Hello Farms Licensing MI, LLC v. GR Vending MI, LLC -Eastern District of Michigan at Bay City

Circuit 6Sep 10, 2026

Split Score

SplitScore: 57/100

Case Summary

Disposition

Reversed

The Sixth Circuit reversed a $31.8-million jury verdict in favor of Hello Farms, holding that federal courts may not enforce a marijuana-supply contract because the agreement requires conduct that is a felony under the federal Controlled Substances Act. The panel concluded that neither the federal appropriations rider (Rohrabacher-Farr Amendment) nor the 2026 rescheduling of certain medical-marijuana products alters the CSA’s explicit federal policy barring enforcement of such contracts.

View Full Opinion Document (PDF)

Circuit Split Identified

Legal Issue

Whether, and under what standard, the Rohrabacher-Farr Amendment bars Department of Justice prosecution of state-legal medical-marijuana activity.

Circuit Positions

Circuit 9

RFA bars prosecution only if the defendant strictly complies with all state medical-marijuana regulations (strict-compliance standard).

Circuit 1Circuit 10

RFA bars prosecution so long as the defendant generally or substantially complies with state medical-marijuana law; strict compliance is not required.

Circuit 6(this circuit)

Issue undecided; Sixth Circuit expressly declines to rule on the RFA’s scope in this opinion.

Conflict Summary

The Ninth Circuit requires defendants to show ‘strict compliance’ with all state medical-marijuana laws before the rider bars prosecution, while the First and Tenth Circuits reject a strict-compliance test and apply a more flexible standard of substantial or general compliance. In the present opinion, the Sixth Circuit expressly declines to decide the issue and therefore takes no substantive position.

Parties & Counsel

Parties

Appellant:GR Vending MI, LLC and CURA MI, LLC
Appellee:Hello Farms Licensing MI, LLC

Legal Counsel

Appellant:JENNER & BLOCK LLP; HONIGMAN LLP
Appellee:STINAR LANNEN, PLLC; PLUNKETT COONEY