NH Hemp Council v. Constantine, DEA

CourtDistrict Court, D. New Hampshire
DecidedOctober 11, 1998
DocketCV-98-280-JD
StatusPublished

This text of NH Hemp Council v. Constantine, DEA (NH Hemp Council v. Constantine, DEA) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
NH Hemp Council v. Constantine, DEA, (D.N.H. 1998).

Opinion

NH Hemp Council v. Constantine, DEA CV-98-280-JD 10/11/98 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

New Hampshire Hemp Council, Inc., et al.

v. Civil No. 98-280-JD

Thomas A. Constantine, Admin., Drug Enforcement Administration

O R D E R

The plaintiffs, Derek Owen and the New Hampshire Hemp

Council, brought this action against the defendant, Thomas

Constantine, the Administrator of the United States Drug

Enforcement Agency ("DEA"), pursuant to the Administrative

Procedure Act, 5 U.S.C.A. § 702 and § 703, asserting that the

defendant exceeded its statutory authority under the

Comprehensive Drug Abuse Prevention and Control Act and

unlawfully violated their constitutional rights. Before the

court now is the plaintiffs' objection to the Report and

Recommendation of Magistrate Judge James R. Muirhead which

recommended that the plaintiffs' motion for a temporary

restraining order and preliminary injunction be denied and the

case be dismissed for lack of standing (document no. 15). Background1

Plaintiff Owen is an established New Hampshire agricultural

producer who currently grows a wide range of commodities. The

New Hampshire Hemp Council is a non-profit corporation. Owen, in

cooperation with the New Hampshire Hemp Council, seeks to grow

hemp on his farm as an agricultural commodity and to demonstrate

hemp's value in contributing to improved soil productivity and

sustainable local agriculture.

Owen is also a New Hampshire State Representative. In the

1998 New Hampshire legislative session, Owen co-sponsored a bill

entitled "An act permitting the development of an industrial hemp

industry in New Hampshire and continually appropriating a special

fund." See Compl. at 7. The bill would have established a state

system for licensing and inspecting hemp growing operations.

Although the bill was recommended for passage in the legislature

by the Committee on Environment and Agriculture of the New

Hampshire House of Representatives, the full House of

Representatives defeated the bill with a 175-164 vote.

On February 3, 1998, during consideration of the bill, DEA

Special Agent George Festa testified before the Committee that

1The facts related herein represent the findings of the court for the purposes of the temporary restraining order and preliminary injunction.

2 the DEA's interpretation of federal law did not recognize a

distinction between hemp and marihuana and criminalized both of

them. Therefore, the proposed state legislation would conflict

with federal legislation, and the DEA would treat industrial hemp

cultivation as a federal offense. These statements were

allegedly a cause of the bill's failure in the New Hampshire

House of Representatives.

The plaintiffs assert that the DEA has exceeded its

statutory authority in declaring hemp manufacture and distribu­

tion illegal and in threatening prosecution for engaging in such

activities under the Comprehensive Drug Abuse Prevention and

Control Act. See 21 U.S.C.A. § 801 - § 966 (West 1981) ("1970

Act"). They argue that these actions violated their Fifth

Amendment rights and that the DEA agent's testimony before the

Committee violated their First Amendment rights. Ultimately the

plaintiffs seek, inter alia, a permanent injunction prohibiting

the DEA from prosecuting them for hemp cultivation, and a

declaration of hemp's legality.

On May 2, 1998, the plaintiffs filed a motion for a

temporary restraining order and preliminary injunction, which was

opposed by the defendant. The motion was referred to Magistrate

Judge James R. Muirhead pursuant to 28 U.S.C.A. § 636(b)(1)(B).

A hearing before the Magistrate followed and his report and

3 recommendation was issued on June 9, 1998. The magistrate

recommended dismissal of the plaintiffs' action, finding that the

plaintiffs lacked standing. The magistrate reasoned that because

the plaintiffs could not grow hemp legally in New Hampshire under

state law, the defendant's allegedly erroneous interpretation of

federal law and unlawful threat of prosecution caused no injury

to the plaintiffs.

In the event the plaintiffs were found to have standing, the

magistrate also considered the merits of the plaintiffs' motion

for a temporary restraining order and preliminary injunction. In

evaluating the four factors that a court must weigh in

considering a preliminary injunction, that is, the likelihood of

success on the merits, the potential for irreparable harm, the

balance of eguities, and the public interest, the Magistrate

found the plaintiffs' motion should not be granted. First, the

plaintiffs were unlikely to succeed on the merits of the claim as

Congress had spoken clearly on the issue and intended to

criminalize hemp. Second, because the plaintiffs do not grow

hemp, nor have they ever grown hemp, and because New Hampshire

law criminalizes hemp independently of federal law, the status

guo was not likely to be changed by the defendant's actions and

there was no risk of irreparable harm. Finally, the magistrate

determined that while the public interest favored no party

4 clearly, equity favored the defendant since distinguishing

between immature hemp and marihuana plants is difficult and the

DEA's efforts to enforce the nation's drug laws would be

frustrated. The plaintiffs filed their objections to the

magistrate's report on June 19, 1998.

Discussion

After a party makes a timely written objection to a

magistrate's report, the district court must review the matter de

novo. See Northinqton v. Marin, 102 F.3d 1564, 1570 (10th Cir.

1996). "The district court must consider the actual testimony or

other evidence in the record and not merely review the

magistrate's report and recommendation." Id.

As discussed above, Owen, in cooperation with the Hemp

Council, intends to cultivate hemp for industrial purposes and

thereby demonstrate its usefulness as a valuable rotational crop.

The plaintiffs therefore seek an injunction prohibiting the DEA

from prosecuting persons manufacturing and distributing hemp, as

well as a declaratory judgment, in furtherance of their intention

to grow hemp, finding hemp cultivation legal and requiring

prosecutors to establish in criminal cases, when appropriate,

that the substance at issue is marihuana and not hemp.

In support of their action, the plaintiffs assert that

5 Congress only sought to criminalize, inter alia, the manufacture

and possession of psychoactive Cannabis sativa L., which the

plaintiffs refer to as marihuana, as opposed to the allegedly

non-psychoactive Cannabis sativa L., which they refer to as hemp.

The plaintiffs argue that the defendant's interpretation of the

statute as proscribing the cultivation and possession of hemp is

in error. Conseguently, the defendant's actions declaring hemp

cultivation illegal and threatening prosecution for such

cultivation are allegedly beyond its statutory authorization and

unlawful. The defendant responded, in part, that the plaintiffs

lack standing to bring this action and challenged the injury that

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