Persistent Inequities in Cannabis Policy

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arijuana is one of the most-used Persistent Inequities psychoactive substances in the MUnited States, second only to alcohol in popularity. An estimated 45 per- in Cannabis Policy cent of the adult population have now tried it in their lifetime.1 Public support for legal- By Katharine Neill Harris and William Martin ization has surged. A September 2019 Pew Research poll found that 91 percent of adults approve of legalizing cannabis for medical use, and 59 percent of this group say it should be legal for general adult use as well.2 Marijuana policy is slowly but steadily catching up to American preferences. Since 1996, 35 states have loosened cannabis laws. The majority of the U.S. population lives in a state with legalized medical access and a growing plurality live in a state where it is legal for adult use.3 In November 2020, cannabis legalization measures were approved in all states that had them, including Mississippi (for medical purposes); Arizona, New Jersey, and Mon- tana (for general adult use); and South Dakota (for both). Despite being widely available and highly tolerated, if not enthusiastically endorsed, marijuana remains an integral feature of the larger War on Drugs. More people are arrested for cannabis possession than any other offense in the United States. There were over 1.6 million drug arrests in 2018; 43 percent were marijuana related.4 Ninety-two percent of these marijuana arrests were for possession.5 Marijuana law enforcement has always disproportionately impacted people of color, a pattern that continues despite reform. Minorities are also less likely to

Katharine Neill Harris and William Martin are with Rice University’s Baker Institute for Public Policy.

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Published in The Judges' Journal, Volume 60, Number 1, Winter 2021. © 2021 by the American Bar Association. Reproduced with permission. All rights reserved. This information or any portion thereof may not be copied or disseminated in any form or by any means or stored in an electronic database or retrieval system without the express written consent of the American Bar Association. benefit from the financial opportunities and while increasingly punitive, drug policy Racial Disparities in Enforcement and legal access promised by legalization. was still largely piecemeal. The 1970 Con- Cannabis use rates are roughly equivalent Structural resistance to change and logis- trolled Substances Act streamlined drug across racial groups, yet Black people on tical hurdles to developing and policies by creating a classification system average are 3.64 times more likely to be implementing new regulatory structures are based on abuse potential and medical ben- arrested for possession, a disparity that has part of the problem. But at a basic level, efits.11 Marijuana, deemed to have no remained constant since 2010 despite sev- these inequities persist because of the fail- medical value and high potential for abuse, eral states’ loosening restrictions since ure to center reform around racial justice. was placed in Schedule I, where it remains then.17 Troublingly, disparities increased in A supposed benefit of policy change, today despite a wealth of evidence showing 31 states between 2010 and 2018.18 racial justice has too often been eclipsed the errors of this categorization.12 States that have legalized marijuana by arguments touting the economic and The linchpin of public support for mari- sales or decriminalized marijuana posses- personal liberty gains of legalization. Until juana prohibition—its association with sion have lower rates of racial disparities in recently, the expectation that legalization minorities and “deviant” populations— arrests compared to those that maintain will improve racial equity has been treated began to weaken in the 1960s as more prohibition. But in several states that legal- as a foregone conclusion, one requiring no middle-class white youth used cannabis ized or decriminalized possession between additional action beyond legalization itself. and the civil rights movement demanded 2010 and 2018, arrest disparities have We now know, and should have always equality for the disenfranchised. These increased, even as arrest rates have known, that this is not the case. changes, however, coupled with the coun- declined, demonstrating that these reforms try’s fracturing over the Vietnam War, alone are not enough to remedy systemic War on Marijuana: A Brief History sparked anger and fear among white Chris- inequities.19 Until roughly 100 years ago, prohibition of tian conservatives.13 Richard Nixon, first In some places, both arrests and dispari- mind-altering substances in the United in his presidential campaign and then dur- ties have trended up post-legalization. In States was a haphazard endeavor. A few ing his tenure in the White House, L.A. County, marijuana arrests increased states had laws against cannabis, cocaine, exploited and perpetuated white resent- between 2017, a year before legalization, and and opium use, motivated by xenophobia, ment over integration and civil rights by 2019, a year after legalization. During that racism, and fear that drugs would trigger constructing drugs and crime as problems period, the proportion of people arrested the moral demise of white people.6 The fed- of the urban poor and minorities.14 In 1971, who were Black increased from 29 percent eral government’s role in cannabis he declared the “War on Drugs.” In a recent to 42 percent.20 Most of these arrests were prohibition began in the 1930s with Harry interview, John Ehrlichman, a former related to transporting or selling marijuana, Anslinger and the Federal Bureau of Nar- domestic policy chief for Nixon, stated, but, as others have pointed out, these cotics (FBN). Anslinger, who led the FBN “We knew we couldn’t make it illegal to be charges are typically based on officer for 32 years, saw in cannabis an opportu- either against the war or black, but by get- assumptions, not direct viewing of selling nity to expand his agency’s power, which ting the public to associate the hippies with activity.21 In Los Angeles, the vast majority until that point was largely limited to marijuana and blacks with heroin, and of legal marijuana dispensaries are in white enforcing restrictions on opium prescrib- then criminalizing both heavily, we could neighborhoods, so state-sanctioned mari- ing.7 He launched a campaign vilifying disrupt those communities.”15 juana purchases are less physically accessible marijuana, his preferred term due to its Reflecting the changing attitudes on to minority communities.22 Mexican roots, claiming that it spawned cannabis use, 11 states reduced penalties Data from other cities suggest that criminal activity and sexual proclivity for cannabis possession between 1973 and minorities are more likely to get arrested among all who used it, but especially 1978.16 But the ensuing intensification of for minor marijuana-related law violations. among Blacks and Hispanics—a crusade the drug war halted further reforms, and In Washington, D.C., for example, where we know today as “Reefer Madness.”8 state cannabis laws remained relatively ending racial disparities was a central tenet The campaign was so successful that all stagnant until 1996, when California legal- of the successful 2014 campaign to legalize 48 states adopted anti-cannabis laws by ized cannabis for medical use. marijuana possession, 84 percent of people 1936; and in 1937, the United States passed arrested for public consumption since the the Marihuana Tax Act.9 The new law Continuing Inequities in change took effect have been Black (45 per- required people to register with the federal Cannabis Policy cent of the city’s population is Black).23 government and pay a tax on cannabis The recent shift toward legalization, while When states legalize medicinal canna- sales. More significantly, it enabled the beneficial in many respects, has not been bis use without taking additional measures, FBN to strengthen its enforcement powers, enough to undo the racism endemic to can- arrest disparities are also likely to continue, and it solidified the framing of cannabis nabis policy. This is apparent in the if not increase. Arizona, Arkansas, Florida, use as a criminal act.10 In the 1950s, persistent disparities in enforcement of Georgia, Louisiana, Montana, New Jersey, national and state-level laws enhanced remaining marijuana laws and in access to Oklahoma, Pennsylvania, Utah, and West penalties for marijuana possession and sale, the marijuana industry and its profits. Virginia currently allow medical use but

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Published in The Judges' Journal, Volume 60, Number 1, Winter 2021. © 2021 by the American Bar Association. Reproduced with permission. All rights reserved. This information or any portion thereof may not be copied or disseminated in any form or by any means or stored in an electronic database or retrieval system without the express written consent of the American Bar Association. prohibit simple possession (Montana and Simply Pure in Denver, becoming the first Lack of access to capital and systemic Arizona had legalization initiatives on the Black person legally licensed to own a can- economic racism dramatically winnow out November ballot and passed).24 Many peo- nabis dispensary, she hoped other Black the wannabes from the weed field. At less ple who use marijuana illegally do so for entrepreneurs would follow her lead. Per- than $10,000 each, cultivation and dispen- medical conditions. Residents of medical haps instead of serving as an entrapping sary licenses in Colorado are quite cannabis states can obtain a license fairly agent that funnels Black men and women reasonable, but so many have been issued easily—if they have health care access. into jails and prisons, marijuana would pro- that new applications are distributed by lot- Minorities and people who are poor are less vide honest employment in neighborhoods tery and the competition from likely to have this access and are also less lacking opportunity and inject sorely long-established growers and dealers is stiff. likely to live near licensed dispensaries. needed money back into communities of In many other states, these licenses are These factors increase the likelihood that color. But when PBS reporter Yamiche much more expensive. Illinois charges marginalized communities will continue Alcindor asked for her view of the canna- $25,000 just to apply for the cultivation fee; to use marijuana illicitly—even if they bis industry in June 2020, her response was those who are successful pay an annual fee have legitimate medical reasons to use and blunt: “White men. White men. White of $100,000. The range is wide and can live in a state with medical access—and men. White men.”28 depend on the cultivation area. Some states thus be more vulnerable to law enforce- James’s perspective was understandable. require evidence of deep pockets before ment intervention. A Denver Cannabis Business and Employ- even considering an application. Just to Marijuana arrest disparities are likely ment Opportunity Study published that apply for a $100,000 annual cultivation fee greater than available figures suggest. The same month reported that almost 75 per- in Arkansas, applicants must have a $1 mil- Federal Bureau of Investigation’s Uniform cent of the owners of licensed cannabis lion bond or assets worth $1 million and Crime Report, the go-to source for aggre- businesses in Denver city and county were be able to show $500,000 in cash liquidity gated arrest data, does not specify Latinx white, as were 68 percent of the employees to indicate the ability to be a viable com- ethnicity, typically coding individuals who of such businesses. “Blacks or African pany in an increasingly competitive identify as Latinx as white. This neglects Americans” accounted for less than 6 per- industry.32 Not surprisingly, similar chal- to account for disparate treatment of this cent in both those categories.29 Denver, lenges face those seeking to operate retail group and underestimates the Black-white however, is far from anomalous. A 2017 sur- cannabis dispensaries.33 disparities by inflating the number of white vey of 389 cannabis businesses in the 33 Such regulations can discourage aspi- marijuana arrests.25 states and D.C. where medicinal or adult- rants with the knowledge and ability to Conviction for a drug offense can have use marijuana is legal, found that 81 grow and sell cannabis successfully but serious consequences. A student can be percent of people who have “launched a without that much cash in hand.34 Aaron tossed out of school or lose a college loan or cannabis business and/or have an owner- McCrary, co-owner of one of the two scholarship. A parent can lose custody of a ship stake in a marijuana company” are Black-owned cultivation facilities in child or be barred from subsidized housing. whites, 5.7 percent are Hispanic/Latinos, Nevada, explained the dilemma to the A criminal record of any magnitude can and only 4.3 percent are Blacks/African Marijuana Business Daily. “When regula- make it extremely difficult to land a job. Americans.30 tors require $250,000 of liquid assets to Even when a conviction has been expunged, These low levels of involvement cannot score points on an application for new it does not completely go away, and many be explained as a failure of Blacks and licenses, those applicants with generational employers can likely see it without much other minorities to see the mind-blowing wealth have a distinct leg up,” he said. “The effort. And even without a conviction, a potential of the new industry. They saw it, ability to access large sums of legitimate marijuana arrest creates a publicly available they see it, they want to be part of it, but capital,” he said, “is the No. 1 impediment criminal record and can shape future inter- formidable obstacles, many already in place to success of all small businesses.”35 actions with the police.26 It would be naive for generations, make attaining it a daunt- According to Marijuana Business Daily, not to think this would be a greater disad- ing, often-disillusioning challenge. In the “The vast majority of U.S. marijuana com- vantage to Blacks than to whites.27 early push to legalize medicinal and adult- panies are privately owned and self-funded use cannabis, it appears that no serious by the founders.” Friends and family can Racial Disparities in the Cannabis effort was made to facilitate involvement chip in to help, “but only a small percent- Industry of minorities. Diversity and equitable dis- age of cannabis companies . . . will manage Unfortunately, the racial disparity evident tribution of the expected benefits simply to secure funding from private equity/ven- in the treatment of people who use mari- weren’t on the agenda. Ashley Kilroy, direc- ture capital firms or angel investors. . . . juana illegally finds its counterpart in the tor of Denver’s Office of Marijuana Policy, Furthermore, investors able to provide the burgeoning commercial industry that has said, “People didn’t know what they didn’t amount of funding that cannabis busi- developed in states that have legalized know at the time. I think [they] were just nesses need to get off the ground are, medical and/or adult use of cannabis. trying to get this passed and . . . up and generally speaking, white males. Whether In 2009, when Wanda James opened running.”31 consciously or unconsciously, white male

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Published in The Judges' Journal, Volume 60, Number 1, Winter 2021. © 2021 by the American Bar Association. Reproduced with permission. All rights reserved. This information or any portion thereof may not be copied or disseminated in any form or by any means or stored in an electronic database or retrieval system without the express written consent of the American Bar Association. investors tend to fund businesses run and State implemented a program to grant mar- always sufficient. Massachusetts’s licensing led by people who look like them—putting ijuana retail licenses to individuals program includes provisions to assist women and racial minorities at a impacted by the drug war.41 minority applicants or those who meet cri- disadvantage.”36 Other states are attempting to tackle teria such as having a past drug conviction racial disparities in conjunction with legal- or living in a neighborhood disproportion- Policies to Improve Equity ization. Illinois’s racial disparities in ately impacted by the drug war, but these Most early iterations of marijuana reform marijuana arrests increased by over 100 efforts are hampered by local control over did not incorporate equity provisions. That percent between 2010 and 2018, even the process that advantages big-money is starting to change, albeit more slowly though it decriminalized possession in players.47 When Ohio legalized medical than justice advocates would like. Federal 2016.42 But the Illinois Cannabis Regula- cannabis, the law required that 15 percent leadership, conspicuously absent so far, tion and Tax Act, signed into law in 2019, of dispensary licenses be reserved for racial could provide a blueprint for slow-moving includes measures for automatic expunge- minorities.48 This provision seemed effec- states to adopt equitable reforms. The Mar- ment of prior marijuana convictions (an tive; by 2018, 16 percent of state-awarded ijuana Opportunity Reinvestment and estimated 740,000 cases are eligible); assis- licenses had gone to minorities, but this Expungement Act of 2019 (MORE Act) tance in obtaining licensing, funding, and “racial quota” system was later found provides such an opportunity. training for marijuana business ownership unconstitutional.49 The MORE Act would decriminalize for people impacted by prohibition; and dis- marijuana by removing it from the list of tribution of 25 percent of tax revenue to a Conclusion federally controlled substances and abol- community investment program.43 It is too Cannabis legalization alone cannot erase ishing criminal penalties for possession, soon to tell whether the program, imple- the racist legacy of prohibition. Many addi- distribution, and manufacturing.37 Several mented in January 2020, is having the tional measures are needed to dismantle other provisions address racial disparities intended effect, but it is a promising effort. this system. Expungements for past convic- and other damages caused by the drug war, Still, equity concerns are too often not tions should be automatic. Penalties for including establishing a federal expunge- a central focus of reform initiatives. The remaining law violations in legal states, ment process for marijuana convictions, legalization measures in Mississippi, Mon- such as underage or public use, should be prohibiting denial of federal benefits or tana, and South Dakota do not address drastically reduced or eliminated and immigration protections on the basis of industry equity, and while Arizona and should not include collateral consequences marijuana-related convictions, creating a Montana allow residents to apply for like state supervision. Medical legalization trust fund to support services in communi- expungement of past marijuana convic- measures should decriminalize simple ties impacted by the drug war, and requiring tions, this is a limited offering that burdens possession. the Bureau of Labor Statistics to collect individuals with initiating the process.44 Newly created medical and adult-use and publish demographic data on those Even when policymakers try to address programs must incorporate social equity who work in the marijuana industry.38 Fed- racial disparities, effort does not guarantee measures from the outset. In addition to eral decriminalization would also help success. Sometimes bill language is too giving priority licenses to social equity diversify the cannabis industry by giving vague, as in Maryland’s case, where law- applicants, states should provide assistance banks the green light to approve loans for makers directed the Medical Cannabis with the licensing process, lower the finan- cannabis-related businesses, granting Commission to “actively seek to achieve cial barrier to entry, and fund programs potential access to capital among less racial, ethnic, and geographic diversity.” that offer mentorship and training in the wealthy cannabis entrepreneurs. None of the first 15 licenses issued in the industry.50 States and localities should com- The House of Representatives is state went to Black applicants. Joe Gaskin, mit to investing a sizable portion of expected to vote on the MORE Act later a spokesperson for the African American industry tax revenue in communities in 2020.39 Even if it is signed into law, an Cannabis Association, said, “unfortunately, impacted by the drug war. Localities should outcome far from certain, the degree to when minority inclusion has been written seek residents’ input regarding how these which cannabis policies promote equity into legislation, there is a struggle to gain funds are spent. Data collection, transpar- effectively will also depend on individual support and passage into law.”45 The state’s ency in the licensing process, and fiscal states. Some states have incorporated medical cannabis program was sued for fail- accountability are critical to ensuring these equity measures, but these efforts vary con- ing to promote industry diversity, and measures are effective. siderably. A few early legalizers that ignored Maryland has since passed legislation more States and localities should be doing all equity factors initially have since made explicitly requiring consideration of appli- they can to implement cannabis reform in tweaks to address these concerns. Califor- cants’ race, but the program continues to an equitable manner, but, ultimately, we nia legalized adult use in 2016 and encounter regulatory and legal need national leadership. The federal gov- instituted automatic expungement for past problems.46 ernment started the war on marijuana, and convictions in 2018.40 In 2020, eight years Specific language is necessary to achiev- it must be the one to end it. It is the only after it legalized adult use, Washington ing desired equity outcomes but is not entity that can remove cannabis from the

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Published in The Judges' Journal, Volume 60, Number 1, Winter 2021. © 2021 by the American Bar Association. Reproduced with permission. All rights reserved. This information or any portion thereof may not be copied or disseminated in any form or by any means or stored in an electronic database or retrieval system without the express written consent of the American Bar Association. list of Schedule I controlled substances, harpers.org/archive/2016/04/legalize-it-all. 37. Marijuana Opportunity Reinvestment and allow more scientific research, and give 16. Neill Harris, supra note 13. Expungement Act, Summary: S.2227, 116th Cong. banks legal cover to provide cannabis- 17. ACLU, supra note 4. (2019–2020), https://bit.ly/3jcOFu4. related business loans. When the federal 18. Id. 38. Id. government eventually enacts marijuana 19. Id. These states include Delaware, Illinois, 39. Sarah Ferris & Natalie Fertig, House Punts reform, we hope it will do so with social Maine, New Hampshire, Rhode Island, and Marijuana Vote, Politico (Sept. 17, 2020), https:// justice and racial equity as primary goals Vermont. politi.co/334DrSp. and that this victory will mark the begin- 20. Alexander Lekhtman, Why Are Black Arrest 40. A.B. 1793, ch. 993, Cal. Legis. Info. (Oct. ning of an end to the War on Drugs. n Rates for Marijuana Rising in Los Angeles?, Filter 1, 2018), https://bit.ly/3j6FECp. Mag. (July 16, 2020), https://bit.ly/3cCMkWO. 41. Wash. State Liquor & Cannabis Bd., Fact Endnotes 21. Id. Sheet: Bill No. E2SHB 2870, Allowing Additional 1. SAMHSA, Results from the 2018 22. Id. Marijuana Retail Licenses for Social Equity Purposes National Survey on Drug Use and Health 23. Paul Schwartzman & John D. Harden, D.C. (June 11, 2020), https://bit.ly/3kTuqBI. (2019). Legalized Marijuana, But One Thing Didn’t Change: 42. ACLU, supra note 4. 2. Andres Daniller, Two-thirds of Americans Almost Everyone Arrested on Pot Charges Is Black, 43. Overview of the Illinois Cannabis Regulation Support Marijuana Legalization, Pew Rsch. Ctr. Wash. Post (Sept. 15, 2020), https://wapo. and Tax Act, Marijuana Pol’y Project (2019), (Nov. 14, 2019), https://pewrsr.ch/2Gh99mv. st/344qSpt. https://bit.ly/3690gqf; Adult-Use Legalization Pro- 3. Christopher Ingraham, Michigan Becomes 24. ACLU, supra note 4. gram Launches, Marijuana Pol’y Project (Jan. 10th State to Allow Recreational Marijuana, Wash. 25. Id. 21, 2020), https://bit.ly/3idfWLC. Post (Nov. 7, 2018), https://wapo.st/2S8gG9T; 26. Just a Slap on the Wrist? The Life-Changing 44. See 2020 Ballot Initiatives, Marijuana Pol’y Medical Marijuana Patient Numbers, Marijuana Consequences of a Marijuana Arrest, Drug Pol’y Project (2020), https://bit.ly/3eCSpU8. Pol’y Project (July 6, 2020), https://bit.ly/36e1dNV. All. (Feb. 9, 2016), https://bit.ly/3kYWy6A. 45. Brentin Mock, Race and Weed in Maryland, 4. Am. Civil Liberties Union, A Tale of Two 27. Chris Keyser, Who Can See My Criminal Bloomberg CityLab (May 4, 2017), https://bloom. Countries: Racially Targeted Arrests in the Record After It Is Expunged?, Keyser L. Blog (Dec. bg/3i3JVoV. Era of Marijuana Reform (2020). 6, 2016), https://bit.ly/3cIc4kn. 46. See Erin Cox, Maryland Medical Marijuana 5. Id. 28. Yamiche Alcindor, Why the Legal Marijuana Regulators Sued for Not Considering Racial Diversity 6. Kenneth J. Meier, The Politics of Sin: Industry Is Now Struggling with Diversity and Inclu- of License Winners, Balt. Sun (Oct. 31, 2016), Drugs, Alcohol, and Public Policy (1994); sion, PBS News Hour (July 12, 2020), https:// https://bit.ly/2S0aqRM; Doug Donovan, Mary- Michael Tonry, Race and the War on Drugs, 1994 to.pbs.org/3i8yFYG. land’s Plan to Diversify Medical Cannabis Market Univ. Chi. Legal F. 25 (1994). 29. Analytic Insight, Denver Cannabis Busi- Attracts 160 Applicants for 14 New Licenses Despite 7. See Johann Hari, Chasing the Scream: ness and Employment Opportunity Study 17 Snags, Balt. Sun (May 29, 2019), https://bit. The Opposite of Addiction Is Connection (June 2020), https://bit.ly/3cDkr0x. ly/3481a3s; Mary Anne Pazanowski, Suit over (2015). 30. Eli McVey, Chart: Percentage of Cannabis Maryland’s Medical Marijuana Licensing Scheme 8. Id. Business Owners and Founders by Race, Marijuana Bounced, Bloomberg Law (Sept. 17, 2020), https:// 9. Katharine Neill, Tough on Drugs: Law and Bus. Daily (Sept. 11, 2017), https://bit.ly/3mY4yqo. bit.ly/3j9D4M2. Order Dominance and the Neglect of Public Health 31. Alcindor, supra note 28. 47. Natalie Fertig, Local Rule Is Undermining in U.S. Drug Policy, 6 World Med. & Health 32. Associated Press, Want to Grow Arkansas Massachusetts’ Attempt to Create Equity in the Can- Pol’y 375 (2014). Medical Marijuana? Here’s How Much You Need to nabis Industry, Politico (Mar. 6, 2020), https:// 10. Meier, supra note 6. Pay Annually, The Cannabist (Jan. 5, 2017), politi.co/3cEzjMq. 11. David T. Courtwright, The Controlled Sub- https://dpo.st/36bC9Hj. 48. Eli McVey, Not All States’ Cannabis Social stances Act: How a “Big Tent” Reform Became a 33. Gary Cohen, How Much Does It Cost to Hold Equity Programs Are Equal, Marijuana Bus. Daily Punitive Drug Law, 76 Drug & Alcohol Depen- a Cannabis Dispensary?, Cova (Oct. 23, 2019), (Aug. 20, 2019), https://bit.ly/3cxpr73. dence 9 (2004). https://bit.ly/3mUPeL7. 49. Ohio Judge: Medical Marijuana Ownership 12. See Nat’l Acads. Sci., The Health Effects 34. Noelle Skodzinski, Your State-by-State Guide “Racial Quota” Is Unconstitutional, Marijuana of Cannabis and Cannabinoids (2017). to Cannabis Cultivation Business Application and Bus. Daily (Nov. 19, 2018), https://bit.ly/36bW8pA. 13. Katharine Neill Harris, North American Drug Licensing Fees, Cannabis Bus. Times (Feb. 28, 50. Jessica F. Gonzalez & Brian J. Ellis, Social Policy: American and Canadian Developments from 2019), https://bit.ly/36en8EW. Equity and Cannabis in NJ Ahead of November Bal- the Early Twentieth Century to Today, in Research 35. Bart Schaneman, Scant Minority Ownership lot Initiative, N.J.L.J. (June 24, 2020), https://bit. Handbook on International Drug Policy 54 in Nevada’s Cannabis Industry, Spurring Calls for ly/30eftm7. (David R. Bewley-Taylor & Khalid Tinasti eds., Social Equity Reform, Marijuana Bus. Daily (Aug. 2020). 20, 2020), https://bit.ly/2FYJtvs. 14. Neill, supra note 9. 36. Marijuana Business Daily, Women & 15. Dan Baum, Legalize It All: How to Win the Minorities in the Cannabis Industry (2019), War on Drugs, Harper’s Mag. (Apr. 2016), https:// https://bit.ly/2HyOHhH.

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