Georgia Atlas, Inc. v. Executive Director of the Georgia Access to Medical Cannabis Commission

Court of Appeals for the Eleventh Circuit·Decided September 2, 2026·No. 22-11046·Unpublished

Opinion

NOT FOR PUBLICATION

In the

United States Court of Appeals For the Eleventh Circuit

No. 22-11046

GEORGIA ATLAS, INC., ATLAS ILLINOIS, INC., Plaintiffs-Appellants,

versus

EXECUTIVE DIRECTOR OF THE GEORGIA ACCESS TO MEDICAL CANNABIS COMMISSION, COMMISSIONER OF THE GEORGIA ACCESS TO MEDICAL CANNABIS COMMISSION, Defendants-Appellees.

Appeal from the United States District Court for the Northern District of Georgia D.C. Docket No. 1:21-cv-03520-SDG

USCA11 Case: 22-11046 Document: 41-1 Date Filed: 09/02/2026 Page: 2 of 19

2 Opinion of the Court 22-11046

Before ROSENBAUM, LAGOA, Circuit Judges, and SINGHAL,* District Judge. PER CURIAM:

Georgia Atlas, Inc., and Atlas Illinois, Inc. (collectively, “Atlas ”), appeal the dismissal of their amended complaint for lack of Article III standing. Georgia Atlas applied for a license to cultivate and sell marijuana for medical uses permitted under Georgia law. But the Georgia Access to Medical Cannabis Commission (the “Commission”) denied its application. Atlas then sued the Commissioner and the Executive Director of the Commission, alleging violations of the Due Process Clause of the Fourteenth Amendment and the Equal Protection Clause, among other provisions. The district court subsequently dismissed Atlas’s claims.

After careful review, and with the benefit of oral argument, we conclude that the district court erred in dismissing Counts I and II for lack of Article III standing. Whether federal law ultimately defeats Atlas’s asserted constitutional interests goes to the merits of those claims, not to Atlas’s standing to pursue them. Atlas nevertheless lacks standing to pursue Count V because the relief sought under the Supremacy Clause would not redress the injuries it alleges . Accordingly, we affirm the dismissal of Count V, vacate the dismissal of Counts I and II, and remand for further proceedings.

* Honorable Raag Singhal, United States District Judge for the Southern Dis-

trict of Florida, sitting by designation.

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22-11046 Opinion of the Court 3

I. FACTUAL AND PROCEDURAL BACKGROUND1 In 2019, the Georgia General Assembly passed, and Governor Kemp signed, Georgia’s Hope Act, which established the Commission . See O.C.G.A. §§ 16-12-200 to -236. The Commission has seven members. Its purpose is to oversee the licensing of in-state cultivation, production, and sale of low THC oil to registered patients on the state’s low THC oil registry.

In pursuit of a license from the Commission, Atlas allegedly expended “significant” “time, effort, and money” in reliance on “the stated purpose and goals of the Hope Act.” But according to Atlas, the implementation of the Hope Act was hampered by “misconduct ,” including corruption, incompetence, and a lack of transparency . In its amended complaint, Atlas alleged five claims for relief (three of which are relevant to this appeal). 2 Specifically, Atlas alleged claims under the Due Process Clause of the Fourteenth Amendment (“Count I”), the Equal Protection and Commerce Clauses (“Count II”), and the Supremacy Clause (“Count V”).

As to Count I, Atlas alleged that the Defendants wrongfully denied Georgia Atlas’s applications by failing to properly

1 At the motion-to-dismiss stage, we accept the well-pleaded factual allegations

in Atlas’s amended complaint as true and construe all reasonable inferences therefrom in the light most favorable to Atlas. See Renfroe v. Nationstar Mortg., LLC, 822 F.3d 1241, 1243 (11th Cir. 2016). 2 Because Atlas expressly abandoned Counts III and IV of its amended com-

plaint, which raised claims under the Georgia Administrative Procedure Act and the Georgia Purchasing Act, we do not address them on appeal.

4 Opinion of the Court 22-11046

implement the Hope Act. Atlas alleged that the Defendants’ “wrongful actions” included: “(i) the failure to establish, publish, and employ standardized evaluation criteria for the applications, (ii) the failure to employ blind grading, (iii) the failure to preserve the transparency of the license awarding process, and (iv) the appearance of impropriety due to certain inconsistencies in scoring applications.”

Count II alleged that the Defendants “intentionally draft[ed]

and implement[ed] the Hope Act in a manner which discriminated against certain groups.” For example, the Defendants allegedly discriminated by giving greater weight to companies that were not bona fide domestic corporations and by not awarding licenses to minority-owned businesses. Atlas complained that it “had to essentially divide itself and its resources, as well as, recruit new owners and managers from Georgia, to apply for a license in Georgia due to the Hope Act’s residency requirement.” Atlas also incorporated “significant minority participation in its ownership and management .” And Atlas complained that the Defendants discriminated against it by awarding licenses to applicants who allegedly “possessed improper relationships” with the Defendants.

Count V alleged that the Hope Act is preempted by federal law. Specifically, the Controlled Substances Act (“CSA”) forbids the cultivation and sale of marijuana for any purpose.

For Counts I, II, and V, Atlas sought equitable relief, including a declaration that the Hope Act was unconstitutional and an injunction against the Commission’s policies and alleged practices.

22-11046 Opinion of the Court 5

Alternatively, Atlas requested an injunction against the enforcement of the Hope Act in its entirety.

Defendants moved to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). The district court agreed, dismissing all claims for lack of Article III standing. It separately dismissed Counts III and IV for failure to state a claim, but did not address whether Counts I, II, or V likewise failed under Rule 12(b)(6). Atlas appealed.

II. STANDARD OF REVIEW A dismissal for lack of standing has the same effect as a dismissal for lack of subject-matter jurisdiction under Rule 12(b)(1). Stalley ex rel. United States v. Orlando Reg’l Healthcare Sys., Inc., 524 F.3d 1229, 1232 (11th Cir. 2008). We review questions concerning subject-matter jurisdiction, including standing, de novo. Elend v. Basham, 471 F.3d 1199, 1204 (11th Cir. 2006).

III. ANALYSIS

This appeal concerns standing, not the ultimate merits of Atlas ’s claims. “Standing is a threshold jurisdictional question which must be addressed prior to and independent of the merits of a party’s claims.” Common Cause/Ga. v. Billups, 554 F.3d 1340, 1349 (11th Cir. 2009) (quoting Bochese v. Town of Ponce Inlet, 405 F.3d 964, 974 (11th Cir. 2005)).

To establish Article III standing, a plaintiff “must have (1) suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be

6 Opinion of the Court 22-11046

redressed by a favorable judicial decision.” Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016) (citing Lujan v. Defs. of Wildlife, 504 U.S. 555, 560 (1992)). The plaintiff bears the burden of establishing each element and, at the pleading stage, must “clearly . . . allege facts demonstrating” them. Id. (quoting Warth v. Seldin, 422 U.S. 490, 518 (1975)); accord Billups, 554 F.3d at 1349.

The district court treated a potential defect in the merits of Counts I and II as a defect in Article III standing. That was error.

A. Counts I and II

The district court concluded that Atlas could not establish injury in fact and, relatedly, redressability as to Counts I and II. Relying on the Supreme Court’s decision in Raich, the district court explained that Atlas had no legally protected interest in growing or selling marijuana (or a state-created license to do so) because marijuana is designated as contraband for any purpose under federal law. See Gonzales v. Raich, 545 U.S. 1, 27 (2005). Defendants press the same argument on appeal.

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