THE AMERICAN LAW INSTITUTEContinuing Legal Education
Cannabis and Commercial Real Estate: Navigating a Budding Industry
February 22, 2017 Telephone Seminar/Audio Webcast
Excerpts from Harris Bricken’s Canna Law Blog (www.cannalawblog.com)
Submitted by
Vincent SliwoskiHarris Bricken
Portland, Oregon
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Excerpts from Harris Bricken’s
Canna Law Blog (www.cannalawblog.com)
Bank Loans on Cannabis Property: Tread Carefully
By Vince Sliwoski on January 3, 2017
My law firm represents a large number of cannabis operators in Oregon, Washington and
California. Some of these operators own the land they trade on; others simply lease. Whenever
we are lucky enough to meet the client before the onset of cannabis activity, our first question is
often whether the target property is mortgaged, or if it is owned free and clear. If the property is
mortgaged, we ask “by whom?” If the answer is “a bank,” we tend to say, “let’s talk about that
for a minute.”
Your standard institutional mortgage contains language allowing the mortgagee/lender to call the
loan if the property is being used to conduct “illegal activity.” Lenders won’t budge on that
provision: it relates back to federal lending guidelines, and attempting to pare back that language
is impossible. If a borrower acquires a bank loan with the secret intention of operating or leasing
to a cannabis business, that borrower is running a risk of foreclosure, to say nothing of
allegations of fraud.
When a bank discovers that cannabis is being grown, processed, held or sold on its mortgaged
property, it has the option, under contract, to call the loan. This means the bank can declare the
entire mortgage balance due and owing on the spot. In practice, if a loan is in good standing it
won’t always get called; but if a bank learns that cannabis is being traded on the property, a
real possibility exists that the mortgage will get called. And refinancing with the lender will be
all but impossible.
Although banks typically do not troll their commercial loans looking for pot merchants, many
loans require borrowers to inform lenders about tenants and new leases on the property. When a
bank decides to call a loan due to cannabis activity, the bank may give the mortgagor a limited
window of time to cure the defect (stop the cannabis activities), or to find alternative lending.
Given the realities of business investment and operations, the strictures of leases and the high
cost of private lending, this can cause tremendous headaches.
There is no work-around for the “illegal activities” issue in institutional lending, but that hasn’t
stopped some folks from trying. Among other creative ideas, we recently saw one owner give a
second, unrecorded mortgage to a cannabis operator as “insurance” against the first loan getting
called. Not only would this approach fail to prevent the first mortgage from getting called, it
would typically allow the first mortgagee to declare the balance of its loan payable immediately,
as “due on sale.” Such an action could wipe out the junior, unrecorded mortgage interest in any
subsequent foreclosure.
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Finding a cannabis property is not always easy, but it’s important to understand how the property
is financed (or otherwise encumbered) before you sign a lease or begin operations. If you intend
to purchase a cannabis property and cannot pay cash, seller financing is a popular option we have
written about elsewhere. Otherwise, it’s hard money or trying to fool the bank. Neither of those
is a good business plan.
Marijuana Property Transactions: The Curious Role
of Title Companies
By Vince Sliwoski on December 13, 2016
We have run quite a few real estate deals in Oregon, Washington and California cannabis. No
two deals are the same, and as we previously have written, buying and selling land for pot
ventures is a trip. An obvious reason for this is the lack of banking services, but another big
reason is lack of certain title company services, like escrow. If you are hoping to enlist a title
company as escrow in your cannabis property sale, we say to you, “good luck.”
Typically, title companies handle all of the paperwork to close a standard real estate transaction.
It is probably easiest to think of these services in three distinct parts: (1) receiving, holding and
sending money and key documents (escrow); (2) providing a spot for the parties to iron out
details toward the end of a deal (including deeds and other formal documents (closing)); and (3)
issuing title insurance. By providing this suite of services, a title company can serve as a “one
stop shop” for closing most real estate deals.
Pot deals, of course, are different.
In our experience, title companies generally will close a cannabis deal, and they will even
provide title insurance in most cases. However, they generally will not facilitate the exchange of
funds. This seems strange initially, but it relates back to banks, and the fact that many banks
refuse to service businesses even indirectly involved with cannabis. That includes title
companies. Thus, title companies often have formal policies against serving as escrow in
cannabis deals, especially where the land already is being used for a pot-related purpose.
Fortunately, it is possible to close a real estate sale without a title company performing escrow
services. In those transactions, the buyer and seller will usually engage an attorney to serve as
escrow, and the attorney will take instructions on how and when to distribute funds. Though
attorneys tend to be more expensive than title companies for this purpose, they are safer than
fringe operators offering escrow services, and an attorney worth her salt should be able to run the
exchange efficiently.
With respect to title insurance, title companies generally will issue these policies on the rationale
that the insurance product relates to land ownership, rather than to the activities taking place
thereon. Of course, most title insurance policies in marijuana-related transactions will expressly
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exclude coverage for governmental actions, including civil and criminal forfeiture under the
federal Controlled Substance Act. Before purchasing title insurance, we strongly recommend that
the buyer disclose their intended use of the land. Otherwise, the title company has an argument
not to pay on claims.
In the coming months, we expect to handle more and more real estate deals for pot businesses
and also sellers. The California land grab will heat up in that state’s pot friendly counties, and
our Oregon office has seen another spike in land deals from November’s local election results.
Our Washington cannabis lawyers are also seeing an increase in land sales, mostly attributable
to growers who got in early, but now wish to sell.
Ultimately, the laws around the purchase and sale of commercial real estate tied to cannabis are
complicated, and vary state by state. An experienced cannabis attorney with commercial real
estate chops will be able to facilitate the purchase or sale of real estate for pot commerce, from
title examination through recording the deeds. The attorney will know how to work with the
parties’ chosen title company to push the deal through, and how to navigate the unusual aspects
of these transactions, like escrow.
Oregon Marijuana Laws: Buying and Selling Land is
a Trip
By Vince Sliwoski on October 22, 2015
There are 48,699 registered marijuana growers under Oregon’s Medical Marijuana Program.
Some of these growers grow a couple of plants for a patient or two, and others produce at the
program limits of 24 mature plants. There are grow sites with just one or two growers, and others
with dozens of growers and 100 or more registered patients.
Under the new recreational program, grow sites will be even larger. Outdoor limits are currently
capped at 40,000 square feet in total canopy, per license. That is close to an acre. As we have
written here before, marijuana is now an official “crop” in Oregon, protected by the state’s right
to farm laws. For these reasons, Oregon marijuana cultivators are buying up land in grow-
friendly counties at a pretty good clip.
As with marijuana leases, marijuana land sale transactions are not typical and we are already
starting to see documentation drafted by lawyers without cannabis experience that fails to
account for this. Bank loans are out of the question, as chartered lenders are unwilling to finance
the purchase of an asset that could be seized at any moment under the federal Controlled
Substances Act (CSA), 21 USC § 856. That statute, sometimes called the “crack house statute,”
provides that using or allowing real property to be used for unlawfully manufacturing, storing,
distributing, or using a controlled substance, is a federal crime. Marijuana is a Schedule I
controlled substance under the CSA.
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Without access to bank loans, cultivators who are not independently wealthy must deal with hard
money lenders, if they can drum up the collateral; or, more typically, convince the property seller
to carry a loan. In either case, the buyer gives the lender or seller a promissory note. That note
almost always carries a higher interest rate than a standard bank note. Recently, depending on the
size of the transaction and the term involved, we are seeing interest rates in the 10 to 12 percent
range, but they can be even higher.
And then there is the very interesting issue of security. No sensible seller will lend money based
only on a borrower’s promise to pay. Like any seller, a seller who finances the sale of real
property to an Oregon marijuana cultivator will insist on a first deed of trust. That way, if the
buyer misses a payment, the seller can take the land back by foreclosing on the deed. If things
are done correctly, the seller will have priority over any other creditor.
A savvy seller may also insist on a security interest in the marijuana “crop” itself. You may be
wondering how a non-licensed entity, like a creditor to a marijuana business, could legally seize
and sell an acre’s worth of marijuana. The Oregon Liquor Control Commission (OLCC) has
considered this, and its draft rules currently provide that “the Commission may issue a temporary
authority to operate a licensed business to . . . a person holding a security interest in the business
for a reasonable period of time to allow orderly disposition of the business.”
The rules go on to provide for issuance of a “certificate of authority” to the temporary licensee
(in this case, the seller or creditor). This means that if a seller has perfected her interest in the
marijuana crop by filing the appropriate financing statement, and a buyer stops making
payments, the secured seller can actually seize and sell the marijuana. This would be done in
addition to taking back the property, if recovery of the property did not cover the outstanding
debt. Of course, the seller would have to be willing to seize and sell the marijuana in violation of
the federal CSA, but that’s another story.
These are just a few of the more interesting angles on the sale of real property for marijuana
cultivation. There is much more on this topic than we have written here, from standard
considerations like the form of deed exchanged, to industry particular contract terms, like those
related to the failure of a buyer to obtain or maintain OLCC licensure. Both buyers and sellers in
these transactions must take special care to ensure that their interests are protected.
Marijuana Lease Checklist: Ten Things to Note
By Vince Sliwoski on November 29, 2016
In states with legal cannabis programs, most licensed cannabis businesses fall into three broad
categories: producers, processors and retailers. Some states offer more exotic classes of licensure
for activities like testing, research and even wholesaling marijuana, but a substantial majority of
pot entrepreneurs are trading in the basics. Whether you are on the landlord or tenant side of the
transaction, though, marijuana leases are anything but basic.
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Unlike with standard commercial leases, pot landlords and tenants must account for the status of
federal prohibition, the strictures of state-level programs, and the peculiarities of local zoning
laws. These considerations are separate and distinct from baseline commercial lease
considerations, which can themselves be complex and run into the dozens of pages. Without
getting too far into the weeds, here are ten items to consider specifically in your marijuana lease.
1. Profit Sharing. We have seen many, many pot leases drafted by parties where a landlord
agrees to take a cut of business profits over and above base rent. This type of transaction is
typically frowned upon by regulators, who may view anything beyond ordinary, arms-length
payments as de facto license ownership, subject to disclosure and vetting. Both parties should
check local rules before entering into any sort of profit sharing arrangement, even if it is a
small percentage of rent overall.
2. CSA Indemnity. Savvy landlords will often push for an indemnity requirement from
tenants on general liability issues. The experienced marijuana landlord will also require
indemnity on the specific issue of civil forfeiture under the federal Controlled Substances Act.
This stipulation requires a marijuana tenant to defend a landlord and absolve the landlord of
wrongdoing if the federal government takes enforcement action against the landlord for
renting to the pot business.
3. Licensing Cooperation. Most marijuana licenses are tied to locations. A marijuana tenant
will want to ensure that its landlord is obligated to assist if new administrative rules impose
unforeseen requirements on them during the lease term. If a tenant is forced to move, the
chances it will be able to drag its license from one place to the next are low. And if the
property contains any peripheral attributes relevant to cannabis licensure, like a state-approved
water right, the tenant will also want to ensure that the landlord is obligated to maintain that
feature.
4. Access. States have strict rules about who may enter onto a marijuana licensee’s premises,
and when. The right of the landlord to enter onto a premises should be clearly outlined, and it
should dovetail with the provisions contained in any relevant statute or administrative rule
regarding entry by anyone other than the licensee.
5. Occupancy and Commencement Dates. A typical cannabis lease will provide that a
tenant will abide by all state and local laws, which includes a requirement not to begin any
marijuana related activity on the premises prior to licensure. Sometimes, this creates a chicken
and egg problem for a tenant, who needs a lease to get licensed, and also needs a license to
operate under its lease. The parties should plot out a realistic timeline for licensure, and
discuss whether rent will be abated or reduced prior to licensure.
6. Outs. Both parties will want a series of cannabis-specific “outs,” or escape clauses, drafted
into the lease. These outs may accrue in situations ranging from federal law enforcement
action, to local cannabis license denial. The landlord may also want outs for a tenant’s
noncompliance with state or local cannabis laws.
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7. Environmental Concerns. This is a big one in production and processor leases. Landlords
and tenants will want to address fertilizers, herbicides and pesticides used and stored at the
premises, along with the disposal of cannabis products and byproducts. States have both
general environmental laws and cannabis specific laws that govern these issues and a properly
drafted cannabis lease will take them into account.
8. Lease Term. Commercial leases often extend five or ten years at minimum, and a tenant
may have one or more options to renew its lease beyond the initial term. In cannabis, parties
tend to agree to shorter lease terms with fewer renewal options, because of the uncertainty
inherent in cannabis laws and markets. Each party should weigh its desire for contract stability
against the risk of market disruption, before committing to a term.
9. Dispute Resolution. The default rule in commercial leasing is that disputes are settled in
court. Landlords are accustomed to expedited court proceedings designed to deal with FED
(“forcible entry and wrongful detainer”) and courts are well versed in the summary eviction
process. With cannabis, however, there are compelling arguments to be made for arbitration
when it comes to contracts, including leases.
10. Federal Illegality. As with any cannabis contract, a well drafted cannabis lease should
stipulate that federal illegality is not a valid defense to any claim arising from the lease, and
that the parties waive the right to present any such defense related to the status of cannabis
under federal law. Otherwise, a court could throw out the lease entirely, causing some serious
headaches.
The above list is not exhaustive, and every marijuana lease will be different, depending on the
parties, activity, state and location. Above all, it is important to note that marijuana leases, like
other marijuana contracts, are unusual agreements that require expert attention.
Cannabis Real Estate 101
By Daniel Shortt on February 12, 2017
Since licenses to grow, process, or sell cannabis are usually tied to a specific real property
location, it is not surprising that cannabis businesses often need real estate help. The following
are some basic points we try to convey to our cannabis clients about real estate in a cannabis
context.
1. Location. Location. Location. Choosing the right location is important for any business,
but this is especially true for a cannabis business. Finding a suitable and state-and-local-
law-compliant location for a marijuana business can be difficult. Most states, cities, and
counties limit where marijuana businesses can physically operate. States and cities often
require cannabis businesses be at least 1,000 feet away from schools and parks because
federal criminal law sentencing guidelines tack on extra sentencing time for cultivating,
processing, or distributing cannabis within 1,000 feet of a school or park. Local zoning
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laws can also significantly restrict location options and these can vary greatly from local
government to local government. Regulations that limit the number of cannabis stores or
grow sites allowed in a given county are also common, as are moratoriums and outright
bans.
2. Find a Landlord With Whom You Can Work. Most commercial landlords will not rent
out their space to a cannabis business. Because cannabis remains illegal under federal law,
landlords can face arrest for violating the federal Controlled Substances Act or, more
realistically, losing their property via a civil asset forfeiture. Look what happened to the
landlord in the Harborside case. The landlord-tenant relationship can be strained if the
landlord is not informed of the nature of the tenant’s business and the risk associated.
3. Make Sure Your Lease Works for the Cannabis Industry. “Boilerplate” lease
agreements do not work for cannabis businesses. For example, the typical Commercial
Broker’s Association lease states that any illegal activity on the property will constitute a
lease default. We usually write our commercial marijuana leases to forbid only those
actions that violate state law and federal law with the exception of the federal Controlled
Substances Act. Commercial leases also typically contain a provision governing the
activities permitted on the leased property. If the tenant is a marijuana retailer, the
permitted use provision should explicitly permit the “retail sale of marijuana.” Leaving the
permitted use provision vague only increases the chances of the cannabis business tenant
being found in breach of the lease for having conducted an activity not permitted on the
property.
4. Know Your Property. Our cannabis real estate lawyers are far too frequently brought in
on long simmering real estate deals only to have to tell both sides that there will need to be
major changes in the deal points for the deal to work at all. Before getting too far down the
negotiating path, it is wise to at least secure a real property report. These reports will show
ownership history, encumbrances (such as mortgages) on the land, and any easements or
other restrictions on property use. For example, if there is an unpaid mortgage on the land,
the holder of that mortgage can foreclose on the property, even though the current owner
was not the one who entered into the transaction. Even a tenant who is not purchasing the
property should be informed of the property’s history and the risks associated with that
property.
Marijuana Commercial Leases: This Industry Is
Different, You Know
By Hilary Bricken on February 22, 2015
As so many of you know, few landlords are willing to rent to marijuana businesses. They are
afraid of the very real possibility of losing their property in a federal civil asset forfeiture action.
The federal government has been known to seize property being used for cultivating,
manufacturing, or selling marijuana. In the last seven years, the Feds have seized more than
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a billion dollars in personal and real property allegedly tied to federally illegal drugs, including
marijuana in states where marijuana is legal.
If you are a landlord or a marijuana business tenant, you should know what you can do to help
avoid federal intervention, including asset forfeiture.
Under federal law, forfeitures can be civil or criminal:
The following shall be subject to forfeiture to the United States and no property right shall exist
in them … [a]ll real property, including any right, title, and interest (including any leasehold
interest) in the whole of any lot or tract of land and any appurtenances or improvements, which is
used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of,
a violation of this subchapter punishable by more than one year’s imprisonment.
Since manufacturing, cultivating, and distributing cannabis are federal crimes, real property that
facilitates those crimes is subject to asset forfeiture.
Civil forfeitures of real property are brought as judicial forfeiture actions that require a court
to oversee the seizure. In these civil cases, the government has the burden of proving that the
property is subject to forfeiture. The government does not need to prove the landowner is guilty
of a crime. It merely needs to show a “substantial connection” between the property and the
crime.
Federal law does provide what is known an “innocent owner defense” to the forfeiture of real
property. This defense provides that property will not be forfeited if the owner can show that it
did not know about the conduct giving rise to forfeiture or that when it learned of the conduct
giving rise to the forfeiture it did all that it reasonably could to terminate such use of the
property.
Here’s the big problem though in states where marijuana is legal for either medical or
recreational use. In those states, the innocent owner defense is usually not available because the
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state typically mandates that the lease explicitly allow for the growing, manufacturing, or selling
of marijuana. And, in most marijuana-legal states, having a lease that allows for marijuana
activity is also required to receive a state license to operate.
There are though many things that both landlords and tenants can to prevent asset forfeiture or
federal intervention altogether, including those discussed below.
Real property leases that involve a cannabis business should include “escape clauses” that
specifically list out federal intervention, changes in federal enforcement policy, forfeiture threats,
and federal enforcement actions (such as DEA raids or DOJ criminal charges or administrative
actions) as defaults that constitute lease violations. This sort of provision will give the landlord
fodder for appeasing the Feds.
Commercial leases typically contain a permitted use provision governing the activities permitted
on the leased property. The permitted use provision for a cannabis business should specifically
identify the activities allowed on the property. If the tenant is a marijuana retailer, the permitted
use provision should explicitly permit “retail sale of marijuana.” Leaving the permitted use
vague will likely mean that marijuana tenants run the risk of breaching the lease by conducting
an activity not permitted on the property, which itself could invite federal scrutiny.
Marijuana commercial leaseholds should provide for a strict code of conduct for property use.
The typical Commercial Broker’s Association lease states that any illegal activity on the property
will constitute a default in the lease, so just pulling one of these provisions “off the shelf” is
not appropriate. We typically write our commercial marijuana leases to forbid only those actions
that violate state law — not federal law.
Your marijuana lease should also include provisions relating to hours of operation, how the
tenant treats of its neighbors, odors, loitering, use of hazardous substances, the number of people
permitted on the property, and compliance with state and local regulatory rules and with the Cole
Memo.
Federal marijuana prohibition coupled with the fluidity of state marijuana regulatory schemes
make standard commercial lease agreements wrong for leases involving marijuana businesses.
You instead need a lease that deals with the realities of running a marijuana business.
Real Property Forfeiture For Marijuana Tenants:
Your Marijuana Leasehold Is Key
By Hilary Bricken on September 15, 2014
Why do commercial landlords still hesitate to rent to marijuana businesses? In addition to the
remote possibility of a landlord getting arrested and prosecuted by the U.S. Department of
Justice (DOJ) for violating the Federal Controlled Substances Act, landlords face the very real
threat of losing their property via a civil asset forfeiture. The federal government can and does
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sometimes seize property used for cultivating, manufacturing, or selling marijuana. In recent
years, the Federal Government has netted at least one billion dollars from seizing personal and
real property used for to manufacture or distribute Federally illegal drugs, including marijuana in
states where marijuana is legal. Whether you are a commercial landlord or a marijuana business
tenant, you need to know what you can do to help fend off Federal intervention, including asset
forfeiture.
First though, a brief overview of how asset forfeiture works. Forfeiture can be either civil or
criminal. Forfeiture of real property used to violate the Federal Controlled Substances Act is
governed by 21 U.S.C §§ 881 and 18 U.S.C §§ 983 and 985. Pursuant to 18 U.S.C §881(a)(7):
“[t]he following shall be subject to forfeiture to the United States and no property right shall
exist in them … [a]ll real property, including any right, title, and interest (including any
leasehold interest) in the whole of any lot or tract of land and any appurtenances or
improvements, which is used, or intended to be used, in any manner or part, to commit, or to
facilitate the commission of, a violation of this subchapter punishable by more than one year’s
imprisonment.”
Since cultivating, manufacturing, and distributing marijuana are Federal crimes, real property
used to facilitate the commission of those crimes is subject to asset forfeiture.
In civil asset forfeiture cases involving real property, the government actually sues the property
itself and the property owner is treated as a third party claimant. Civil forfeitures of real property
are initiated as judicial forfeitures, meaning a court with competent jurisdiction must oversee the
seizure. The burden of proof is on the government to show by a preponderance of the evidence
that the property is subject to forfeiture. Civil asset forfeiture of real property does not require
that the government prove that the landowner is guilty of any crime; it is enough if the
government shows that there is a “substantial connection” between the property and the crime
alleged. By contrast, criminal forfeiture is against a person only after a conviction (beyond a
reasonable doubt) for an underlying criminal offense.
Nonetheless, 18 U.S.C §983(d) creates what is known as the “innocent owner defense” to asset
forfeiture of real property. “An innocent owner’s interest in property shall not be forfeited under
any civil forfeiture statute. The claimant shall have the burden of proving that the claimant is an
innocent owner by a preponderance of the evidence.” The term “innocent owner” means an
owner who (i) did not know of the conduct giving rise to forfeiture; or (ii) upon learning of the
conduct giving rise to the forfeiture, did all that reasonably could be expected under the
circumstances to terminate such use of the property (emphasis added).”
In many states where marijuana has been legalized (either for recreational or medical use) the
innocent owner defense is usually not available because the marijuana-legal state mandates that
the lease explicitly allow for the cultivation, manufacture, or retail sale of marijuana. And, in
most if not all, marijuana-friendly States, having a lease that allows for marijuana activity is a
requirement to receive an operational license from the state. So then what can landlords and
tenants do to prevent asset forfeiture or Federal intervention altogether?
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First, as we noted in our post, Marijuana Commercial Leaseholds: Any Resemblance to Regular
Leaseholds is Purely Coincidental real property leases that involve a marijuana business should
include “escape clauses” listing Federal intervention, changes of Federal enforcement policy,
forfeiture threats, and/or Federal enforcement (be it a raid by the DEA or filing of criminal
charges by the DOJ) as defaults that constitute lease violations or cancellations.
Leases typically contain a permitted use provision to govern the activities that can take place on
the leased property. The permitted use provision for a marijuana business should accurately
identify the activities allowed on the property. For example, if a tenant is a marijuana retailer, the
permitted use provision should reflect this by explicitly permitting “the retail sale of
marijuana.” If the permitted use is unclear, tenants run the risk of breaching the lease by
conducting an activity not permitted on the property, which itself could invite Federal scrutiny.
It is also prudent for a marijuana commercial leasehold to set out a strict code of conduct relating
to the use of the property. The typical Commercial Broker’s Association lease provides that any
illegal activity on the property constitutes a default so just pulling one of these “off the shelf” is
not the way to go. One reliable way to handle the illegality issue is to write a lease that explicitly
forbids only those actions that violate state (not Federal) law.
Moreover, it is important to include in a marijuana lease provisions relating to hours of
operation, the tenant’s treatment of its surrounding commercial neighbors, loitering, odors, the
use of hazardous substances at the property, the number of people permitted on the property, and
constant compliance with any and all state and local regulatory rules and with the recent Cole
Memo from the DOJ.
The bottom line: Federal marijuana prohibition and the fluidity of state law marijuana
regulatory schemes mean that standard commercial lease agreements are not sufficient to sustain
and protect the landlord/tenant relationship involving a cannabis business. You instead need
lease that accounts for the realities of running a marijuana business. Or prepare to face the
consequences.
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STATE MCLE CONTACTS
Revised: 02/15/2017
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Louisiana Ms. Kitty Hymel Louisiana Supreme Court Committee on MCLE 2800 Veterans Memorial Blvd Suite 355 Metairie, LA 70002-6130 800/518-1518 Toll Free 504/828-1414 504/828-1416 FAX [email protected] www.lascmcle.org
Maine Ms. Susan Adams Maine Board of Overseers of the Bar PO Box 527 Augusta, ME 04332-0527 207/623-1121 207/623-4175 FAX [email protected] www.mecle.com
Minnesota Ms. Liz Vanderbeek Minnesota State Board of CLE 180 E 5th St Ste 950 St. Paul, MN 55101 651/297-7100 651/296-5866 FAX [email protected] www.mbcle.state.mn.us Mississippi Ms. Tracy Graves Mississippi Commission on CLE PO Box 369 Jackson, MS 39205-0369 601/576-4622 601/576-4733 [email protected] www.courts.ms.gov/cle_/ Missouri Mr. Christopher C. Janku The Missouri Bar PO Box 119 Jefferson City, MO 65102-2355 573/638-2233 573/635-2811 FAX [email protected] [email protected] www.mobar.org
Montana Ms. Kathy Powers Montana Commission of CLE 7 W 6th Ave Ste 2B PO Box 577 Helena, MT 59624 406/442-7660 406/442-7763 FAX [email protected] www.mtcle.org
Nebraska Ms. Carole McMahon-Boies 521 S 14th St Ste 200 Lincoln, NE 68508 402/471-3072 402/471-3071 FAX [email protected] www.mcle.ne.gov
Nevada Ms. Toni Sarocka Nevada CLE Board 457 Court St 2nd FL Reno, NV 89501 775/329-4443 775/329-4291 FAX [email protected] www.nvcleboard.org
STATE MCLE CONTACTS
Revised: 02/15/2017
New Hampshire Joanne M. Hinnendael New Hampshire Bar Association 2 Pillsbury St Ste 300 Concord, NH 03301-3502 603/224-6942 603/224-2910 FAX [email protected] www.nhbar.org New Jersey Supreme Court of New Jersey Board of Attorney Certification CLE 25 Market St Trenton, NJ 08625-0979 609/984-3077 [email protected] www.judiciary.state.nj.us/cle New Mexico Ms. Anita J. Otero New Mexico MCLE PO Box 93070 Albuquerque, NM 87199 505/821-1980 505/821-0220 FAX [email protected] www.nmmcle.org New York Ms. Elise Anne Geltzer New York State Unified Court System 25 Beaver St Rm 888 New York, NY 10004 877/697-4253 212/428-2974 FAX [email protected] www.courts.state.ny.us North Carolina Ms. Debra P. Holland North Carolina State Bar PO Box 26148 Raleigh, NC 27611 919/733-0123 919/821-9168 FAX [email protected] www.nccle.org North Dakota Ms. Debbie Bowen North Dakota CLE Commission 504 N Washington St. Bismarck, ND 58501 701/255-1404 701/224-1621 FAX [email protected] www.sband.org Ohio The Supreme Court of Ohio Commission on CLE 65 S Front St FL5 Columbus, OH 43215-3431 614/387-9327 614/387-9323 FAX www.supremecourt.ohio.gov/attorneyservices/cle.default.asp
Oklahoma Ms. Beverly S. Petry Oklahoma Bar Association PO Box 53036 Oklahoma City, OK 73152 405/416-7009 405/416-7089 FAX [email protected] www.okbar.org Oregon Ms. Denise Cline Oregon State Bar 16037 SW Upper Boones Ferry Rd Tigard, OR 97281-1935 503/620-0222 503/598-6915 FAX [email protected] www.osbar.org Pennsylvania Mr. Nate Graham Pennsylvania CLE Board 601 Commonwealth Ave Ste 3400 Harrisburg, PA 17106-2495 717/231-3230 717/231-3251 FAX 800/497-2253 [email protected] www.pacle.org Puerto Rico Ms. Yanis Blanco-Santiago Supreme Court of Puerto Rico CLE Programs PO Box 190917 San Juan PR 00919-0917 787/641-6604 787/641-6602 FAX Rhode Island Ms. Holly Hitchcock, M. Ed. Rhode Island Supreme Court MCLE Commission John E. Fogarty Judicial Annex 24 Weybosset St., 3rd Floor Providence, RI 02903 401/222-4942 401/222-4302 FAX www.courts.ri.gov South Carolina Ms. Mary A. Germack The Supreme Court of South Carolina Commission on CLE & Specialization PO Box 2138 Columbia, SC 29202 803/799-5578 803/799-4118 FAX [email protected] www.commcle.org
Tennessee Ms. Judy Bond-McKissack Tennessee Commission on CLE & Specialization 1321 Murfreesboro Pk Ste 810 Nashville, TN 37217 615/741-3096 615/532-2477 FAX [email protected] www.cletn.com Texas Ms. Nancy R. Smith State Bar of Texas PO Box 13007 Austin, TX 78711-3007 515/427-1806 800/204-2222 x1806 515/427-4123 FAX [email protected] www.texasbar.com/mcle Utah Ms. Sydnie W. Kuhre Utah Supreme Court Board of CLE Utah Law & Justice Center 645 South 200 East, Ste. 312 Salt Lake City, UT 84111-3834 801/531-9077 801/531-0660 FAX [email protected] www.utahbar.org Vermont Ms. Martha I. Hicks-Robinson, Director Vermont Judiciary Board of Bar Examiners, Character & Fitness MCLE 111 State Street, Suite 9B Montpelier VT 05609-0701 (802)828-3281 Fax: (802)828-6550 [email protected] www.vermontjudiciary.org Virginia Ms. Gale M. Cartwright Virginia State Bar 1111 E. Main St., Ste. 700 Richmond, VA 23219-3565 804/775-0577 804/775-0544 FAX [email protected] www.vsb.org Virgin Islands Ms. Hinda Carbon Virgin Islands Bar Association PO Box 4108 Christiansted, VI 00822 340/778-7497 340/773-5060 FAX [email protected]
Washington Ms. Renata Garcia Washington State Bar Association 1325 4th Ave., Ste 600 Seattle, WA 98101-2539 206/727-5987 206/727-8313 FAX [email protected] www.wsba.org West Virginia Ms. Hope L. Gresham The West Virginia State Bar 2000 Deitrick Blvd Charleston, WV 25311-1231 304/553-7238 304/558-2467 FAX [email protected] www.wvbar.org Wisconsin Ms. Jacquelyn B. Rothstein Board of Bar Examiners Mail: PO Box 2748 Madison, WI 53701-2748 Shipping: 110 E. Main St., Ste. 715, Tenney Building Madison, WI 53703-3328 608/266-9760 608/266-1196 FAX [email protected] [email protected] www.wicourts.gov Wyoming Ms. Marie Ellis Wyoming State Bar 4124 Laramie St PO Box 109 Cheyenne, WY 82003-0109 307/632-9061 307/632-3737 FAX [email protected] www.wyomingbar.org