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STATE OF OREGON, Plaintiff-Appellant and Petitioner on Review, v. AMBER and MICHAEL CASTILLEJA, Defendant-Appellees and Respondents on Review
APPLICATION TO APPEAR AS AMICUS CURIAE IN SUPPORT OF THE RESPONDENTS ON REVIEW, AMBER AND MICHAEL CASTILLEJA, BY THE NATIONAL ORGANIZATION FOR THE REFORM OF MARIJUANA LAWS
The National Organization for the Reform of Marijuana Laws (NORML) applies, pursuant to ORAP 8.15(1), for permission to appear as amicus curiae in this case and file a brief (filed herewith) in support of the Respondents on Review, Amber and Michael Castilleja. As grounds therefor, the Applicant NORML states as follows: 1. Applicant=s Non-Private Interest. The Applicant intends to present a position as to the correct rule of law that does not affect a private interest of its own, except to the extent that the correct rule of law serves its members= fundamental state and federal constitutional rights of access to and use of doctor-recommended medicine (including the natural herbal remedy marijuana, the use of which is protected under the state Medical Marijuana Act, ORS 475.300 ; OMMA) without impairing their concomitant entitlements to health, privacy and due process of law.
House of Representatives. The Applicant seeks the regulation. located in Portland. with its primary office located in Washington. the effective protection of adolescents from current massive levels of criminal marijuana distribution empowered by Marijuana Prohibition. a former Speaker of the U. and a former U. Supreme Court Justice. It has approximately 15. The Applicant.S. entailing a loss of more than 40 billion dollars in business and individual tax revenues.000 dues paying members. and costing more than 10 billion dollars in law enforcement resources) by adults and adolescents for the past thirty years. Despite the arrest of an American citizen for marijuana possession at a rate of approximately one every forty seconds pursuant to state and federal Marijuana Prohibition. The Applicant is the oldest drug policy reform (antiprohibition) organization in the nation. -2- .S. Vice-President and Nobel Prize winner. more than half the adults in the United States have used marijuana at least once. Today. President. including by their own admissions: A sitting U. D. Oregon (other affiliates are located in Eugene and Long Valley). and x state-based affiliates from Hawaii to Maine including Oregon NORML. marijuana use has continued unabated at substantial rates (an annual criminal enterprise with an estimated annual value more than 100 billion dollars. The Applicant is a non-profit educational corporation organized in 1971 under the laws of the District of Columbia. 420. control and taxation of a marijuana under state law and administrative regulation to achieve.C.S. a former U. The Applicant=s Public Interest.2. seeking to educate the public and legislators as to the futile and counterproductive impact of Marijuana Prohibition as a matter of federal and state law.000 internet-based supporters.S. among other public benefits. 3.
Department of Health and Human Services. after a million dollar study funded by the federal government in 1999.S. commensurate with a patient=s state and federal constitutional rights to health. similar to the OMMA. an agency of the U. Departments of Justice. to which application process the Applicant contributed. and Health and Human Services. by state legislatures and ballot initiatives. of state laws protecting patient access to doctor-approved use of marijuana for medicinal and palliative purposes in twelve states (including Oregon neighbors California and Washington). privacy and due process of law without unreasonable government interference. Also. The Applicant=s Special Expertise Concerning This Case. as having an accepted medical use. an application pursuant to 21 U. is pending before the U. This case presents an issue concerning patient access to and use of marijuana recommended by a state licenced doctor pursuant to the OMMA. to reschedule marijuana under federal controlled substances act.C. Marijuana was found to have effective medical uses by the National Institute of Medicine. -3- . sec. The Applicant has been instrumental in the adoption.4.S.S. 811 et seq. to which the Applicant contributed.
WHEREFORE. Salem OR 97301. Dated: May 8. 1162 Court St NE. MA BBO# 110940 46 Kenwood Street Brookline MA 02446-2413 Telephone: (617) 816-6056 E-mail: Michaeldcutler@Aim. 2008 X -4- . Moan. and that its brief herewith be accepted for filing. or that the Court grant such other relief deemed appropriate. I mailed a copy of this application to Assistant Attorney General Rolf C. the Applicant moves that this application (for permission to appear as amicus curiae in this case on behalf of the Respondents on Review) be granted. Oregon State Dept.com Certificate of Service: I hereby certify that on this date. Cutler. NATIONAL ORGANIZATION FOR THE REFORM OF MARIJUANA LAWS By Its Attorney: Michael D. of Justice Appellate Division.