When Governor Phil Murphy signed legislation in 2021 to legalize marijuana for adult use, that moment could trace its roots back to 1996 and the voters of California approving the Compassionate Use Act, known as Proposition 215. California became the first state to approve the use of cannabis for medical purposes in direct violation of the federal Controlled Substances Act of 1970 (“the CSA”).

Over 25 years later, 37 states have legalized cannabis for medical purposes, and 19 states permit recreational adult use. Yet the text of the CSA remains the same—cannabis is an illegal Schedule I drug with the high potential for abuse and no accepted or known safe medical use.