances prohibiting or heavily regulating such dispensaries, and because a significant portion of the region has prohibited or heavily regulated medical marijuana dispensaries, there is a substantially increased likelihood that such establishments will seek to locate in the City of Moorpark; (3) the City of standards in its Municipal operation, and concentration within the City; Moorpark does not currently have Code relating to the location, of medical marijuana dispensaries (4) absent the adoption of this interim urgency ordinance, the establishment and operation of medical marijuana dispensaries in the City of Moorpark would result in the negative and harmful secondary effects other cities have experienced, as identified above; (5) currently the state and federal laws relating to medical marijuana dispensaries conflict, and federal legislation continues to be introduced which, if passed, would substantially change the regulation of medical marijuana facilities; and (6) as a result of the conflict in state and federal laws on the matter, coupled with negative and harmful secondary effects associated with medical marijuana dispensaries, the current and immediate threat such secondary effects pose to the public health, safety, and welfare, and the zoning conflicts that would be created by the establishment and operation of a medical marijuana dispensary, it is necessary to establish a temporary, twenty -two (22) month and fifteen (15) day moratorium on the establishment and operation of new medical marijuana dispensaries in the City, pending resolution of the conflict of laws by the Congress of the United States, completion of the City's study of the potential impacts of medical marijuana dispensaries, and possible amendments to the City's zoning ordinances. 000107 Ordinance No. Page 5 SECTION 3. Compliance with California Environmental Quality Act The City Council finds that this ordinance is not subject to the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15060(c) (3) (the activity is not a project as defined in Section 15378) of the CEQA Guidelines, California Code of Regulations, Title 14, Chapter 3, because it has no potential for resulting in physical change to the environment, directly or indirectly; it prevents changes in the environment pending the completion of the contemplated municipal code review. SECTION 4. Severability If any provision of this ordinance or the application thereof to any person or circumstance is held invalid, such invalidity shall not affect other provisions or applications of the ordinance which can be given effect without the invalid provision or application, and to this end the provisions of this ordinance are severable. The City Council hereby declares that it would have adopted this ordinance irrespective of the invalidity of any particular portion thereof. SECTION 5. Effective Date Consistent with Government Code 65858, this ordinance shall become effective immediately upon adoption if adopted by at a least four - fifths vote of the City Council and shall be in effect for twenty -two (22) months and fifteen (15) days from the date of adoption unless extended by the City Council as provided for in the Government Code. SECTION 6. Publication The City Clerk shall certify to the adoption of this ordinance and cause it, or a summary of it, to be published once in a newspaper of general circulation printed and published within the City of Moorpark. 000108 Ordinance No. Page 6 PASSED AND ADOPTED this 20th day of July, 2005. ATTEST: Deborah Traffenstedt, City Clerk Patrick Hunter, Mayor 00010to