Short answer: no. Before the longer answer, let me welcome you to the first installment of “Blunt Legal Talk,” my to-be-regular column for Honeysuckle. I’m thrilled and honored to have been asked! As a seasoned corporate lawyer, author and entrepreneur, I have been representing investors and entrepreneurs in the cannabis industry for five years. I also do quite a bit of speaking and writing on the subject (my blog is at In this column we hope to bring you plain English (and hopefully entertaining) perspective on the important legal issues the industry faces. From constitutional lawsuits to new states coming online to issues in employment and bankruptcy, there is no shortage of topics. So let’s begin!

As many know, in Barack Obama’s second term the famous Cole Memorandum was issued by his Justice Department. The missive, released in 2014 by then Deputy Attorney General James Cole, told the US Attorneys nationwide that there were to be eight principal priorities in the federal government’s enforcement effort in cannabis. These included things like preventing cannabis distribution to minors and the entrance of criminal enterprises, gangs and cartels. Most believed this meant essentially hands off folks who comply with state cannabis laws, even though the possession and sale of cannabis remains a federal crime.