For any company, going public is fraught with securities litigation risks. As highlighted in the recent New York State Appellate Court decision In The Matter of Sundial Growers, Inc. Securities Litigation, companies operating in the relatively new, but rapidly growing, frontier of legal cannabis must be thorough and careful when issuing public disclosures. Companies must also be aware of venue issues: in particular, the potential for simultaneous federal and state proceedings related to IPO filings following the United States Supreme Court’s 2018 Cyan decision, and should consider the adoption of Federal Forum Provisions (“FFPs”) to avoid this problem.

Sundial Growers Securities Litigation

Sundial Growers is a Canadian company which commenced cannabis production in December 2018, following legalization of adult-use cannabis in Canada. The company went public via an Initial Public Offering in August 2019.

As is common following an IPO, plaintiff, on behalf of a putative class of investors, brought a claim under the Securities Act of 1933 (the “Securities Act”) alleging material misstatements and omissions in the IPO’s registration statement that had been filed with the Securities and Exchange Commission. (“SEC”).

Continue Reading Recent New York Appellate Decision Highlights That Cannabis Companies Going Public are Subject to Typical Securities Litigation Risks—and Defenses

Welcome back to The Week in Weed, your Friday look at what’s happening in the world of legalized marijuana.

The new federal hemp rules take effect March 22.  The Idaho House voted in favor of industrial hemp.  Rhode Island Senators introduced a bill to legalize cannabis.  Support for adult-use marijuana grows in Maryland.  The situation in South Dakota grows more complicated by the day.  Mexico could legalize any day now.  And finally, if you’re in the market for a new car, consider one made of hemp.

hemp rules

The US Department of Agriculture announced this week that federal hemp rules will go into effect on March 22, with no changes or additional delay.  We looked at what the new rules will mean here.

idaho hemp

Idaho is the only state where hemp is still illegal.  That may be about to change.  The state House passed a bill allowing farmers to grow the crop, with a limit of 0.3% THC.  The next stop for the legislation is the state Senate.

rhode island

With Massachusetts and its legal market on one side, and Connecticut making noises about legalizing on the other, it seems inevitable that Rhode Island would join its New England neighbors in allowing adult-use cannabis.  Two state Senators introduced a bill this week to do just that.  Further bulletins as events warrant.

maryland

Another state feeling pressure from events close by is Maryland.  Virginia will have a legal market, and DC may allow sales (depending on Congress, of course).  And there’s talk of legalizing in Delaware.  So how do Marylanders feel about adult-use in their state?  They’re strongly in favor.  Two-thirds of those asked in a recent poll indicated they supported legalization, the largest percentage recorded.

south dakota

As long-time (long-suffering?) readers are well aware, South Dakota passed two ballot initiatives last November, one legalizing medical marijuana and one legalizing adult-use marijuana.  Although Arizona’s legal market is already up and running, and New Jersey finally managed to pass implementing legislation, the Mount Rushmore State is still mired in debate.  This week’s news: the state Senate passed a bill that will delay a medical marijuana program, but decriminalize possession of small amounts of cannabis in the meantime.  It may be in for rough sailing in the state House, which has so far shared Governor Noem’s opposition to any legalization.

breaking news

The House failed to pass the Senate version of the legalization bill, which means the ballot initiative goes into effect as written.

Mexico

Shifting our attention south, we see that Mexico is moving towards adult-use legalization.  The Chamber of Deputies (the lower House in the country’s legislature) just passed a legalization bill.  The legislation now goes back to the country’s Senate for a final vote.  The country legalized medical marijuana earlier this year.

and finally

Are you looking to purchase a new car?  Are you looking for a model that’s both environmentally friendly and contains cannabis?  Have we got the vehicle for you!  Aptera Motors is taking orders for a solar-powered car made with hemp, with production to start at the end of the year.

Stay safe and be well everyone – we’ll see you next week!

Recognizing that state medical and recreational marijuana laws are sweeping the nation, and that a recent survey reflected that nearly half of surveyed American adults have used marijuana, the Acting Director of the U.S. Office of Personnel Management (OPM) issued a memorandum regarding “Assessing the Suitability/Fitness of Applicants or Appointees on the Basis of Marijuana Use; Maintaining a Drug-Free Workplace.” In it, Acting Director Kathleen M. McGettigan offered guidance to deal with the problem of federal agencies “increasingly encountering individuals whose knowledge, skills, and abilities make them well-qualified for a position, but whose marijuana use may or may not be of concern when considering the suitability or fitness of the individual for the position.”

Generally speaking, in determining whether an applicant is suitable or fit for a particular government agency job, current regulations state that agencies must base their suitability determinations on the presence or absence of certain factors set forth in those same regulations. No factor is automatically disqualifying. Thus, the agency must conduct a case-by-case assessment to determine the impact, if any, the conduct at issue might have on the integrity and efficiency of the federal government. In conducting this assessment, the agency must consider:

  • the nature of the position for which the person is applying or in which the person is employed;
  • the nature and seriousness of the conduct;
  • the circumstances surrounding the conduct;
  • the recency of the conduct;
  • the age of the person at the time of the conduct;
  • any contributing societal conditions; and
  • the absence or presence of rehabilitation or efforts toward rehabilitation.

The two factors in the federal regulations that might be implicated when an applicant uses or possesses marijuana are: (1) illegal use of narcotics, drugs, or other controlled substances without evidence of substantial rehabilitation; and (2) criminal or dishonest conduct. According to the Acting Director:

  • Prior marijuana use is not automatically disqualifying: “[I]t would be inconsistent with suitability regulations to implement a policy of finding an individual unfit or unsuitable for federal service solely on the basis of recency of marijuana use.” In fact, even where a person has illegally used marijuana without evidence of substantial rehabilitation, agencies cannot find that person unsuitable unless there is a nexus between the conduct and the “integrity or . . . efficiency of the service.” Again, consideration should be given to the factors outlined above. And someone who used marijuana, but no longer does so, should be viewed differently than someone currently using. When considering an applicant who used in the past, consideration should be given to the nature and seriousness of the use, the nature of the position, and any rehabilitation efforts (including, but not limited to, evidence that use will not occur again, passage of time, participation in or completion of treatment or counseling, and a commitment to refrain from using in the future).
  • Agencies should exercise care before making a determination of unsuitability for criminal conduct based on marijuana possession, including a review of the above factors. Again, agencies must consider whether employment of an individual with a criminal history related to the possession of marijuana would adversely impact “the integrity . . . or efficiency of the service.” Depending on the situation, a conviction for marijuana possession might not be incompatible with employment in the position sought.

Setting these scenarios aside, the memorandum concluded with a reminder that federal employees remain subject to E.O. 12564, Drug-Free Federal Workplace, which requires federal employees to refrain from the use of illegal drugs and recognizes that persons who currently use illegal drugs are not suitable for federal employment. Moreover, regardless of the passage of state and local marijuana laws, “[h]eads of agencies are expected to continue advising their workforce that [these state and local efforts] . . . do not alter Federal law or Executive Branch policies regarding a drug-free workplace.” Importantly, federal agencies cannot ignore an employee who disregards federal law as it relates to marijuana while working for the federal government. That said, the E.O. provides that agencies are not required to discipline current employees if they seek counseling or rehabilitation and stop using illegal drugs. Indeed, it is federal policy to offer such treatment and programs to government employees.

While the memorandum is limited to employment with federal agencies, it reflects a shift in how the federal government views consideration of a drug that remains illegal as a matter of federal law.

New Jersey recently enacted a law permitting personal, nonmedical use of marijuana for individuals age 21 and over. Separate laws decriminalize marijuana and hashish possession and set out the penalties when individuals under age 21 use or possess marijuana or hashish. Although not immediately enforceable, New Jersey employers should immediately assess the implications of the laws on their current policies and drug testing practices.

On February 22, 2021, New Jersey Governor Phil Murphy signed A21, the “New Jersey Cannabis Regulatory, Enforcement Assistance, and Marketplace Modernization Act” (NJCREAMMA), which is enabling legislation for the amendment to the New Jersey Constitution making lawful the recreational use of marijuana in the state.  The law directly impacts employers in many ways.

1. Employers may still prohibit marijuana and impairment in the workplace.

The law explains that employers can still maintain drug- and alcohol-free workplaces. Employers are not required to accommodate the use, possession, sale, or transfer of marijuana in the workplace and may prohibit employees from being impaired during work hours.

2. New Prohibitions on Employment Discrimination Based on Marijuana Use Outside of Work.

The law prohibits employers from:

  • refusing to hire or employ an individual who uses marijuana, unless failing to do so would cause the employer to violate a federal contract or lose federal funding; and
  • taking any adverse employment action (e.g., refusing to hire or employ an individual, barring or discharging an individual from employment, requiring an individual to retire from employment, or discriminating against an individual in compensation or in any terms, conditions, or privileges of employment) against someone because they use marijuana or based solely on a positive test result for marijuana metabolites.

3. Limitations on Drug Testing

Under the new law, employers may still conduct numerous forms of drug testing for marijuana, including:

  • Post-offer pre-employment
  • Reasonable suspicion of use at work
  • Reasonable suspicion of impairment
  • Post-accident
  • Random

However, the law limits employers’ ability to rely on these tests in making employment decisions.  The law requires that a drug test include both a “physical evaluation” and “scientifically reliable objective testing methods and procedures, such as testing of blood, urine, or saliva.”  The “physical evaluation” must be conducted by an individual certified to provide an opinion about an employee’s state of impairment, or lack of impairment, related to the use of marijuana. The Cannabis Regulatory Commission is tasked with adopting standards for a “Workplace Impairment Recognition Expert” (WIRE), who must be trained to detect and identify an employee’s use or impairment from marijuana or other intoxicating substances and to assist in the investigation of workplace accidents.

Consequently, the new law creates a requirement similar to reasonable suspicion of impairment to support a positive drug test result for that test to be used in making employment decisions. It is unclear whether this physical evaluation requirement can be accomplished through drug testing services.  Post-accident tests often are performed on employees receiving emergency medical care or treatment, when such an evaluation may be inappropriate.

Further, unless an employer is subject to a federal drug testing requirement, such as DOT-regulated employers, pre-employment marijuana tests in New Jersey are essentially disallowed from serving as the sole basis for revocation of a job offer.  Employers arguably could continue doing the tests, but probably can revoke an offer if an employee admits that they will continue using marijuana such that they are impaired at work.

Employers who continue to drug test should also consider that if an employee or applicant tests positive, the Jake Honig Compassionate Use Medical Cannabis Act (discussed here) imposes additional requirements.  For example, the employer must provide applicants or employees who test positive for marijuana written notice of the individual’s right to explain and their right to provide a “legitimate medical explanation” for the positive test result. The employee has three working days to provide such information, which can include evidence that a health care practitioner has authorized the use of medical marijuana, proof that the applicant or employee is a registered patient, or both. Or, within that same three-day timeframe, the applicant or employee can request a confirmatory retest of the original sample at their own expense.

4. Effective Date Still Unclear

Although these requirements are effective immediately, they do not become operative and, thus, enforceable, until the Cannabis Regulatory Commission adopts rules and regulations relating to the new law. The Cannabis Regulatory Commission must issue the new rules and regulations within 180 days of enactment of the NJCREAMMA or 45 days after appointment of five members to the Commission, whichever is later.

5. No Private Cause of Action

The law does not include a private right of action.  But, we can expect litigation in New Jersey courts, as we have seen courts in other jurisdictions allow aggrieved individuals to sue under medical marijuana laws even without an express private right of action in the statute.

6. Decriminalization

Employers are prohibited from inquiring about or basing any employment decision on the fact that an applicant or employee has been arrested for, charged with, or convicted of certain offenses involving marijuana or hashish. Employers that violate this particular law face civil penalties imposed by the Commissioner of the New Jersey Division of Labor and Workforce Development consisting of $1,000 for the first violation, $5,000 for the second violation, and $10,000 for each violation after that. The law is clear that it does not provide an aggrieved individual with a private right of action in the employment context.

7. Safety Implications for Employers

The New Jersey recreational marijuana law presents hurdles for employers and their efforts to maintain a drug-free workplace.  It appears to undermine employers’ ability to discipline and discharge employees impaired by high levels marijuana, so long as that impairment is not outwardly detectable.  For individuals in safety-sensitive positions, the National Safety Council recommends a zero-tolerance policy for marijuana.  This recommendation is based on the decline in judgment and motor skills, and increase in accidents, incidents, employee injuries, and employee fatalities.  Following workplace fatalities, a large percentage of post-mortem toxicology shows evidence of marijuana impairment.  New Jersey’s new law risks undermining good faith drug and alcohol programs and employers’ abilities to protect the health and safety of employees.

8. Next Steps for Employers

It remains to be seen whether the Cannabis Regulatory Commission will issue regulations that clarify some of the law’s unanswered questions, most importantly how the law impacts employers with employees in safety-sensitive positions. Until those regulations are adopted, New Jersey employers should consider working with relevant stakeholders and experienced employment counsel to determine whether to modify their drug testing practices, including the possibility of eliminating marijuana testing either pre-employment or for certain types of positions, provide training to managers tasked with making reasonable suspicion determinations, and determine the best person to serve as the employer’s WIRE. We will provide an update as soon as the new regulations are adopted.

Welcome back to The Week in Weed, your Friday look at what’s happening in the world of legalized marijuana.

Virginia legalized adult-use cannabis.  Could marijuana sales come to D.C.?  A legalization bill moved forward in New Mexico.  Pennsylvania and Connecticut are also considering permitting an adult-use market.  And finally, a Canadian marijuana company has created a new way to get high.

virginia

On the last day of the session, Virginia lawmakers settled their differences and passed legislation legalizing adult-use cannabis.  Governor Northam (D) supports the bill, but may send amendments back to the legislature. Sales won’t begin until 2024.

district of columbia

D.C. legalized marijuana in 2014, but sales are illegal.  We’ve discussed this situation here and here.  Now that Democrats control Congress, the outlook for setting up a market has improved considerably.  The D.C. Council has two bills to consider.

new mexico

New Mexico’s Senate needs to sort out four bills on cannabis, and they’re running out of time to do it.  The House passed a bill earlier in the session.  Legislators have only 20 days remaining to get a bill through the Senate and reconcile it with the House version, so they need to get busy.

pennsylvania

Two Senators in the Keystone State introduced a bipartisan adult-use cannabis bill.  Senators Dan Laughlin (R-Erie) and Sharif Street (D-Philadelphia) sponsored the bill, which contains social equity provisions and authorizes farmers to cultivate the crop.

connecticut

Connecticut’s Governor Ned Lamont (D) released a plan to legalize cannabis in his state, but social equity advocates have problems with it.  A recent all-day hearing on the measure leads many to believe the legislation will be amended to address their concerns.

and finally

Have you ever wished you could ride in a plane made of hemp that flies on cannabis oil?  Well, Hempearth has you covered.

Stay safe and be well everyone – we’ll see you next week!

Welcome back to The Week in Weed, your Friday look at what’s happening in the world of legalized marijuana.

New Jersey (finally) passes a legalization bill.  South Dakota and Montana continue to struggle with implementing the will of the voters.  North Dakota, on the other hand, moves forward with legislation to allow adult-use cannabis.  On the federal level, members of Congress ask President Biden to grant clemency to those with marijuana convictions.  Merrick Garland gets a Senate hearing and discusses enforcement of marijuana laws.  And finally, we have some movie news, with a New Jersey angle.

new jersey

The Garden State finally got off the legislation roller coaster this week and passed a bill allowing adult use of cannabis.  If you want a look at the ups and downs, just check out The Week in Weed for the past three months.

south dakota & montana

We’ve discussed South Dakota almost as much as New Jersey this year.  As we reported last week, the legislature is debating a bill that would delay implementation of medical marijuana for a year.  Now, those in favor of medicinal cannabis have a proposal that would shorten the delay in setting up a program and provide those with “debilitating medical conditions” a way to avoid criminal penalties in the interim.

As for Montana, Rep. Bill Mercer (R-Billings) wants to delay the sale of adult-use marijuana until 2023.  He says the ballot initiative’s requirement that systems be in place by October of this year is unworkable.  He’s also concerned that a court challenge will invalidate the entire measure.  As always, further bulletins as events warrant.

north dakota

In the marijuana realm, it’s important not to mix up your Dakotas.  We’ve chronicled South Dakota’s many issues in many blog posts, but haven’t devoted as much time to their neighbor to the north.  Here’s where things stand now: In response to a push to put adult-use legalization on the ballot in 2022, legislators took up a legalization proposal themselves this week.  The House passed the bill, which now goes to the Senate.

clemency

Let’s turn our attention to the federal government.  37 House members signed a letter to President Biden, asking him to pardon those convicted of federal cannabis offenses.  Rep. Barbara Lee (D-CA) and Rep. Earl Blumenauer (D-OR) led the group in asking for clemency for those in prison for activity now legalized in so many states.

merrick garland

President Biden’s nominee for Attorney General, Merrick Garland, answered questions on enforcement of federal cannabis laws.  He spoke against spending limited resources on prosecutions in states with legal marijuana.  He also said that stopping the “overemphasis on marijuana possession” would help to address systemic racism.

and finally

In the time it’s taken for New Jersey lawmakers to pass a cannabis bill, Kevin Smith has written a new “Clerks” movie.  In what will come as no surprise, Jay and Silent Bob now run a weed store.

Stay safe and be well everyone – we’ll see you next week!

On January 25, 2021, the National Labor Relations Board’s Division of Advice released an Advice Memo on the issue of whether certain cannabis workers were exempt from the National Labor Relations Act as agricultural workers. The Advice Memo noted at the outset that the “Board has not ruled on whether employees of a marijuana enterprise are agricultural laborers or statutory employees.” The difference in classification is important – the Board has jurisdiction over statutory employees but not agricultural laborers, which means the latter cannot seek redress from the NLRB for alleged labor law violations.

In determining whether a worker is an agricultural laborer, the Board, pursuant to an annual appropriations rider, looks to the broader definition of “agriculture” in the Fair Labor Standards Act, which includes the production of “horticultural commodities” as agricultural activity and, thus, exempt from the NLRB. In concluding that the workers at issue in the Advice Memo were exempt from the NLRA, the Division of Advice highlighted that the workers “perform a substantial amount of agricultural functions” within the meaning of the FLSA standard, including harvesting, pruning, and sorting of plants. Both of the employees used their hands rather than machines to perform their tasks, and were not involved in “transform[ing] the natural product from its raw state.”

The Division of Advice distinguished the facts before it from situations in two previous Advice Memos issued regarding marijuana facility employees. In one, the “processing assistants used machines that transformed the raw plant into retail products, whereas the two employees here handle the plants by hand and do not substantially transform them.” In the other, the functions were similar but the context was different, with the Division of Advice determining that the FLSA’s definition of “agriculture” was inapplicable because, unlike in the instant situation, the employees were not engaged in organizing activities as required by the appropriations rider.

The Advice Memo was limited to its facts and should not be read to mean that exempt cannabis or other agricultural workers are entitled to no protections. Indeed, some states have enacted statutes that protect the right of agricultural workers to organize. Importantly, Advice Memos are not binding on future Board determinations. And, given the Division of Advice wrote the memo before President Biden fired the NLRB General Counsel and the Deputy General Counsel, it remains to be seen whether a Biden Board will issue a decision that actually decides whether other cannabis workers who participate in the transformation of the product are agricultural workers or statutory employees.

Welcome back to The Week in Weed, your Friday look at what’s happening in the world of legalized marijuana.

We have updates on the situations in New Jersey and Virginia.   Many things happened in South Dakota this week.  New Mexico starts the legalization process.  A wide array of governors express support for cannabis.  And finally, marijuana has some effect on brainstorming.

new jersey

As promised last week, we have an update on the situation in the Garden State.  There’s still no cannabis law.  Talks broke down over underage possession penalties, which have been a stumbling block all along.  The chair of the Senate Judiciary Committee, Nicholas Scutari (D-Union), announced on Wednesday that he doesn’t have the votes for any measures other than the two that currently await the governor’s signature or veto.  So will Governor Murphy (D) sign bills that contain language he doesn’t like?  Will he veto them and fail to keep a campaign promise?  We’ll just have to wait and see…

virginia

As we reported last week, lawmakers in Virginia’s General Assembly and Senate passed legalization bills.  Legislators must reach a compromise by February 26 (next Friday) in order to present a bill to the governor to sign.  And that’s where the heavy lifting comes in.

south dakota

So much is happening in South Dakota, very little of it good for legalization.  Regular readers will doubtless recall that South Dakota passed both recreational and medical marijuana ballot initiatives last November.  Governor Noem (R) has already taken action against adult-use with a lawsuit.  And the state’s Attorney General has indicated that he will not argue the law is constitutional if there’s an appeal to the Supreme Court.  Now, Noem is moving against medical cannabis.  A House committee passed a bill designed to delay implementation of the program for a year.

new mexico

Things look a bit brighter for legalization advocates in the Land of Enchantment.  The House Health and Human Services Committee passed legislation with a social equity component this week.  Next stop: the House Tax Committee.  The deadline to send a bill to the Governor, who supports legalization, is March 20.

governors

Governor Noem’s stand against cannabis legalization may make her an outlier among her fellow governors.  Chief executives from states as diverse as Kansas, Kentucky, Wisconsin and New York are all arguing in favor of reform, if not outright legalization.

and finally

In what we hesitate to describe as “news,” it turns out that marijuana use leads to business ideas that are more creative, but less feasible, than ideas generated without cannabis.

Stay safe and be well everyone – we’ll see you next week!

The unlikely tale of the sub-reddit Wall Street Bets (WSB) taking on the world of institutional investing seems fit for a Adam McKay film adaptation, but the saga isn’t over yet. Enter the marijuana stocks – the epilogue at the end of the film that signals WSB’s influence may not be over (cue an ethereal cover song playing in the background). Much to the dismay of some more seasoned WSB members, the sub’s notoriety has caused an uptick in membership, bringing with it a slew of new members trying to find the next big get rich quick stock (including, perhaps, some whose intentions are more nefarious, i.e. the big bad hedge funds themselves). The inevitable outcome was center stage last week as the markets saw huge gains (and then deep dips) on weed stocks. After some posts and comments signaling that gains could be made investing in companies like Aphria Inc. (APHA), Tilray, Inc. (TLRY), and Sundial Growers (SNDL), the stock prices took off and pot stocks across the board benefited from the attention. While more than a few of the posts and comments advised that these were long-term investments, the quick gains were exactly what the masses wanted, and, unlike their GME predecessors, they had no David v. Goliath righteous indignation to hold the stocks long-term. This new “pump and dump” culture has left many WSB members to wonder if this is the beginning of the end for the once under the radar sub that was more fond of posts showing how much money was lost rather than how much was gained. For now, the new interest in weed stocks has brought to light some potential markers that the stock may still be a good long-term investment. There is discussion that the new Democratic-led congress could make legalization a reality, and with more states legalizing or decriminalizing weed, the bets may pay off. In the meantime, I’ll keep holding my 14 shares of APHA @ $24.33 and hope my small contribution to the phenomenon that is MEME stocks pays off. To the moon!

Welcome back to The Week in Weed, your Friday look at what’s happening in the world of legalized marijuana.

Virginia makes progress on legalizing adult-use cannabis.  A South Dakota court overturns the legalization ballot measure.  New Jersey still has no marijuana legislation.  Will Congress treat CBD as a supplement?  Will Congress allow cannabis research?  And finally, Don Lemon doesn’t endorse your CBD product.

virginia

Legalization moved forward again this week, as both chambers of the state legislature voted in favor of allowing adult-use cannabis.  The bills differ significantly, so there’s more work to do before legislation can be sent to Governor Northam.

south dakota

If anyone hasn’t been following this saga, here’s a quick recap: The Mount Rushmore state’s ballot measure allowing marijuana passed with almost 70% approval in November.  Governor Kristi Noem (R), long an opponent of any form of legalization, supported a lawsuit seeking to overturn the measure.  This week, Circuit Judge Christina Klinger sided with the Governor.  She determined that the measure covered more than one topic, and therefore violates the state’s Constitution.  Next stop – the state’s Supreme Court.

new jersey

So Virginia moves forward; South Dakota moves back.  And New Jersey?  It’s still not moving at all.  Penalties for underage possession continue to dominate discussion.  The deadline for the governor to act is now set for February 18.  Rest assured, we’ll have more next week!

cbd

Democrats and Republicans don’t agree on much these days, but the need for CBD regulations brings out the bipartisan spirit.  A group of 19 Representatives introduced a bill that would legalize hemp (and its derivatives) under the Food, Drug and Cosmetic Act.  The act also requires the FDA  to set up a regulatory framework for these products.

research

Aisle-crossing also reigns in the area of marijuana research.  Three senators re-introduced the Cannabidiol and Marihuana Research Expansion Act, which passed unanimously last year.  The bill would simplify the application process for scientists wishing to study cannabis, as well as encourage the FDA to develop medicines derived from marijuana.  2021 could be a busy year for the Food and Drug Administration!

and finally

In what is now becoming a regular feature of this blog, we have yet another phony celebrity CBD endorsement.  This time, it’s CNN anchor Don Lemon.

Stay safe and be well everyone – we’ll see you next week!