United States v. Oakland Cannabis Buyers' Coop

PETITIONER: United States
RESPONDENT: Oakland Cannabis Buyers' Coop
LOCATION: Attorney General's Office of MA

DOCKET NO.: 00-151
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 532 US 483 (2001)
ARGUED: Mar 28, 2001
DECIDED: May 14, 2001

ADVOCATES:
Barbara D. Underwood - Department of Justice, argued the cause for the petitioner
Gerald F. Uelmen - Argued the cause for the respondents

Facts of the case

Under California's Compassionate Use Act of 1996, the Oakland Cannabis Buyers' Cooperative was organized to distribute marijuana to qualified patients for medical purposes. In 1998, the United States sued to enjoin the Cooperative and its executive director. The government argued that the Cooperative's activities violated the Controlled Substances Act's prohibitions on distributing, manufacturing, and possessing with the intent to distribute or manufacture a controlled substance. Although the District Court enjoined it, the Cooperative continued to distribute marijuana. Rejecting the Cooperative's medical necessity defense, the court found the Cooperative in contempt. On appeal, the Court of Appeals concluded that the medical necessity defense was a legally cognizable defense. On remand from the Court of Appeals, the District Court modified its injunction to incorporate a medical necessity defense, under which medically necessary distributions were to be permitted.

Question

Does a medical necessity exception to the Controlled Substances Act's prohibition on the manufacture and distribution of various drugs, including marijuana, exist?

Media for United States v. Oakland Cannabis Buyers' Coop

Audio Transcription for Oral Argument - March 28, 2001 in United States v. Oakland Cannabis Buyers' Coop

Audio Transcription for Opinion Announcement - May 14, 2001 in United States v. Oakland Cannabis Buyers' Coop

Justice Thomas has an opinion to announce.

Clarence Thomas:

I have the opinion in the United States versus Oakland Cannabis Buyers Cooperative.

This case comes to us on a writ of certiorari to the United States Court of Appeals for the Ninth Circuit.

Respondent Oakland Cannabis Buyers Cooperative was organized to distribute marijuana to qualified patients for medical purposes.

The United States sought to enjoin the Cooperative’s efforts under the Controlled Substances Act, which prohibits the manufacture and distribution of certain drugs including marijuana.

The District Court granted the Government’s request for a preliminary injunction.

The Court then rejected the Cooperative’s motion to modify the injunction to permit distributions that are medically necessary.

The Cooperative appealed and the Ninth Circuit reversed the District Court’s ruling on the motion to modify the injunction.

According to the Ninth Circuit, medical necessity is a legally cognizable defense to the statute’s prescriptions.

The Ninth Circuit also concluded that the District Court could have issued an injunction more limited in scope than the Controlled Substances Act, and thus instructed the District Court to consider the criteria for the medical necessity exception.

In an opinion filed with the Clerk today, we reverse and remand.

We hold that there was no medical necessity exception to the Controlled Substances Act’s prohibition on manufacturing and distributing marijuana.

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 meriting an exception.

Whereas, other drugs can be dispensed and prescribed for medical use, the same is not true for marijuana, which according to the Act, has no currently accepted medical use.

The Ninth Circuit erred in instructing the District Court to consider the criteria for medical necessity exception when fashioning the injunction.

Although District Courts that are properly acting as courts of equity generally have discretion in designing relief.

They cannot ignore Congress’ judgment expressed explicitly in legislation.

Justice Stevens has filed an opinion concurring in the judgment, which Justices Souter and Ginsburg have joined.

Justice Breyer took no part in the consideration or decision of this case.