When it comes to cannabis licenses, every state has its own statutory and regulatory quirks that create traps for the unwary.  In Michigan, one is the Marijuana Regulatory Agency’s (“MRA’s”) strained interpretation of the limit on the number of grower licenses a person may hold under the Michigan Regulation and Taxation of Marihuana Act (“MRTMA”).

Section 9 of MRTMA prohibits the MRA from issuing a license if doing so would mean that “a person who holds an ownership interest in the marihuana [business] . . . will hold an ownership interest in more than 5 marihuana growers.” MRTMA defines the term “marihuana grower” as “a person [or entity] licensed to cultivate marihuana.”  But in applying Section 9’s limitation, MRA interprets the term “grower” to mean a singular grow license.
Continue Reading Michigan Regulator’s Odd Limit on Grow Licenses

Late last month, Michigan’s Marijuana Regulatory Agency (“MRA”) released its new Medical Marijuana Facilities License and Marijuana Establishment License (adult-use) application forms and instructions.

MRA’s new forms were issued in connection with the new topic-based administrative rules for both facility types released in the same week, which reflected lessons learned by the State and industry after operating under temporary and emergency rules since 2017. Under the new rules, all applicants are subject to the almost the same standards and requirements for both medical and adult-use licensing. Most of the application changes will serve to further streamline the application process, eliminating extraneous information that bogged down applications in the past. Applications remain a two-step process of submitting for prequalification (“Step 1”) and facility licensure (“Step 2”).

Continue Reading Michigan’s Marijuana Regulatory Agency Releases New Application Forms for Medical and Recreational Facilities: What to Know