HomeMy WebLinkAbout18 - Medical Marijuana Dispensaries MoratoriumCITY OF NEWPORT BEACH
CITY COUNCIL STAFF REPORT
Agenda Item No. 18
May 24, 2005
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: Aaron C. Harp, Assistant City Attorney
Ext. 3131, aharp(@city.newport- beach.ca.us
SUBJECT: Interim Urgency Ordinance Establishing a Temporary Moratorium on the
Establishment and Operation of Medical Marijuana Dispensaries
ISSUE:
Should the City adopt an interim urgency ordinance establishing a temporary
moratorium on the establishment and operation of medical marijuana dispensaries?
RECOMMENDED ACTION:
Adopt the attached interim urgency ordinance placing a temporary forty -five (45) day
moratorium on the establishment and operation of medical marijuana dispensaries.
(Requires five Councilmembers' votes).
BACKGROUND:
In 1996 the voters of California approved by voter initiative "The Compassionate Use
Act of 1996," also known as Proposition 215, and codified at Health & Safety Code
Section 11362.5 et seq. The purpose of Proposition 215 was to allow people to obtain
and use medical marijuana under certain specified circumstances.
In 2003, the state legislature approved SB 420 which provided additional statutory
guidance for those involved with medical marijuana use. One of the sections added to
state law by this bill is California Health & Safety Code Section 11362.83, which
provides "nothing in this article shall prevent a city or other local governing body from
adopting and enforcing laws consistent with this article." Hence, cities are authorized to
enact rules and regulations with regard to medical marijuana consistent with California
law.
The City has received inquiries from individuals wanting to open medical marijuana
dispensaries in the City of Newport Beach. One individual, Adam Powers, has asked for
Proposed Interim Urgency Ordinance Regarding
Medical Marijuana Dispensaries
May 24, 2005
Page 2
information on what type of application would be required to open such a facility and
what zone a medical marijuana dispensary could legally operate.
Currently, the Newport Beach Municipal Code does not specifically address the
regulation or location of medical marijuana dispensaries or list medical marijuana
dispensaries as a permitted use in any zoning district. Section 20.05.010 of the
Newport Beach Municipal Code provides that "the Planning Director shall determine
whether a specific use shall be deemed to be within one or more use classifications or
not within any classification in this Code." Pursuant to Section 20.05.020 of the
Newport Beach Municipal Code, "any new use, or any use that cannot be clearly
determined to be in an existing use classification, may be incorporated into zoning
regulations by a Zoning Code text amendment, as provided in chapter 20.94."
DISCUSSION:
The Newport Beach Municipal Code does not specifically address the regulation or
location of medical marijuana dispensaries. An increasing number of cities have
adopted ordinances placing temporary moratoriums on such dispensaries. For
instance, in the last few months the Cities of San Francisco, Modesto, Ontario,
Huntington Beach, Lake Forest, Long Beach and West Hollywood have imposed
moratoriums until the rules for the dispensaries can be clarified and /or developed. As
more local cities regulate or ban medical marijuana dispensaries, it is increasingly likely
that medical marijuana dispensaries may seek to locate in the City of Newport Beach in
the immediate future.
Currently, there appears to be a conflict between state and federal laws relating the
legality of medical marijuana dispensaries. Although the State of California passed
Proposition 215 in 1996, and then SIB 420 in 2003 (effective January 1, 2004), which
allowed for the establishment of medical marijuana dispensaries under very limited
circumstances, the United States Supreme Court in United States v. Oakland Cannabis
Buyers' Cooperative, (2001) 532 U.S. 483 held that the federal Controlled Substances
Act continues to prohibit marijuana use, distribution, and possession, and that no
medical necessity exceptions exist to those prohibitions. Further, the U.S. Supreme
Court is currently reviewing, and is due to issue its decision this summer, the case of
Raich v. Ashcroft, (2003) 352 F.3d 1222, in which the 9th Circuit held that the federal
Controlled Substances Act was likely unconstitutional. It is also important to note that
where state and federal laws are in conflict or are inconsistent, the federal law will
generally preempt the state law pursuant to the Supremacy Clause of the U.S.
Constitution.
Based on the apparent conflict in laws and the pending U.S. Supreme Court opinion
resolving the conflict, the fact that federal preemption over the inconsistent laws
currently seems to indicate that medical marijuana dispensaries may be illegal, the
Proposed Interim Urgency Ordinance Regarding
Medical Marijuana Dispensaries
May 24, 2005
Page 3
establishment of a medical marijuana dispensary moratorium is appropriate until such
time that the issue is resolved and /or clarified by the U.S. Supreme Court.
Further, a moratorium is necessary to give the Planning Commission, the City Council,
and the public an opportunity to determine the appropriateness of such facilities within
the City of Newport Beach including, but not limited to, evaluating the legality of such
facilities, the legal authority to establish such facilities, the desirability of such facilities,
zoning conflicts which would be created by the establishment of these facilities and the
extent of regulatory controls (e.g. location and operational controls), should such
facilities be thought appropriate.
The need for proper regulation of these facilities, if deemed to be legal and appropriate,
is crucial so that these sites do not become magnets for non - medical marijuana sales,
drug dealings and other crimes. Specifically, medical marijuana dispensaries have
been established in several locations in California, and as a consequence, some local
agencies have reported increases in illegal drug activity, illegal drug sales, robbery of
persons leaving dispensaries, loitering around dispensaries, falsely obtaining
"identification cards" to qualify for medical marijuana, and other increases in criminal
activity. Recent examples include: men who kicked in the window of a medical
marijuana dispensary in Oakland and tried to rob the dispensary; and, at another
medical marijuana dispensary in Alameda County, thieves broke into the building and
robbed the safe as well as persons present. The United States Department of Justice's
(DOJ) California Medical Marijuana Information report has advised that large -scale drug
traffickers have been posing as "care givers" to obtain and sell marijuana.
Pursuant to Government Code § 65858, the City Council may, without following the
procedures otherwise required prior to adoption of a zoning ordinance, adopt as an
urgency measure an interim ordinance prohibiting any use that may be in conflict with
the contemplated general plan, specific plan, or zoning proposal that the City Council,
Planning Commission or the Planning Department is considering or studying or intends
to study within a reasonable time. Under Government Code § 65858, any urgency
ordinance measure shall require a four -fifths (4/5) vote of the City Council for adoption.
Further, Section 412 of the City Charter provides that "an emergency measure for
preserving the public peace, health, or safety, and containing a statement of the
reasons for its urgency, may be introduced and adopted at one and the same meeting if
passed by at least five affirmative votes."
ENVIRONMENTAL REVIEW:
Environmental review is not required under the California Environmental Quality Act
(CEQA) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or
reasonably foreseeable indirect physical change in the environment) and 15060(c)(3)
(the activity is not a project as defined in Section 15378) of the CEQA Guidelines,
Proposed Interim Urgency Ordinance Regarding
Medical Marijuana Dispensaries
May 24, 2005
Page 4
California Code of Regulations, Title 14, Chapter 3, because it has no potential for
resulting in physical change to the environment, directly or indirectly and it prevents
changes in the environment pending the completion of the contemplated municipal code
review.
PUBLIC NOTICE:
Pursuant to Government Code § 65858, the City is not required to follow the procedures
otherwise required prior to adoption of a zoning ordinance.
ALTERNATIVES:
Do not adopt an interim urgency ordinance establishing a temporary moratorium on the
establishment and operation of medical marijuana dispensaries
Prepared by:
-A , #',�
Aaron C. Harp, Assist rh City Attorney
Subry�i y:
Robin Clauson, City Attorney
Attachment: Interim Urgency Ordinance Establishing a Temporary Moratorium on the
Establishment of Medical Marijuana Dispensaries
ORDINANCE NO. 2005-
AN INTERIM URGENCY ORDINANCE OF THE CITY OF
NEWPORT BEACH, CALIFORNIA, MAKING FINDINGS AND
ESTABLISHING A TEMPORARY MORATORIUM ON THE
ESTABLISHMENT AND OPERATION OF MEDICAL MARIJUANA
DISPENSARIES
WHEREAS, Section 200 of the City Charter vests the City Council with the
authority to make and enforce all laws, rules and regulations with respect to
municipal affairs subject only to the restrictions and limitations contained in the
Charter and the Constitution, and the power to exercise, or act pursuant to any
and all rights, powers, and privileges, or procedures granted or prescribed by any
law of the State of California; and
WHEREAS, Government Code Section 65858 provides that for the purpose of
protecting the public safety, health and welfare, the City Council may adopt,
without following the procedures otherwise required prior to the adoption of a
zoning ordinance, as an urgency measure, an interim ordinance, by a vote of
four -fifths (4/5) majority, prohibiting any uses that may be in conflict with a
contemplated general plan, specific plan, or zoning proposal that the legislative
body, planning commission or the planning department is considering or studying
or intends to study within a reasonable time; and
WHEREAS, Section 412 of the City Charter provides for the adoption as an
emergency measure an interim ordinance to preserve the public peace, health or
safety by a vote of at least five (5) City Councilmembers; and
WHEREAS, under the Newport Beach Municipal Code, a question has been
posed regarding what type of application would be required to open a medical
marijuana dispensary and what zone a medical marijuana dispensary could
legally operate.
NOW, THEREFORE, the Newport Beach City Council does hereby ordain as
follows:
SECTION 1: Findings.
A. In 1996, the voters of the State of California approved Proposition 215,
which was codified as Health and Safety Code Section 11362.5, et seq.,
and entitled the Compassionate Use Act of 1996 ( "the Act').
B. The intent of Proposition 215 was to enable persons who are in need of
medical marijuana for medical purposes to obtain and use it under limited,
specified circumstances.
C. On January 1, 2004, SB 420 went into effect. SB 420 was enacted by the
Legislature to clarify the scope of the Act and to allow cities and counties
to adopt and enforce rules and regulations consistent with SB 420 and the
Act.
D. The Newport Beach Municipal Code does not address or regulate in any
manner the existence or location of medical marijuana dispensaries.
E. After receiving inquiries from persons interested in establishing medical
marijuana dispensaries, numerous other cities in the State of California
have adopted ordinances prohibiting or heavily regulating such
dispensaries. Because a significant number of cities, including cities in
the County of Orange, have prohibited or heavily regulated medical
marijuana dispensaries, there is a substantially increased likelihood that
such establishments will seek to locate in the City of Newport Beach in the
near future.
F. Other California cities that have permitted the establishment of medical
marijuana dispensaries have witnessed an increase in crime, such as
burglaries, robberies, and sales of illegal drugs in the areas immediately
surrounding such dispensaries.
G. The United States Supreme Court addressed marijuana use in California
in United States v. Oakland Cannabis Buyers' Cooperative, (2001) 532 US
483. The U.S. Supreme Court held that the federal Controlled Substances
Act continues to prohibit marijuana use, distribution, and possession, and
that no medical necessity exception exists to these prohibitions. Further,
the U.S. Supreme Court is currently reviewing the California case of Raich
v. Ashcroft, (2003) 352 F.3d 1222, and is considering the validity of the
federal Controlled Substances Act and should be rendering its decision
this summer. Therefore, it appears there is currently a conflict between
federal laws and California laws regarding the legality of medical
marijuana dispensaries, which the U.S. Supreme Court should be
resolving in an opinion due this summer.
H. To address the apparent conflict in state and federal laws, as well as the
community and statewide concerns regarding the establishment of
medical marijuana dispensaries, it is necessary for the City to study the
potential impacts such facilities may have on the public health, safety, and
welfare.
Based on the foregoing, the City Council finds that issuing permits,
business licenses, or other applicable entitlements providing for the
establishment and /or operation of medical marijuana dispensaries, prior to
(1) the U.S. Supreme Court resolving the conflict in state and federal laws
on the subject, (2) the City's completion of its study of the legality,
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potential impact, and regulation of such facilities; and (3) resolving any
zoning conflicts based on the fact that no zoning currently exists in the
City for such dispensaries, would pose a current and immediate threat to
the public health, safety, and welfare, and that a temporary moratorium on
the issuance of such permits, licenses, and entitlements is thus
necessary.
SECTION 2: Imposition of Moratorium.
A. In accordance with the authority granted the City of Newport Beach by the
City Charter and Government Code Section 65858, from and after the
date of this ordinance, no use permit, variance, building permit, business
license or other applicable entitlement for use shall be approved or issued
for the establishment or operation of a medical marijuana dispensary for a
period of forty -five (45) days.
B. For purposes of this ordinance, "medical marijuana dispensary" shall
mean any facility or location where a primary caregiver intends to or does
make available, sell, transmit, give, or otherwise provide medical
marijuana to two or more of the following: a qualified patient, a person with
an identification card, or a primary caregiver. For purposes of this
ordinance, the terms "primary caregiver," "qualified patient," and "person
with an identification card" shall have the same meaning as that set forth
in Health and Safety Code Section 11362.5, et seq.
C. This ordinance is an interim urgency ordinance adopted pursuant to the
authority granted to the City of Newport Beach by the City Charter and
Government Code Section 65858, and is for the immediate preservation of
the public health, safety, and welfare. The facts constituting the urgency
are:
(1) California cities that have permitted the establishment of medical
marijuana dispensaries have found that such dispensaries have
resulted in negative and harmful secondary effects, such as an
increase in crime, including robberies, burglaries, and sales of
illegal drugs in the areas immediately surrounding medical
marijuana dispensaries;
(2) After receiving inquiries from persons interested in establishing
medical marijuana dispensaries, numerous other cities in California,
including cities in the County of Orange, have adopted ordinances
prohibiting or heavily regulating such dispensaries, .and because a
significant portion of the region has prohibited or heavily regulated
medical marijuana dispensaries, there is a substantially increased
likelihood that such establishments will seek to locate in the City of
Newport Beach;
Cl
(3) The City of Newport Beach does not currently have standards in its
Municipal Code relating to the location, operation, and
concentration of medical marijuana dispensaries within the City;
(4) Absent the adoption of this interim urgency ordinance, the
establishment and operation of medical marijuana dispensaries in
the City of Newport Beach would result in the negative and harmful
secondary effects other cities have experienced, as identified
above;
(5) Currently the state and federal laws relating to medical marijuana
dispensaries appear to be in conflict, and the United States
Supreme Court is due to render an opinion to clarify and resolve
this apparent conflict this summer; and
(6) As a result of the conflict in state and federal laws on the matter,
coupled with negative and harmful secondary effects associated
with medical marijuana dispensaries, the current and immediate
threat such secondary effects pose to the public health, safety, and
welfare, and the zoning conflicts that would be created by the
establishment and operation of a medical marijuana dispensary, it
is necessary to establish a temporary, forty -five (45) day
moratorium on the establishment and operation of new medical
marijuana dispensaries in the City, pending resolution of the conflict
of laws by the U.S. Supreme Court, completion of the City's study
of the legality, potential impacts and regulation of medical
marijuana dispensaries, and possible amendments to the City's
zoning ordinances.
SECTION 3: Planning Study.
The Planning Department with the assistance of the City Attorney's Office is
directed to analyze the appropriateness of such facilities within the City of
Newport Beach, including but not limited to, evaluating conflicts in state and
federal law, the legality of such facilities, the legal authority to establish such
facilities, the desirability of such facilities, and the extent of regulatory controls,
should such facilities be thought appropriate.
SECTION 4: Amendments to Ordinance.
The City Council by ordinance after notice of public hearing, by the affirmative
vote of at least four -fifths (4/5) of the voting City Council Members may modify,
amend, delete or add to this ordinance upon a finding that such action will
implement and enforce the goals, policies, and purposes of this Ordinance.
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SECTION 5: Compliance with California Environmental Quality Act.
The City Council finds that this ordinance is not subject to the California
Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) (the activity
will not result in a direct or reasonably foreseeable indirect physical change in the
environment) and 15060(c)(3) (the activity is not a project as defined in Section
15378) of the CEQA Guidelines, California Code of Regulations, Title 14,
Chapter 3, because it has no potential for resulting in physical change to the
environment, directly or indirectly; and it prevents changes in the environment
pending the completion of the contemplated municipal code review.
SECTION 6: Waiver.
The City, on a case by case basis, shall have the authority, upon a showing of
good cause by an applicant, to waive the interim prohibition /moratorium imposed
by this ordinance. Good cause shall mean a factual and evidentiary showing by
the applicant that the interim prohibition /moratorium, if not waived, will deprive
the applicant of substantially all reasonable use of his /her property.
SECTION 7: Urgency Ordinances; Extension.
This interim urgency ordinance shall by operation of law be of no further force
and effect forty five (45) days from and after the date of this adoption on May 24,
2005; provided, however, that after notice of public hearing the City Council
Members may by a four - fifths (4/5) of the voting City Councilmembers extend this
interim or urgency ordinance for an initial period of time up to ten (10) months
and fifteen (15) days. Thereafter, after hearing a further one (1) year extension is
also permitted.
SECTION 8: Severability.
The City Council hereby declares that if any section, subsection, sentence,
clause or phrase of this Ordinance is, for any reason, held to be invalid or
unconstitutional such decision shall not affect the validity or constitutionality of
the remaining portions of this Ordinance. The City Council hereby declares that
it would have passed this Ordinance, and each section, subsection, clause or
phrase hereof, irrespective of the fact that any one or more sections,
subsections, sentences, clauses or phrases may be declared invalid or
unconstitutional.
SECTION 9: Effective Date.
This ordinance is hereby declared to be an urgency measure and shall be
enforced and be in effect immediately upon its adoption.
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SECTION 10: Publication.
The Mayor shall sign and the City Clerk shall attest to the passage of this
Ordinance. The City Clerk shall cause the same to be published once in the
official newspaper of the City of Newport Beach within fifteen (15) days of its
adoption.
This Ordinance was introduced and adopted as an urgency measure at a regular
meeting of the City Council of the City of Newport Beach held on the day
of , 2005, and adopted on the day of , 2005,
by the following vote, to -wit:
AYES, COUNCILMEMBERS
NOES,COUNCILMEMBERS
ABSENT, COUNCILMEMBERS
MAYOR
ATTEST:
CITY CLERK
F: \users \cat \shared \Ordinance \Med MariDis pensa ries \05.12.05.doc