Key takeaways
DEA has sent orders to show cause to at least some medical cannabis registration applicants in California, Delaware, Illinois, North Dakota, Oregon and Washington, D.C., Marijuana Moment reported Nov. 11.
With Minnesota, that makes at least six states plus D.C. where DEA has moved to deny registrations under medical rescheduling.
The orders target state program design: dual medical and adult-use licenses, and patient access without a practitioner’s signed certification.
An order to show cause isn’t a final denial, and DEA’s supply chain deadline for timely applicants is still Nov. 29, 2026.
The DEA’s pushback on medical cannabis registrations is no longer just a Minnesota problem. The agency has moved to deny applicants in at least six states and Washington, D.C., and its reasons go after how whole state programs work, not just individual businesses.
Marijuana Moment reported Nov. 11 that DEA sent orders to show cause to at least some businesses in California, Delaware, D.C., Illinois, North Dakota and Oregon, based on industry sources and order text shared with the outlet. That adds to the Minnesota order that became public late last month, after the Justice Department announced more than 900 registrations in seven other states.
What the DEA show-cause orders say
The orders differ by state, but Marijuana Moment describes two recurring objections. The first is that some states let businesses sell non-medical marijuana, which DEA says breaks the federal “closed system” and U.S. treaty obligations.
The second is patient access without a practitioner’s signed certification. DEA’s order to a California business says state law lets patients get an ID card with written documentation in their medical records rather than a certification, and the Illinois order flags veterans qualifying with one year of VA medical records. In D.C., the issue is patient self-certification, MJBizDaily reported.
The Illinois order also repeats the Minnesota argument that one license covering both medical and adult-use sales doesn’t protect against diversion. Marijuana Moment didn’t detail the grounds cited in Delaware, North Dakota or Oregon.
The federal rule behind the orders
The standard is in 21 C.F.R. 1301.13(k). DEA must register a state medical licensee unless registration is “inconsistent with the public interest,” weighing federal factors and the Single Convention on Narcotic Drugs.
"In general, registration of an applicant that complies with a state-law regime that contains robust protections against diversion, requirements for record-keeping and reporting, and safety and inspection measures will not be inconsistent with the public interest so long as registration is consistent with the Single Convention."
Under paragraph (k)(5), a state certification works as a prescription only if it’s dated and signed the day it’s issued, names the patient with an address, and lists the practitioner’s name, address and state license number. DEA’s California order cites that paragraph directly, saying the state lets dispensaries serve patients without a written certification.
How many applicants are in the affected states
DEA’s timely applicant list (file dated Nov. 12, 2026) has 5,996 entries. Our count for the jurisdictions named so far is below. Not every applicant in these places has necessarily gotten an order; reports say “at least some” have.
Jurisdiction | Entries on DEA’s Nov. 12 list |
|---|---|
California | 771 |
Illinois | 82 |
Oregon | 37 |
Minnesota | 30 |
Washington, D.C. | 30 |
North Dakota | 11 |
Delaware | 7 |
Total | 968 |
What this means for operators
Compare your state program to the objections so far: dual-use licenses, patient self-certification, and certifications missing a practitioner’s signature or license number.
Prepare for an order before it arrives. In the Minnesota case, the applicant had 30 days to request a hearing, according to Foley Hoag.
Keep working toward Nov. 29. DEA’s guidance expects timely applicants to trade only with other timely applicants and registrants by then, Foley Hoag notes.
Recheck trading partners. If a supplier or buyer gets an order, ask counsel what it means for your own supply chain.
Talk to your state regulator and trade group. Several of these objections can only be fixed by changing state rules, not by one business.
What this means for cannabis workers
Nothing changes at the counter today because of these orders. State law still governs your dispensary, and an order to show cause starts a process rather than ending one.
If you work medical intake or patient verification, expect more attention on how patient paperwork is checked and recorded. Ask your manager whether your employer has gotten an order and how it plans to respond.
The bigger picture
These orders cover only the medical carve-out the Justice Department created in April. A separate proposal to move all marijuana to Schedule III is still before a DEA judge, and it’s unclear when he’ll issue a recommendation, Marijuana Moment reports. MJBizDaily notes DEA hasn’t said how many applicants it has rejected, where or why.
Related on The Weekly Joint: DEA moves to deny a Minnesota dispensary · DEA registers 900+ medical dispensaries · DEA’s 2027 production quotas · Archive
Sources
This article is general information, not legal advice.
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