advisory cannabis

we are 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.

Leveraging the ability to communicate effectively in the language of policymakers is essential for eliminating stigma, developing regulations, obtaining licenses, launching new facilities, and maintaining compliant operations.

In 2025's frothiest markets with a focus on the rollout of adult-use in Connecticut, New Jersey, Maryland, Pennsylvania, Delaware, and Ohio: 

• forecasting state-based demand and supply imbalance
• evaluating the price compression timetable
• deciphering cannabis M&A's volatile valuations
• anticipating, assessing, and managing risk associated with deal breaking delays

levers and catalysts

January 2025: SAFE gets refiled in January as the new Congressional makeup and committees take shape. 

Rescheduling:  Moving cannabis to S3 is inadvertently on hold until the new administrator of the DEA determines teh course of action.



Litigation will surely follow with an attempt at an injunction to hold up implementation of the final rule, 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 late April 2025 with the reasonably bearish pushing that into the Q3'25.

• If the new DEA administrator 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 DE
• 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 (potentially 4/21/25)

Hat tip: Matt Zorn has done an amazing job compiling the most up to date cannabis rescheduling information 

The DEA docket portal is available to the public.

February 2025

>  Boies Schiller lawsuit:  Oral arguments were heard in the US Court of Appeals for the First Circuit in Boston on 12/5/24 and the three-judge panel has yet to rule on the attempt to appeal on up to the Supreme Court late summer to overturn Raich. The Boies Schiller path to victory will be riddled with lots of developments to confuse and excite the space, but the momentum has so far been optimistic as the case accelerates through the process.

This landmark litigation, on behalf of Massachusetts retailer Canna Provisions, marijuana delivery business owner Gyasi Sellers, cultivator Wiseacre Farm and publicly traded multistate operator Verano Holdings, has even been blamed by the DEA as they attempt to drag rescheduling out as long as they can.  Christine Bailey unpacks the case fantastically here.

The judicial system may move "faster" than the administrative and legislative reform channels, but litigation sure is expensive. 

>  Administrative Shift:  New political leadership will greatly impact cannabis reform at the federal level as the administration transitions in over the next three weeks.

All eyes are on potential Attorney General Pam Bondi as the Department of Justice and the DEA hold most of the cards as the rescheduling timeline painstakingly unfolds. S3 could get back on the fast track very quickly with our without any Bondi memo.

Upon rescheduling, the jobs report would begin to include the nearly half a million cannabis industry workers and that will be a very important metric for the new administration.

There is tremendous interest but little clarity as to how the new administration and Congress will handle bills like the CSRA (Cannabinoid Safety and Regulation Act) and the Farm Bill. Senate Majority Leader John Thune hasn't warmed up to cannabis despite representing legal Montana, but it isn't expected that he will block the new administration's support of the industry.

June 2025: The Farm Bill potentially gets across the finish line, closing the intoxicating hemp loophole to coincide with most states passing legislation to do the same. 

>  States:  Pennsylvania is likely going to hammer through imperfect legislation, but they need the tax revenue so there is a strong possibility that adult-use sales begin before EOY25. 

Nebraska should have medical cannabis regulations soon thanks to the success of Initiatives 437 & 438 at the ballot and the subsequent creation of the Nebraska Medical Cannabis Commission.

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 by March.

Minnesota's lottery has been sadly delayed because of litigation and that rollout seems like it's going to go more like an embattled New York than a zippy Missouri.

The most up to date cannabis conversations can be found on LinkedIn and Twitter, where I am very active.