Cannabis Does Not Belong in the Controlled Substances Act
Jason Greninger, Senior Vice President of Operations for Compassion Center and Director of Legislative and Congressional Advocacy for the Coalition for Patient Rights, on behalf of the Coalition for Patient Rights and Compassion Center, has formally submitted a petition and motion to the United States Attorney General, the United States Secretary of Health and Human Services, and the Drug Enforcement Administration Administrator calling for the full descheduling of cannabis from the federal Controlled Substances Act.
For patients, caregivers, and advocates across the country, this is not an academic debate. It is a fight over whether people should be treated like criminals for growing, using, processing, or sharing a plant that many rely on as part of their everyday health, stability, and quality of life.
The current federal framework was not built around real patients. It was built around control, restriction, and a one-size-fits-all drug policy that does not adequately reflect the realities of medical cannabis, patient autonomy, or state-level access programs. That is why CPR is pushing beyond half-measures and calling for full descheduling. The Controlled Substances Act sorts substances into five schedules based on medical use, abuse potential, and dependence liability, and the Justice Department’s 2024 proposal was only to move marijuana from Schedule I to Schedule III, not remove it from the CSA entirely.
Why We Filed:
CPR’s filing is meant to do more than make noise. It is meant to force a serious federal reckoning with a system that still fails patients, burdens providers, and leaves ordinary people exposed to criminal liability for conduct that many Americans and many states already recognize as lawful, necessary, and humane.
This effort is about preserving the rights of patients to:
- grow their own cannabis
- process their own cannabis into the form that works best for them
- share their medicine with other patients in need
- live free from unnecessary criminal exposure and regulatory overreach
It is also about making clear that patients should not have to spend their life savings trying to become a federally compliant pharmaceutical operation just to avoid being treated like traffickers for possession, production, manufacturing, or distribution.
Why Schedule III Is Not Enough
Moving cannabis to Schedule III may sound like progress, but it would still keep cannabis inside the federal controlled-substance system. That matters.
Under federal law, Schedule III substances remain controlled substances subject to registration, manufacturing, distribution, dispensing, recordkeeping, and anti-diversion controls. Federal law requires persons who dispense controlled substances to obtain registration, and it separately regulates manufacturers, distributors, practitioners, and pharmacies within that framework. The statute also defines “dispense” as delivery to an ultimate user by, or pursuant to, the lawful order of, a practitioner.
That is a very different model from patients growing a plant at home, preparing it for personal use, or sharing it compassionately with another patient. If cannabis remains in Schedule III, it stays inside a federal architecture designed for controlled-drug channels, lawful orders, registrants, inventory controls, and diversion enforcement. Schedule III prescriptions also operate within prescription rules that include refill limits and practitioner authorization requirements.
So the problem is not only symbolism. The problem is structural.
A Schedule III System Still Favors a Pharmaceutical Model
A Schedule III approach would not simply “free cannabis up.” It would move cannabis into a framework that is far more consistent with prescription-drug regulation than with patient cultivation, community access, or small-scale medical use. This means that all the work that we have done to create medical cannabis programs will be rolled back.
Federal law provides for registration of Schedule III manufacturers, distributors, practitioners, and pharmacies, and DEA guidance for controlled substances centers heavily on practitioner orders, pharmacy dispensing, recordkeeping, security, and diversion control. The Department of Justice’s Office of Legal Counsel has also stated that marijuana could be moved to Schedule III while DEA imposes additional restrictions under its CSA authorities.
That is why many patients and advocates are concerned that a Schedule III outcome would increase pressure to push cannabis further into pharmacy-like and prescription-driven channels instead of protecting the rights of patients to grow, process, and access their medicine more directly. That concern is an inference from the federal framework itself.
Cannabis Is a Plant Before It Is a Pharmaceutical Product
Cannabis in its raw botanical form is not the same thing as a finished, FDA-approved drug product.
FDA’s own botanical drug guidance describes a formal drug-development pathway involving manufacturing controls, characterization of botanical raw materials and drug substances, process controls, consistency, and eventual NDA-level review for commercial drug products. FDA has also explained that cannabis-derived human drugs must meet the same approval standards as other human drugs.
That is precisely the point. Once government forces a plant into a pharmaceutical-style pathway, the people most likely to be squeezed out are not multinational companies. They are patients, caregivers, small operators, and community-based access models.
Cannabis should not remain trapped in a federal framework that treats a plant like contraband unless it is filtered through a tightly regulated commercial drug channel.
What Is Broken About the Current System
The current system is inadequate because it creates contradiction after contradiction:
Patients can be lawful under state systems and still vulnerable under federal law.
A plant with accepted medical use under many state programs is still trapped inside a federal controlled-substance framework.
Patients who grow or process their own medicine can still face criminal exposure because the system was not built around personal medical autonomy.
The people with the least money are often the ones forced to carry the highest legal risk.
Even the federal government’s own recent actions show the problem. In May 2024, the Justice Department announced a proposed rule to move marijuana to Schedule III, which implicitly recognized accepted medical use while still keeping marijuana inside the CSA. And the Office of Legal Counsel made clear that Schedule III could still come with additional federal restrictions.
That is not full freedom. That is a partial reclassification inside the same old cage.
What We Are Asking For
CPR is calling for full descheduling of cannabis from the Controlled Substances Act.
That means removing cannabis from the federal scheduling framework entirely rather than merely relocating it from one schedule to another.
Descheduling would create room for a more rational system that:
- protects patients instead of criminalizing them
- respects the right to grow and process personal medicine
- protects compassionate sharing between patients
- reduces unnecessary compliance burdens built for controlled-drug channels
- distinguishes between a raw botanical plant and a finished pharmaceutical product
- allows states, patients, providers, and policymakers to build standards that fit reality
Why Awareness Matters Now
This petition is not just a filing. It is a call for public awareness.
If the public only hears that cannabis might move to Schedule III, many people will assume the problem has been solved. It has not. Schedule III would still leave cannabis under the Controlled Substances Act, still subject to federal control, and still vulnerable to added restrictions.
Patients deserve a solution that reflects how cannabis is actually used in the real world, not one that forces them into a regulatory structure built for something else.
Stand With Patients. Support Descheduling.
Help us raise awareness.
Help us defend the rights of patients to grow, process, and share their medicine.
Help us push back against a system that still treats patients like criminals for choosing a plant over a pill.
Help us call on federal leaders to do what partial reform will not: fully deschedule cannabis.
Take action. Share the message. Support the petition.
A Truly Historic Partnership
The Coalition for Patient Rights (CPR) and the Stormy Ray Cardholders’ Foundation (SRCF) have formed a uniquely aligned partnership to strengthen, organize, and amplify the collective voice of medical cannabis patients and the advocates who stand beside them.
Through this partnership, SRCF has taken a leading role in helping CPR steer its medical cannabis-focused advocacy priorities, including the rights of patients to grow, use, and process their own medicine, the need for meaningful protections against infringements on those rights, the establishment of practical and ethical standards, and the urgent push to remove cannabis from the federal Controlled Substances Act.
This is more than a symbolic alliance. It is a working partnership built to protect patients, sharpen public policy positions, and help ensure that those most directly affected by cannabis laws are not left out of the conversation.
Its Official
Coalition for Patient Rights and our management partner, Compassion Center, have filed the official petition and motion to De-Schedule cannabis from the DEA’s Controlled Substances Act.
Why This Partnership Matters
For too long, patients have had to navigate a patchwork of laws, penalties, stigma, and institutional barriers that fail to reflect the realities of medical need, bodily autonomy, and personal liberty. CPR, the Compassion Center and the SRCF believe patients deserve more than partial protections and political half-measures.
Together, these organizations are advancing a framework that supports:
- Patient rights to grow their own medicine
- Patient rights to use their medicine without unjust interference
- Patient rights to process their medicine in forms that meet their medical needs
- Clear protections against discrimination, retaliation, and unnecessary government intrusion
- Thoughtful standards that protect patients without criminalizing them
- Full descheduling of cannabis from the Controlled Substances Act
A Distinct Membership Model with Shared Strength
This partnership also creates a powerful membership bridge between these two organizations.
Members of the Stormy Ray Cardholders’ Foundation are automatically enrolled as members of the Coalition for Patient Rights, strengthening CPR’s collective advocacy voice with the lived experience, legacy, and cannabis-specific focus of SRCF’s membership base.
Members of the Coalition for Patient Rights are welcome to become members of the Stormy Ray Cardholders’ Foundation, but CPR membership alone does not automatically create SRCF membership. CPR members must affirmatively elect to join SRCF in order to receive the benefits and alignment that come with that additional membership.
This structure is intentional. It preserves the unique identity and mission of each organization while creating a stronger, more coordinated patient-rights movement.
Built for Advocacy. Grounded in Patients. Focused on the Future.
SRCF brings a historic and deeply rooted patient-centered perspective to the cannabis conversation. CPR brings a broader coalition model focused on defending and advancing patient rights across public policy, public education, and coordinated advocacy. Together, they are helping shape a more disciplined, more credible, and more forceful voice for cannabis patients at a time when clarity, courage, and organization are needed most.
Stand with patient rights. Join the movement. Strengthen the voice. Click on the button below to be taken to the SRCF and get started!