advisory cannabis

an East Coast cannabis advisory specializing in macro & micro strategy, expansion, industry research & intelligence, municipal outreach, and market mechanics for regulators, stakeholders, and operators in adult-use and medical marijuana markets.

Continually leveraging the ability to:

• communicate effectively in the language of policymakers:

• essential for eliminating stigma
• developing regulations
• obtaining licenses
• launching new facilities
• maintaining compliant operations

• anticipate and act on key inflection points in emerging cannabis markets

• grasp of policy-driven triggers (legislation, licensing, litigation, regulation, etc.)
• reinforce geographic focus
• extract alpha from complex or delayed markets

• deepest on the near-term's frothiest markets with a focus on the rollout of AU in Connecticut, New Jersey, Maryland, Virginia, Pennsylvania, and Delaware: 
  
  
• modeling state-based demand and supply imbalance
• evaluating the price compression timetable
• deciphering cannabis M&A's volatile valuations
• assessing, underwriting, and managing risks that break deals and lose money

levers and catalysts

> SAFER has been dangled as an addition to other bills but no one is taking the bait.  Other banking measures mixed in with Chokepoint, debanking, crypto, and the Bitcoin reserve are just other Peanuts holding footballs for Charlie.

> Rescheduling:  Moving cannabis to S3 is inadvertently and indefinitely on hold via interlocutory appeal until Terry Cole is officially installed as the new administrator of the DEA.  Attorney General Pam Bondi could take steps to give us a Final Rule at any time and this is the expected path.  Follow @admindotlaw on Twitter for the inside line.

Litigation will surely follow with an attempt at an injunction to hold up implementation of the FR, though a judge may simply reject that on the grounds that the request is without merit.  The most bullish scenarios have a final rule coming before the end of June, with the reasonably bearish pushing that deep into Q3'25.

• If incoming DEA administrator Terry Cole determines that a new hearing is to be scheduled, that will fall to current ALJ John Mulrooney or his replacement.
• ALJ will compile all the evidence and make a rescheduling recommendation to the DEA
• DEA will consider, then issue a final rule by publishing it in the Federal Register
• The Final Rule will become effective 30 days after publication.

Hat tip: Matt Zorn (now a Deputy Director at HHS!) has done an amazing job compiling the most up to date cannabis rescheduling information.

Notably, the DEA Notice of Proposed Rulemaking webpage has just recently been cleaned up nicely.

>  Boies Schiller lawsuit:  Current probability of a SCOTUS writ of certiorari ranges from 0.0% to 10% but the case's merits are less important right now than the temperature of the court and cannabis reform's current spotlight.  Four Justices are required and bets are on Clarence Thomas, Neil Gorsuch, Sonia Sotomayor, and Ketanji Brown Jackson. 

Thomas ruled on Raich, Gorsuch understands States' Rights, and both Sotomayor and Brown Jackson are from communities victimized by the War on Drugs.  Definitely a longshot, but saying that there is zero chance is simply irresponsible.

>  States:  Pennsylvania is likely going to hammer through imperfect legislation this session, but they have already missed their budget deadline.  The Commonwealth desperately needs the tax revenue so likeliest scenarios still have adult-use sales starting 1/1/26.

Delaware  adult-use sales will begin 8/1/25 at all 13 formerly medical dispensaries.  MSOs like MariMed and The Cannabist are counting on lots of runway before adult-use retails won by lottery get open.  Their largest moat is in Sussex County, even if SB 75 is signed by Governor Matt Meyer, where at least 2.5 million will visit before beach season ends.

Virginia  has Abigail Spanberger on deck, but more importantly Governor Ralph Northam's Cannabis Control Board (part of the VA Cannabis Control Authority) has been convening every sixty days and met last on 6/18/25 to approve METRC as their seed-to-sale vendor.  First adult-use sales by 5/1/26.

Nebraska  has a Medical Cannabis Commission thanks to Initiatives 437 & 438 passing at the ballot and withstanding legal challenges.  Emergency regulations were approved 6/26/25 and Governor Jim Pillen signed 6/29/25.  Applications can now be accepted and issuance must begin by 10/1/25 though NE is currently facing a $70,000 funding gap to build a licensing portal and host application data online.

Kentucky's first 36 medical cannabis retail licenses were awarded via a lottery that took place on 11/25/24 with the second retail round adding 12 more on 12/16/24.  The 16 cultivators (10 Tier I, 4 Tier II, 2 Tier III) were awarded by lottery on 10/28/24.  First sales are expected before the end of the year and Alternative Care in Louisville (2401-B Bardstown Road) is under construction and aims to open in October or November 2025.

Minnesota's delayed licensing has finally begun and that rollout seems less like it's going to go more like an embattled New York yet still unlike a zippy Missouri. On 6/18/25, the Minnesota Office of Cannabis Management (OCM) granted its first adult-use license to Herb Quest, LLC (a microbusiness cultivation license in Pine County).  The June lottery drew 249 winners and there will be a second chance lottery on 7/22/25.  Jacob Schlicter's Smoking Tree in Albert Lea was named the first to receive a micro retail license and is now the first to have passed inspection.  Stay tuned.

The timeliest cannabis conversations can be found on LinkedIn and Twitter, where I am very active.