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New York Cannabis: Early Unforced Errors in Enforcement

A lot has been made recently on New York’s new legislation that empowers the Office of Cannabis Management (OCM) to take enforcement actions against illicit retail dispensaries (check out our posts here and here). This article (paywall) by the always excellent Brad Racino of NY Cannabis Insider provides a play-by-play of the OCM’s first ever enforcement hearing.

Here is the background: Roll Up Nation was one of the 31 allegedly illicit dispensaries that was issued a notice of violation the week of June 5, when the OCM had its first series of raids. Mr. Racino does a great job of setting the scene, describing the participants in the hearing and their respective rolls. We strongly urge anyone interested to read the article, if you can.

But what really caught our eye is the description of “sloppy paperwork” errors committed by OCM. The article references the OCM’s Notice of Violation naming the wrong address for the business and in another instance the OCM’s inspection report naming the wrong business.

On one hand, these sorts of minor discrepancies are not a big deal. On the other hand, administrative dismissals of violations on procedural technicalities is not uncommon, and the OCM (nay, New

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