Medical Marijuana Use in New York and its Implications under Federal Law 

The following is an analysis of the legal and regulatory landscape regarding medical marijuana in New York and the implications of the legalization of medical marijuana under New York State law while federal law continues to criminalize it.  This report summarizes the relevant federal and state law.  It is not intended, and should not be interpreted, as legal advice in any degree.  Rather, this report is intended to provide general legal information in the form of a statement of laws and regulations, which is not, and is not intended to be, applicable to any particular situation.   

In January 2016, New York’s Compassionate Care Act went into effect allowing patients to obtain medical marijuana for certain qualifying conditions.

As a practicing physician, I began research into how this alternative treatment could help some of my patients but soon realized there was another pressing and unresolved question:  Could physicians in New York legally prescribe marijuana without fear of penalty or federal prosecution for violating the Controlled Substance Act (CSA)?

The first medical marijuana laws were passed in 1996 and were met with a strong response from the federal government.  Although legal in their home state, physicians providing patients “with oral or written” recommendations for marijuana were threatened by the federal government with revocation of their controlled substance license, exclusion from Medicare programs and criminal prosecution for alleged violation of the CSA—which created an apparent ambiguity between the state and federal marijuana laws.^[1]  

In the more than 20 years since these events, nearly 90% of states now allow for some use of medical marijuana,^[2] but ambiguity remains between state and federal law.  In New York, for example, medical marijuana use was legalized through its Compassionate Care Act.  In contrast, however, medical marijuana use remains illegal under federal law. 

The purpose of this report is to elucidate some of this lack of clarity for physicians and hospitals in New York that hope to provide care under the NY Compassionate Care Act.  The report also has implications for a wider audience of policymakers, hospitals, health insurers, lawmakers, law enforcement, and other state agencies.

References:

[1] See generally Conant v. McCaffrey, 172 F.R.D. 681 (N.D. Cal. 2000).

[2] Lisa Sacco et al., Cong. Research Serv., R44782, The Marijuana Policy Gap and The Path Forward (2017), available at https://crsreports.congress.gov/product/pdf/R/R44782.

In 2014, New York passed into law the Compassionate Care Act (the “Act”), which legalized the use of medical marijuana in certain circumstances.[1]  Pursuant to the Act, the “possession, acquisition, use, delivery, transfer, transportation, or administration of medical marihuana by a certified patient or designated caregiver possessing a valid registry identification card, for certified medical use” is lawful.[2]  To qualify as a “certified patient,” an individual must have a “serious condition,” defined as “cancer, positive status for human immunodeficiency virus [HIV] or acquired immune deficiency syndrome [AIDS], amyotrophic lateral sclerosis [ALS], Parkinson’s disease, multiple sclerosis [MS], damage to the nervous tissue of the spinal cord with objective neurological indication of intractable spasticity, epilepsy, inflammatory bowel disease [IBD], neuropathies, post-traumatic stress disorder [PTSD], pain that degrades health and functional capability where the use of medical marihuana is an alternative to opioid use, substance use disorder,”[3] Huntington’s Disease,[4] or anything else approved by the State.[5]  Additionally, by rule adopted on March 22, 2017, the Department of Health added “severe debilitating pain” to the list of conditions medical marijuana is approved to treat.[6]

The patient also must have one of the following complications as a result of the serious condition: cachexia or wasting syndrome, severe or chronic pain, severe nausea, seizures, or severe or persistent muscle spasms, opioid use disorder[7] or PTSD.[8]

Upon qualifying as a certified patient, the individual must obtain a valid registration card from the New York State Department of Health (“DOH”), which requires that he/she first obtain a certification from his/her physician.[9]  The physician must certify that the patient: (1) suffers from one of the enumerated “serious conditions;” (2) is in the certifying physician’s continuing care for that condition; and (3) is likely to receive therapeutic or palliative benefits from marijuana.[10]  The physician must consider what form of medical marijuana the patient should use and state any recommendations or limitations in the certification.[11]  After the certification is approved, the DOH will send the patient a registration card, which is valid for one year.[12]  Patients must have their registration cards with them at all times while carrying marijuana.[13]

A certified patient may name up to two individuals as designated caregivers.[14]   Designated caregivers may obtain medical marijuana on behalf of the certified patient, provided the quantities they obtain do not exceed those permitted by statute.[15] Designated caregivers must be 21 years of age or older, unless an exception applies.[16]  If a certified patient is under the age of eighteen, the designated caregiver must be: (i) his or her parent or legal guardian; (ii) someone designated by the patient’s parent or legal guardian; or (iii) an “appropriate person” approved by the DOH.[17]

The Act does not provide unfettered access to and use of medical marijuana.  Medical marijuana issued under the Act may not be “smoked, consumed, vaporized, or grown in a public place.”[18]  Smokable and edible forms of medical marijuana are prohibited, even when consumed in a private setting.[19]  The form and dosage that the patient will use will be determined by the practitioner issuing the certification.[20]  Further, a patient may not carry more than a 30-day supply of medical marijuana.[21] 

Additionally, because the Act does not require healthcare insurers to cover medical marijuana,[22] the patient may be solely responsible for the cost of purchasing medical marijuana.  Moreover, the Act does not apply to out-of-state patients, although a practitioner may prescribe medical marijuana for a patient who temporarily resides in New York.[23] 

New York law affords certain protections for those participating in activities allowed by the Act.  For instance, pursuant to New York law, patients, caregivers, physicians, and staffers of lawful state medical marijuana organizations are not subject to arrest or prosecution, or civil penalty, for engaging in conduct that is permissible under the Act.[24]  In addition, being a medical marijuana patient is considered a disability under New York State anti-discrimination laws.[25] Classifying medical marijuana certification as a disability protects patients from discrimination and harassment[26] and allows for possible prosecution of crimes against medical marijuana patients as hate crimes.[27]  Furthermore, a person’s status as a certified patient shall not be considered in a proceeding related to the domestic relations or social services laws, or the family court act.[28] 

In July 2018, the DOH published a report detailing its assessment of the potential impact of regulated marijuana.  In its findings, which were overwhelmingly positive, the DOH focused on marijuana’s health benefits and risks, effects on criminal justice and public safety, the economic impact of a regulated regime, the necessary public education programs, the impact of legalization in New York on other states, and the best means of implementing a regulated marijuana program.[29] 

While the report is not associated with specific regulations regarding the legalization of medical marijuana in New York, after its release, Governor Andrew M. Cuomo acknowledged that the “situation on marijuana is changing.”[30]

References:

[1] N.Y. Pub. Health Law § 3360 et seq. (McKinney 2018).

[2] Id. § 3362. 

[3] Id. at § 3360.

[4] 10 N.Y.C.R.R. § 1004.2(a)(8)(x).

[5] Id. at § 3360.

[6] 10 N.Y.C.R.R. § 1004.2(a)(8)(xi): “[A]ny severe debilitating pain that the practitioner determines degrades health and functional capability; where the patient has contraindications, has experienced intolerable side effects, or has experienced failure of one or more previously tried therapeutic options; and where there is documented medical evidence of such pain having lasted three months or more beyond onset, or the practitioner reasonably anticipates such pain to last three months or more beyond onset.”

[7] N.Y.C.R.R. § 1004.2 (lists opiate use disorder as an associated complication, but only when the patient is in an article 32 treatment program).

[8] N.Y. Pub. Health Law § 3360.

[9] N.Y. Pub. Health Law § 3361. 

[10] Id.

[11] Id.

[12] Id. § 3363. 

[13] Id. § 3362. 

[14] Id. § 3360. 

[15] Id. § 3362.

[16] Id. § 3363. 

[17] Id. § 3363. 

[18] Id.

[19] 10 N.Y.C.C.R. 1004.11. 

[20] N.Y. Pub. Health Law § 3361 (McKinney 2018).

[21] Id. § 3362.

[22] Id. § 3368.

[23] 10 N.Y.C.R.R. § 1004.2.

[24] Id. § 3369.

[25] Id.

[26] See N.Y. Civ. Rights Law § 40-c.

[27] See N.Y.  Penal Law § 485.05. 

[28] N.Y. Pub. Health Law § 3369 (McKinney 2018).

[29] Assessment of the Potential Impact of Regulated Marijuana in New York State, (July 2018), available at https://www.health.ny.gov/regulations/regulated_marijuana/docs/marijuana_legalization_impact_assessment.pdf.

[30] J. David Goodman, Cuomo Moves Closer to Marijuana Legalization in New York, The New York Times (July 13, 2018). 

In general, states are free to regulate marijuana use within their own borders, and state authorities are bound by those legislative decisions; however, such decisions do not bind federal authorities.  That is because, under the United States Constitution, federal law is the “supreme law of the land” – i.e., it preempts state law.[1]  Accordingly, the federal government may criminalize marijuana, even where a state has deemed it legal—which is precisely what the federal government did in enacting the Controlled Substances Act (the “CSA”) in 1970.  Under the CSA, which governs marijuana and other drug use at the federal level, each controlled substance is assigned to one of five categories, known as schedules,[2] based on the drug’s medicinal value, potential for abuse and addiction, and effects on the body.[3]  Pursuant to the CSA, marijuana is a Schedule I substance due to its “high potential for abuse, lack of any accepted medical use, and absence of any accepted safety for use in medically supervised treatment.”[4]  Based on this classification, it is a criminal offense for anyone to manufacture, distribute, or possess marijuana in any quantity.[5]  As a result, while medical marijuana possession and use are legal in New York, under federal law, the use, possession, sale, or cultivation of any amount or type of marijuana—including medical marijuana—remains illegal.

Federal penalties for possession of marijuana vary based on certain factors, including the amount of marijuana the individual possessed and whether the individual was cultivating or selling it.[6]  A first offense for simple possession of marijuana is punishable by up to a year of incarceration and a $1,000 fine; the penalty for a second offense carries a mandatory minimum of 15 days (and up to two years) of incarceration and a $2,500 fine.  Further offenses are punishable by a mandatory minimum of 90 days (and up to three years) of incarceration and a $5,000 fine.[7]

By comparison, the statutory penalties for the sale or cultivation of marijuana are harsher.  A conviction for selling less than 50 kilograms of marijuana is punishable by up to five years in prison and a $250,000 fine and, for selling more than 1,000 kilograms, a person faces imprisonment of 10 years to life and a $1,000,000 fine.[8]  Penalties for cultivating marijuana are similarly based on the amount of marijuana, with those convicted for growing fewer than 50 plants or kilograms facing up to five years’ imprisonment and a $250,000 fine, and those convicted of growing 1,000 or more plants or kilograms facing ten years to life in prison and a $1,000,000 fine.[9]

There is some federal precedent in respect of physicians who wish to prescribe medical marijuana for their patients.  In 2002, the Ninth Circuit Court of Appeals[10] ruled that the federal government cannot punish, or threaten to punish, a physician simply for informing a patient that his or her use of marijuana for medical treatment purposes is proper.[11]  However, the Court was careful to draw a distinction between this practice and “aiding and abetting” a client to obtain marijuana, which is illegal under the CSA.  Where, “in making the recommendation, the physician intends for the patient to use it as the means for obtaining marijuana, as a prescription is used as a means for a patient to obtain a controlled substance, … a physician would be guilty of aiding and abetting the violation of federal law.”[12]

References:

[1] U.S. Const. art. VI, cl. 2. 

[2] Schedule 1 drugs (the most serious in nature) are deemed to have no medicinal value and high potential for abuse, while Schedule 2 through Schedule 5 substances are deemed to have some medicinal value but varying levels of potential for abuse (from high to low).

[3] 21 U.S.C.A. § 812(a)-(b) (McKinney 2018). 

[4] Gonzales v. Raich, 545 U.S. 1, at 2 (2005). See also 21 U.S.C. §§ 812(b)(1), 812(c) (McKinney 2018). 

[5] 21 U.S.C.A. §§ 841(a)(1), 844(a) (McKinney 2018) (emphasis added). 

[6] See 21 U.S.C.A. §§ 841(a)(1), 844(a) (McKinney 2018). 

[7] Id.

[8] Id. at § 841.

[9] Id. 

[10] The Ninth Circuit comprises the following courts: District of Alaska, District of Arizona, Central District of California, Eastern District of California, Northern District of California, Southern District of California, District of Hawaii, District of Idaho, District of Montana, District of Nevada, District of Oregon, Eastern District of Washington and Western District of Washington.  The Ninth Circuit does not include New York’s federal judicial district courts and Ninth Circuit court decisions are not binding precedent for New York’s federal courts or the Second Circuit Court of Appeals (where New York sits).  

[11] Conant v. Walters, 309 F.3d 629 (9th Cir. 2002).

[12] Id.

In 2005, the Supreme Court in Gonzales v. Raich affirmed the constitutionality of the CSA’s enforcement against users of medical marijuana in states where medical marijuana had been legalized.[1]  In Raich, legal users and growers of marijuana under California’s Compassionate Care Act, which authorized the use of medical marijuana in limited instances, sought a declaration from the Court that the CSA was an unconstitutional exercise of Congress’ Commerce Clause powers.[2] 

The Court held that, although the conduct at issue in Raich was wholly within the borders of California and legal under California law, Congress nevertheless had the power pursuant to the Commerce Clause to regulate these purely local activities because they were part of an “economic class of activities that have substantial effect on interstate commerce.”[3]  Under Raich, therefore, the federal government has the authority to enforce the CSA against users and distributors of medical marijuana, even if those individuals’ activities are legal under state law.  The Court’s ruling also established that “compliance with state drug laws and regulations cannot be used as a defense from arrest or prosecution under federal drug laws.”[4] 

[1] Gonzales v. Raich, 545 U.S. 1 (2005). 

[2] In Raich, federal agents seized and destroyed the cannabis plants of one of the respondents, who already had been deemed by local authorities to have been growing medical marijuana legally under California law.  Gonzales v. Raich, 545 U.S. 1 (2005).

[3] Id. at 17 (internal quotations omitted). 

[4] Todd Grabarsky, Conflicting Federal and State Medical Marijuana Policies:  A Threat to Cooperative Federalism, 116 W. Va. L. Rev. 1, 10 (2013).

Federal enforcement of the CSA’s prohibition on marijuana has changed over time and depending on the political landscape.  In 2009, former Deputy Attorney General David Ogden of the Department of Justice (“DOJ”) published a memo (the “Ogden Memo”) addressed to United States’ Attorneys[1] working in states that permit the use of marijuana, advising that they “should not focus federal resources in [their] States on individuals whose actions are in clear and unambiguous compliance with existing state laws.”[2]  However, after various states’ laws became increasingly permissive regarding the sale and/or large-scale cultivation of marijuana, DOJ clarified that the Ogden Memo was never intended to protect commercial activities from federal prosecution.[3] 

In 2013, DOJ, under former Deputy Attorney General James Cole, issued further guidance explicitly instructing United States Attorneys, when determining whether to prosecute a marijuana business, to consider not only the size or commercial nature of the business, but also whether the commercial operation is in compliance with state law (the “Cole Memo”).[4]  In accordance with the Cole Memo, prosecutors and law enforcement deciding whether to federally prosecute individuals and businesses for marijuana crimes focused on the following priorities[5] related to legal state cannabis operations:

• Preventing the distribution of marijuana to minors;
• Preventing revenue from the sale of marijuana from going to criminal enterprises, gangs, and cartels;
• Preventing the diversion of marijuana from states where it has been legalized to other states;
• Preventing state-authorized marijuana activity from being used as a cover or pretext for the trafficking of other illegal drugs or other illegal activity;
• Preventing violence and the use of firearms in the cultivation and distribution of marijuana;
• Preventing drugged driving and the exacerbation of other adverse public health consequences associated with marijuana use;
• Preventing the growing of marijuana on public lands and the attendant public safety and environmental dangers posed by marijuana production on public lands; and
• Preventing marijuana possession or use on federal property.

 The policy outlined in the Cole Memo remained in effect until early 2018 and was in place during the establishment of much of New York’s Compassionate Care Act. 

On January 4, 2018, in a memorandum (the “Sessions Memo”) that superseded the Ogden and Cole Memos, then Attorney General Jeff Sessions (who had been appointed by President Trump) rescinded the policies and themes set forth in those Memos and directed that prosecutions involving marijuana activities follow the “previously established prosecutorial principles that provide [law enforcement] with all the necessary tools to disrupt criminal organizations, tackle the growing drug crisis, and thwart violent crime across our country.”[6] 

Despite the DOJ’s current apparent willingness to pursue strict penalties against those that violate the CSA, there are nonetheless restraints on the federal government’s ability to prosecute conduct that is compliant with state medical marijuana laws.  For instance, the “Rohrabacher-Farr” Amendment (“Rohrabacher-Farr”), signed into law in 2014, prevents the DOJ from spending funds in a way that would hinder the implementation of state medical marijuana laws.[7]  Two years later, the Ninth Circuit clarified the purpose of the amendment, holding that Rohrabacher-Farr “prohibits DOJ from spending funds from relevant appropriations acts for the prosecution of individuals who engaged in conduct permitted by the [states that permit legal medical marijuana use] and who fully complied with such laws.”[8]  The Ninth Circuit expressly stated that Rohrabacher-Farr “does not provide immunity from prosecution for federal marijuana offenses…[a]nyone in any state who possesses, distributes, or manufactures marijuana for medical or recreational purposes (or attempts or conspires to do so) is committing a federal crime,” and that the amendment simply prohibits “the government from spending certain funds to prosecute certain individuals.”[9]

In June 2018, Senators Elizabeth Warren (D-Mass) and Cory Gardener (R-Co) introduced the bi-partisan STATES Act, which if passed, will amend the CSA such that the federal prohibition on marijuana will not apply in states that have legalized the drug.  (It will not, however, result in declassification of marijuana as a Schedule 1 drug.)  In addition, commercial marijuana activity that is legal under state law no longer will be considered drug trafficking for purposes of federal law, and proceeds from the activity will not be subject to forfeiture by DOJ.[10] 

In an apparent divergence from the Sessions Memo, President Trump said in June 2018 that he likely will support the STATES Act, which would drastically change the current policies and principles regarding federal legal action against marijuana users.[11]

References:

[1] All states are divided into federal judicial districts.  United States Attorneys, appointed by the President and confirmed by Congress, are the chief federal law enforcement agents in the judicial district they serve, and choose what federal crimes to prosecute within their territory.    

[2] Memorandum from Deputy Attorney General David W. Ogden to Selected United States Attorneys, Investigations and Prosecutions in States Authorizing the Medical Use of Marijuana (Oct. 19, 2009). 

[3] Memorandum from Deputy Attorney General James M. Cole to United States Attorneys, Guidance Regarding the Ogden Memo in Jurisdictions Seeking to Authorize Marijuana for Medical Use (June 29, 2011).

[4] Memorandum from Deputy Attorney General James M. Cole to all United States Attorneys, Guidance Regarding Marijuana Enforcement (Aug. 29, 2013). 

[5] Id.

[6] As explained in the Sessions Memo, “[t]hese principles require federal prosecutors deciding which cases to prosecute to weigh all relevant considerations, including federal law enforcement priorities set by the Attorney General, the seriousness of the crime, the deterrent effect of criminal prosecution, and the cumulative impact of particular crimes on the community.”  Memorandum from Attorney General Jefferson B. Sessions, III to all United States Attorneys, Marijuana Enforcement (Jan. 4, 2018). 

[7] 160 Cong. Rec. H4982 (daily ed. May 29, 2014).

[8] United States v. McIntosh, 833 F.3d 1163, 1178 (9th Cir. 2016) (emphasis added). 

[9] Id. at 1179.

[10] Elizabeth Warren and Cory Gardner, The STATES Act, available at https://www.warren.senate.gov/imo/media/doc/STATES%20Act%20One%20Pager.pdf.

[11] The STATES Act has not passed the Senate vote.  In December 2018, Senator Gardner attempted to attach the bill as an amendment to the First Step Act, a criminal justice reform bill being debated in the Senate during the lame-duck session of the 115th U.S. Congress, but that effort was blocked.  Senator Gardner has said that he plans to reintroduce the bill.  Anna Staver, Sen. Cory Gardner fails to get marijuana reform into criminal justice bill, The Denver Post (December 18, 2018), available at https://www.denverpost.com/2018/12/18/cory-gardner-marijuana-amendment-fails. Eileen Sullivan, Trump Says He’s Likely to Back Marijuana Bill, in Apparent Break With Sessions, N.Y. Times (June 8, 2018), https://www.nytimes.com/2018/06/08/us/politics/trump-marijuana-bill-states.html.

In April 2016, the Federation of State Medical Boards (FSMB) adopted the Model Guidelines for the Recommendation of Marijuana in Patient Care (the “FSMB Guidelines”).  The FSMB Guidelines are meant to be used by state medical boards in regulating physicians and physicians’ assistants and in establishing expectations for those practitioners who are regulated by the board and who recommend medical marijuana for certain patients.[1] 

The FSMB Guidelines[2] are as follows:   

• Physicians should adhere to current standards of practice and comply with state laws, rules and regulations, which may specify conditions for which a patient may qualify.
• Physicians’ offices should not be located at a marijuana dispensary or cultivation center.
• Physicians should not receive financial compensation from or hold a financial interest in marijuana-related businesses or be affiliated with them in any way.
• Physicians should not use marijuana either medicinally or recreationally while actively engaged in the practice of medicine.
• There should be an established physician-patient relationship before the physician considers the use of medical marijuana for the patient.
• Physicians should do a physical examination and gather health history, including documentation of previous therapies used by the patient and information on any personal or family history of substance abuse, mental illness, or psychotic disorders. The diagnosis should justify the consideration of medical marijuana.
• Physicians should review other treatment options. The known benefits and risks of marijuana should be presented, along with the warning that, unlike with FDA-approved drugs, there is variability and lack of standardization in marijuana preparation.
• If the physician advises the use of medical marijuana, a specific treatment plan for a limited period of time should be agreed upon, with details documented in the medical record. The physician should instruct the patient not to drive or operate heavy machinery while using marijuana.
• The patient should be seen for follow-up visits to monitor for the efficacy and side effects of medical marijuana.
• Patients with a history of mental health problems, substance abuse, or addiction should be referred for further evaluation as needed.

The FSMB Guidelines expressly note that marijuana is classified as a Schedule 1 substance under federal law and that it is possible for the federal government to prosecute those who engage in a conspiracy to purchase, cultivate, or possess marijuana.[3]  The already daunting possibility of federal prosecution of a physician complying with the FSMB Guidelines and with New York State laws and regulations takes on added significance in light of the Sessions Memo.

 References:

[1] See Federation of State Medical Boards, Model Guidelines for the Recommendation of Marijuana in Patient Care 1 (2016).

[2] Susan Fitzgerald, National Board Offers Guidance for Doctors Prescribing Medical Marijuana, Neurology Today (Sept. 22, 2016), at 17, 18.

[3] See Federation of State Medical Boards, Model Guidelines for the Recommendation of Marijuana in Patient Care 4 (2016). 

Given the direct conflict between New York State and federal law with respect to medical marijuana use, New York State practitioners who wish to prescribe (rather than simply recommend) medical marijuana for their patients under the Compassionate Care Act, but who also do not want to violate federal law, face a conundrum.  As long as marijuana remains a Schedule 1 substance under the CSA, compliance with federal law while participating in a state-run medical marijuana program will not be possible.  Nevertheless, practitioners in New York can lower their risk of federal prosecution by strictly complying with the Act and remaining up to date on and in compliance with any new regulations or requirements as they are signed into law.  Again, nothing in this report should be interpreted as providing guidance on this topic, definitive or otherwise.   

1. Clinical Endocannabinoid Deficiency Reconsidered: Current Research Supports the Theory in Migraine, Fibromyalgia, Irritable Bowel, and Other Treatment-Resistant Syndromes. Russo EB. Cannabis Cannabinoid Res. 2016 Jul 1;1(1):154-165. doi: 10.1089/can.2016.0009. eCollection 2016. Review.
2. Identification of a highly potent and selective CB2 agonist, RQ-00202730, for the treatment of irritable bowel syndrome. Iwata Y, Ando K, Taniguchi K, Koba N, Sugiura A, Sudo M. Bioorg Med Chem Lett. 2015 Jan 15;25(2):236-40.
3. Clinical endocannabinoid deficiency (CECD) revisited: can this concept explain the therapeutic benefits of cannabis in migraine, fibromyalgia, irritable bowel syndrome and other treatment-resistant conditions? Smith SC, Wagner MS. Neuro Endocrinol Lett. 2014;35(3):198-201. 
4. Irritable bowel syndrome: a dysfunction of the endocannabinoid system? Storr M, Allescher HD. Gastroenterology. 2012 Feb;142(2):406-8. doi: 10.1053/j.gastro.2011.12.028. Epub 2011 Dec 19.
5. The role of the endocannabinoid system in the pathophysiology and treatment of irritable bowel syndrome. Storr MA, Yüce B, Andrews CN, Sharkey KA. Neurogastroenterol Motil. 2008 Aug;20(8):857-68.
6. Clinical endocannabinoid deficiency (CECD): can this concept explain therapeutic benefits of cannabis in migraine, fibromyalgia, irritable bowel syndrome and other treatment-resistant conditions? Russo EB. Neuro Endocrinol Lett. 2008 Apr;29(2):192-200.
7. Clinical endocannabinoid deficiency (CECD): can this concept explain therapeutic benefits of cannabis in migraine, fibromyalgia, irritable bowel syndrome and other treatment-resistant conditions? Russo EB. Neuro Endocrinol Lett. 2004 Feb-Apr;25(1-2):31-9.