Hello Farms Licensing MI, LLC v. GR Vending MI, LLC -Eastern District of Michigan at Bay City
Split Score
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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.
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
RFA bars prosecution only if the defendant strictly complies with all state medical-marijuana regulations (strict-compliance standard).
RFA bars prosecution so long as the defendant generally or substantially complies with state medical-marijuana law; strict compliance is not required.
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.