United States v. Scarmazzo

Rule of Law:

In a federal prosecution under the Controlled Substances Act, defenses based on medical necessity, good faith belief in the legality of conduct under state law, advice of counsel, and entrapment by estoppel are generally not permissible because the statute establishes a general intent crime and reflects a congressional determination that marijuana has no accepted medical use.

Facts:

• Defendants were engaged in conduct involving marijuana for purported medical purposes.
• This conduct was in potential compliance with state law, such as California's Proposition 215, which permits medical marijuana.
• The federal Controlled Substances Act (CSA) classifies marijuana as a Schedule I controlled substance, making its manufacture, distribution, or possession a federal crime.
• Defendants were federally prosecuted for their marijuana-related activities under the CSA.
• Defendants sought to argue at trial that their actions were justified by medical necessity, that they acted in good faith believing their conduct was lawful, and that they were entrapped by estoppel or relied on the advice of counsel.

Procedural Posture:

• The United States government initiated a criminal prosecution against the defendants in the U.S. District Court for violating the Controlled Substances Act.
• Prior to trial, the government filed several motions in limine.
• These motions sought a pretrial court order to exclude the defendants from presenting certain evidence and arguments to the jury.
• The specific defenses the government sought to exclude included medical necessity, good faith, entrapment by estoppel, advice of counsel, and any arguments aimed at jury nullification.