United States v. Oakland Cannabis Buyers' Cooperative

United States v. Oakland Cannabis Buyers' Cooperative
Supreme Court of the United States
Argued March 28, 2001 Decided May 14, 2001
Full case name	United States of America v. Oakland Cannabis Buyers' Cooperative
Citations	532 U.S. 483 (more) 121 S. Ct. 1711 (2001)
Holding
There is no medical necessity defense to a charge under the Controlled Substances Act, 21 U.S.C. § 841 et seq.
Court membership
Case opinions
Majority	Thomas, joined by Rehnquist, O'Connor, Scalia, Kennedy
Concurrence	Stevens, joined by Souter, Ginsburg
Breyer took no part in the consideration or decision of the case.
Laws applied
21 U.S.C. § 841 et seq.

In United States v. Oakland Cannabis Buyers' Cooperative, 532 U.S. 483 (2001), the United States Supreme Court rejected the common-law medical necessity defense to crimes enacted under the federal Controlled Substances Act of 1970, regardless of their legal status under the laws of states such as California that recognize a medical use for marijuana. Oakland Cannabis Buyers' Cooperative was represented by Gerald Uelmen.

This case would not have arisen without the passage of Proposition 215, California's Compassionate Use Act. The Act allowed a patient or his primary caregiver to cultivate or possess marijuana on the advice of a physician. Bolstered by this enactment, certain groups organized to supply marijuana to patients in a manner consistent with the Act. The Oakland Cannabis Buyers' Cooperative is one such group.

In January 1998, the U.S. Government sued the OCBC to stop the cultivation and distribution of marijuana in violation of federal law. The Government based its argument on the provisions of the Controlled Substances Act, which forbade the distribution, manufacture, and possession with intent to distribute or manufacture a controlled substance (including marijuana). The lawsuit began in the U.S. District Court for the Northern District of California, and came before district judge Charles Breyer. Judge Breyer concluded that the Government would likely prevail on the merits, and issued the injunction.

The OCBC believed, however, that ceasing the distribution of marijuana to patients would be harmful to them, and therefore chose to violate Judge Breyer's injunction. The Government brought contempt proceedings against the OCBC. The OCBC argued that the distributions were medically necessary. Judge Breyer found OCBC in contempt, denied OCBC's request to authorize medically necessary distributions of marijuana, and authorized the U.S. Marshals to seize OCBC's premises. At this point, the OCBC agreed to stop distributing marijuana. It also appealed Judge Breyer's decision to the Ninth Circuit.