HomeMy WebLinkAboutAgenda Report - April 6, 2016 C-11TM
CITY OF LODI
COUNCIL COMMUNICATION
AGENDA ITEM
AGENDA TITLE: Receive Report Regarding Communication Pertaining to Assembly Bill 2614
(Bonta) — Medical Cannabis: Out -of -State Convictions
MEETING DATE: April 6, 2016
PREPARED BY: City Clerk
RECOMMENDED ACTION: Receive report regarding communication pertaining to Assembly
Bill 2614 (Bonta) — Medical Cannabis: Out -of -State Convictions.
BACKGROUND INFORMATION: The City received a request for communication from the League of
California Cities regarding AB 2614 (Bonta). There was a need to
send a letter of opposition immediately in light of a pending hearing.
AB 2614 would prohibit the denial of a state license for commercial cannabis activity if the denial is based
solely on an out-of-state felony conviction that did not include a period of incarceration, so long as a local
jurisdiction is aware of the conviction and is nonetheless willing to issue a local permit or other
authorization. Any change to the existing statutory licensing provisions that would restrict the discretion of
the relevant state agency in granting a license — particularly in regard to evaluating an applicant's criminal
history — represents a dangerous, negative precedent in the form of a legislative attempt to encroach
upon and micromanage what has until now been a purely executive function.
The attached letter, signed by the Mayor, was sent out on March 17, 2016. A copy of the initial request,
along with the text of the bill, is also attached. This report is provided for informational purposes only,
pursuant to policy.
FISCAL IMPACT: Not applicable.
FUNDING AVAILABLE: Not applicable.
J'nifer Mi slerraiolo
City Clerk
APPROVED:
ephen Schwab
N:\Administration\CLERK\Council\COUNCOM\LeagueReceiveReportMaster.doc
ity Manager
CITY COUNCIL
MARK CHANDLER, Mayor
DOUG KUEHNE,
Mayor Pro Tempore
BOB JOHNSON
JOANNE MOUNCE
ALAN NAKANISHI
CITY OF LODI
The Honorable Rob Bonta
California State Assembly
State Capitol — Room 6005
Sacramento, CA 95814
FAX: (916) 319-2118
CITY HALL, 221 WEST PINE STREET
P.O. BOX 3006
LODI, CALIFORNIA 95241-1910
(209) 333-6702 / FAX (209) 333-6807
[gdi.gov citvclerk@iodi.Qov
March 17, 2016
RE: AB 2614 (Bonta) Medical Cannabis: Out -of -State Convictions
Notice of OPPOSITION
Dear Assembly Member Bonta:
STEPHEN SCHWABAUER
City Manager
JENNIFER M. FERRAIOLO
City Clerk
JANICE D. MAGDICH
City Attorney
The City of Lodi regrets to inform you of its strong opposition to AB 2614. AB 2614 would
prohibit the denial of a state license for commercial cannabis activity if the denial is based
solely on an out-of-state felony conviction that did not include a period of incarceration,
so long as a local jurisdiction is aware of the conviction and is nonetheless willing to issue
a local permit or other authorization.
The suitability provisions for state licensure included in the Medical Marijuana Regulation
and Safety Act (MMRSA) ensure that individuals seeking a state license for commercial
cannabis activity represent law-abiding citizens whom our communities can trust to
operate compliant medical cannabis business operations. The provisions were negotiated
in good faith among a number of stakeholders over the course of 2015, culminating in
language that protects public safety while acknowledging the legal challenges that
cannabis industry operators have faced in the past. In addition to providing a means for
an individual with a felony conviction to obtain a license, the language also provides
complete discretion to the licensing authority by stating that the licensing authority "may
deny the application for licensure" if the applicant has been convicted of a substantially
related offense.
Any change to the existing statutory licensing provisions that would restrict the discretion
of the relevant state agency in granting a license — particularly in regard to evaluating an
applicant's criminal history — represents a dangerous, negative precedent in the form of a
legislative attempt to encroach upon and micromanage what has until now been a purely
executive function.
There is no pressing need to change existing law in this area by crafting a weaker
standard for state licensing for medical marijuana businesses than is applied to any other
applicant for any other category of state licensure. This approach calls the legitimacy of
the entire regulatory structure for medical marijuana into question, because it invites
unnecessary and entirely avoidable hazards to public safety. Should AB 2614 become
law, it is within the realm of plausibility that drug traffickers of far more dangerous
controlled substances — who happen to have been convicted only once — could become
licensed by the State of California.
AB 2614 (Bonta) Medical Cannabis: Out -of -State Convictions — Notice of OPPOSITION
Page Two
This measure discards the fragile consensus on the issue of disqualifying felonies for
state licensure that was achieved only after several weeks of bitter and contentious
stakeholder meetings last year. At a minimum, it will damage the credibility of the entire
regulatory structure from the viewpoint of cities and law enforcement groups who played
a critical role in achieving last year's consensus. To re -open this issue now invites a
resumption of last year's conflict, as it may well result in calls for even stricter criteria for
licensing than that which exists in the MMRSA today.
Finally, this bill runs the very substantial risk of provoking a negative reaction from
federal law enforcement authorities, by weakening the criteria for state licensure in a way
that makes it more difficult to ferret out potential bad actors. It invites more intense
federal scrutiny, and may well pave the way to future federal enforcement efforts, which
no one wants.
For these reasons the City of Lodi must respectfully, but firmly, oppose AB 2614.
Sincerely,
/U1141 adi.41:64.7
Mark Chandler
Mayor, City of Lodi
MCljmf
cc: Senator Cathleen Galgiani, Fax: (916) 651-4905
Assemblymember Jim Cooper, Fax: (916) 319-2109
Le Ondra Clark Harvey, Chief Consultant, Assembly Business and Professions Committee,
Fax: (916) 319-3306
Stephen Qualls, Regional Public Affairs Manager, squallsCa)cacities.ora
Meg Desmond, League of California Cities, mdesmond a[�,cacities.orff
Jennifer Ferraiolo
From: Stephen R. Qualls <squalls@cacities.org>
Sent: Tuesday, March 15, 2016 6:43 PM
Subject: URGENT: LETTERS NEEDED
Attachments: AB 2614_Talking Points.pdf; Sample Oppose Letter.docx; Action Alert.docx
After months of negotiations last year, the League and the California Police Chiefs Association were able to reach an
agreement that prohibited those with prior drug related convictions from obtaining licenses from the Department of
Consumers Affairs to sell Medical Marijuana. Even if those convictions were from outside the state and no time was
served.
AB 2614 would set a precedent by allowing such people to obtain a license by prohibiting the Department of Consumers
Affairs from denying a license if their prior conviction was the only reason for doing so. Under California law, similar
rules have NEVER been applied to licensing before.
This means that the dispensaries in your city could be operated by convicted drug trafficers or abusers.
Please be sure to send the attached letter to the author, your legislators and those requested in the letter.
As usual, please contact me with any questions.
Thank you,
Stephen Qualls
Central Valley Regional Public Affairs Manager League of California Cities
209-614-0118
Fax 209-883-0653
squalls@cacities.org<mailto: squalls@cacities.org>
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1
AB 2614 (Bonta) Medical Marijuana: Felony Convictions
Talking Points
• This bill disregards the consensus language on disqualifying
felonies for state licensure that the Police Chiefs Association and
the League agreed to in last year's legislation — solely for the
benefit of a tiny handful of wealthy individuals who have grown
rich selling marijuana.
• AB 2614 seeks to take away the discretion of the Department of
Consumer Affairs on the decision of whether applicants with out-
of-state felony convictions can be licensed to operate a marijuana
business in California.
• This bill would prohibit the Department from denying a license to
a person with an out-of-state felony conviction. Such a rule has
never applied to any other category of state licensing.
• There is no compelling public policy or public safety argument
justifying this attempt to weaken the rules on state licensing.
• This measure should be rejected as imposing an unnecessary and
unacceptable danger to public safety.
• AB 2614 places California at greater risk of intense scrutiny by
federal law enforcement officials, making it more likely that we
will see more, not less, federal enforcement action in the future.
ACTION ALERT!!
AB 2614 (Bonta)
Medical cannabis: state licenses: out-of-state convictions.
OPPOSE
Background for AB 2614 (Bonta):
AB 2614 would prevent the Department of Consumer Affairs from denying a state license to a person
with an out-of-state conviction. It provides that such a conviction cannot be the sole basis for denial of
a license, if it did not include a period of incarceration, and if a local jurisdiction is aware of the
conviction and is nonetheless willing to issue a local permit or other authorization.
This bill blatantly disregards consensus language on disqualifying felonies for state licensure that the
League and the Police Chiefs agreed to in last year's legislation, re -opening one of the most
controversial issues in the Medical Marijuana and Safety Act to ensure that a small number of current
business operators can obtain a state license.
Under current law, the Department has discretion to approve or deny a license based on an out-of-state
conviction. This is the standard rule for state licensing entities. AB 2614 seeks to change that, by
infringing on a state licensing entity's discretion for the benefit of a tiny handful of individuals who have
grown rich selling marijuana.
This is unprecedented in California law. Such a rule has never applied to any other category of state
licensing.
This bill is an attempt by the Legislature to encroach upon licensing decisions in a most sensitive area
— criminal background — a function that until now has been purely a function of the executive branch of
government.
There is no compelling public policy or public safety argument justifying this attempt to weaken the
rules on state licensing.
Finally, this bill runs the very substantial risk of provoking a negative reaction from federal law
enforcement authorities, by weakening the criteria for state licensure. AB 2614 invites more intense
federal scrutiny, and may well pave the way to future federal enforcement efforts.
ACTION:
AB 2614, although not yet calendared, is expected to be heard in the Assembly Business and
Professions Committee in the next few weeks.
Please send a letter of CITY OPPOSITION to your Assembly Member. Sample letter is
attached or you may use the League's Action Center to submit a letter online.
ASSEMBLY BUSINESS AND PROFESSIONS
Member
District
Party
Room
Phone
Fax
Baker, Catharine
16
R
4153
916 319 2016
916 319 2116
Bloom, Richard
50
D
2003
916 319 2050
916 319 2150
Brough, William (Vice -Chair)
73
R
2174
916 319 2073
916 319 2173
Campos, Nora 27 I D I 4016 916 319 2027 I 916 319 2127
Chavez, Rocky
76
R
2170
916 319 2076
916 319 2176
Dahle, Brian
1
R
2158
916 319 2001
916 319 2101
Dodd, Bill
4
D
2137
916 319 2004
916 319 2104
EQgman, Susan
13
D
3173
916 319 2013
916 319 2113
Gatto, Mike
43
D
5136
916 319 2043
916 319 2143
Gomez, Jimmy
51
D I 2114 I 916 319 2051 916 319 2151
Holden, Chris
41 D 3152 916 319 2041 916 319 2141
Jones, Brian
71 R 3141 916 319 2071 r 916 319 2171
Mullin, Kevin
22 D I 3160 r 916 319 2022 r-916 319 2122
Salas, Rudy (Chair)
32
D
2188
916 319 2032
916 319 2132
Ting, Philip
19
D
6026
916 319 2019
916 319 2119
Wood, Jim 2 I D I 3120 916 319 2002 916 319 2102
Talking Points:
• This bill disregards the consensus language on disqualifying felonies for state licensure that the
Police Chiefs Association and the League agreed to in last year's legislation — solely for the
benefit of a tiny handful of wealthy individuals who have grown rich selling marijuana.
• AB 2614 seeks to take away the discretion of the Department of Consumer Affairs on the
decision of whether applicants with out-of-state felony convictions can be licensed to operate a
marijuana business in California.
• This bill would prohibit the Department from denying a license to a person with an out-of-state
felony conviction. Such a rule has never applied to any other category of state licensing.
• There is no compelling public policy or public safety argument justifying this attempt to weaken
the rules on state licensing.
• This measure should be rejected as imposing an unnecessary and unacceptable danger to public
safety.
• AB 2614 places California at greater risk of intense scrutiny by federal law enforcement officials,
making it more likely that we will see more, not less, federal enforcement action in the future.
CALIFORNIA LEGISLATURE -2015-16 REGULAR SESSION
ASSEMBLY BILL No. 2614
Introduced by Assembly Member Bonta
February 19, 2016
An act to amend Section 19325 of the Business and Professions Code,
relating to medical cannabis.
LEGISLATIVE COUNSEL'S DIGEST
AB 2614, as introduced, Bonta. Medical cannabis: state licenses:
out-of-state convictions.
The Medical Marijuana Regulation and Safety Act provides for the
licensure of persons engaged in specified activities relating to medical
cannabis and authorizes licensing authorities to only issue state licenses
to qualified applicants. Existing law prohibits a person from engaging
in commercial cannabis activity without possessing both a state license
and a local permit, license, or other authorization.
This bill would prohibit the denial of a state license to an applicant
if the denial is based solely on a conviction outside of the state of
California where the sentencing did not include a period of incarceration,
but only if a local government with knowledge of that prior conviction
issues a permit, license, or other authorization permitting the applicant
to engage in commercial cannabis activity.
Vote: majority. Appropriation: no. Fiscal committee: yes.
State -mandated local program: no.
The people of the State of California do enact as follows:
1 SECTION 1. Section 19325 of the Business and Professions
2 Code is amended to read:
99
AB2614 —2-
1 19325. An applicant shall not be denied a state license if the
2 denial is based solely on any of the following:
3 (a) A conviction or act that is substantially related to the
4 qualifications, functions, or duties of the business or profession
5 for which the application is made for which the applicant or
6 licensee has obtained a certificate of rehabilitation pursuant to
7 Chapter 3.5 (commencing with Section 4852.01) of Title 6 of Part
8 3 of the Penal Code.
9 (b) A conviction that was subsequently dismissed pursuant to
10 Section 1203.4, 1203.4a, or 1203.41 of the Penal Code.
11 (c) A conviction outside of the state of California where the
12 sentencing did not include a period of incarceration, but only if a
13 local government with knowledge of that prior conviction issues
14 a permit, license, or other authorization permitting the applicant
15 to engage in commercial cannabis activity.
0
99
FACSIMILE COVER SHEET
CITY CLERK'S OFFICE
221 WEST PINE STREET - P.O. BOX 3006
LODI, CALIFORNIA 95241-1910
PHONE (209) 333-6702 FAX (209) 333-6807
citycirk@lodi.gov or ufa�risc,ladi.goy
DATE: March 17, 2016
FROM: Pamela M. Farris
Deputy City Clerk
TO: Assemblymember Rob Bonta, 916-319-2118
Senator Cathleen Galgiani, 916-651-4905
Assemblymember Jim Cooper, 916-319-2109
Le Ondra Clark Harvey, Chief Consultant, 916-319-3306
COMMENTS: Attached please find the Notice of Opposition for AB 2614
(Bonta) — Medical Cannabis: Out -of -State Convictions
THIS TRANSMITTAL CONTAINS 3 PAGE(S), INCLUDING THIS COVER SHEET.
forms\aafaxjen.doc
CITY COUNCIL
MARK CHANDLER, Mayor
DOUG KUEHNE,
Mayor Pro Tempore
BOB JOHNSON
JOANNE MOUNCE
ALAN NAKANISHI
CITY OF LODI
CITY HALL, 221 WEST PINE STREET
P.O. BOX 3006
LODI, CALIFORNIA 95241-1910
(209) 333-6702 / FAX (209) 333-6807
www.lodi.gov citvclerk@Iodr.gov
March 17, 2016
The Honorable Rob Bonta
California State Assembly
State Capitol — Room 6005
Sacramento, CA 95814
FAX: (916) 319-2118
RE: AB 2614 (Banta) Medical Cannabis: Out -of -State Convictions
Notice of OPPOSITION
STEPHEN SCHWABAUER
City Manager
JENNIFER M. FERRAIOLO
City Clerk
JANICE D. MAGDICH
City Attorney
Dear Assembly Member Bonta:
The City of Lodi regrets to inform you of its strong opposition to AB 2614. AB 2614 would
prohibit the denial of a state license for commercial cannabis activity if the denial is based
solely on an out-of-state felony conviction that did not include a period of incarceration,
so long as a local jurisdiction is aware of the conviction and is nonetheless willing to issue
a local permit or other authorization.
The suitability provisions for state licensure included in the Medical Marijuana Regulation
and Safety Act (MMRSA) ensure that individuals seeking a state license for commercial
cannabis activity represent law-abiding citizens whom our communities can trust to
operate compliant medical cannabis business operations. The provisions were negotiated
in good faith among a number of stakeholders over the course of 2015, culminating in
language that protects public safety while acknowledging the legal challenges that
cannabis industry operators have faced in the past. In addition to providing a means for
an individual with a felony conviction to obtain a license, the language also provides
complete discretion to the licensing authority by stating that the licensing authority may
deny the application for licensure" if the applicant has been convicted of a substantially
related offense.
Any change to the existing statutory licensing provisions that would restrict the discretion
of the relevant state agency in granting a license — particularly in regard to evaluating an
applicant's criminal history — represents a dangerous, negative precedent in the form of a
legislative attempt to encroach upon and micromanage what has until now been a purely
executive function.
There is no pressing need to change existing law in this area by crafting a weaker
standard for state licensing for medical marijuana businesses than is applied to any other
applicant for any other category of state licensure. This approach calls the legitimacy of
the entire regulatory structure for medical marijuana into question, because it invites
unnecessary and entirely avoidable hazards to public safety. Should AB 2614 become
law, it is within the realm of plausibility that drug traffickers of far more dangerous
controlled substances — who happen to have been convicted only once — could become
licensed by the State of California.
AB 2614 (Bonta) Medical Cannabis: Out -of -State Convictions — Notice of OPPOSITION
Page Two
This measure discards the fragile consensus on the issue of disqualifying felonies for
state licensure that was achieved only after several weeks of bitter and contentious
stakeholder meetings last year. At a minimum, it will damage the credibility of the entire
regulatory structure from the viewpoint of cities and law enforcement groups who played
a critical role in achieving last year's consensus. To re -open this issue now invites a
resumption of last year's conflict, as it may well result in calls for even stricter criteria for
licensing than that which exists in the MMRSA today.
Finally, this bill runs the very substantial risk of provoking a negative reaction from
federal law enforcement authorities, by weakening the criteria for state licensure in a way
that makes it more difficult to ferret out potential bad actors. It invites more intense
federal scrutiny, and may well pave the way to future federal enforcement efforts, which
no one wants.
For these reasons the City of Lodi must respectfully, but firmly, oppose AB 2614.
Sincerely,
„,4
Mark Chandler
Mayor, City of Lodi
MC/jmf
cc: Senator Cathleen Galgiani, Fax: (916) 651-4905
Assemblymember Jim Cooper, Fax: (916) 319-2109
Le Ondra Clark Harvey, Chief Consultant, Assembly Business and Professions Committee,
Fax: (916) 319-3306
Stephen Qualls, Regional Public Affairs Manager, sauallsaallcacities.org
Meg Desmond, League of California Cities, mdesmond@cacities.orq