In Gonzales v. Raich, the U.S. Supreme Court upheld the federal Controlled Substances Act (CSA) as applied to individuals who grew and used marijuana for medicinal purposes. Specifically, in Raich, two California residents cultivated and consumed marijuana to achieve pain relief that could not be accomplished by conventional medications. They used cannabis pursuant to a state law, the Compassionate Use Act, which legalized the medicinal use of marijuana with a physician's prescription.

The federal government seized and destroyed one of the plaintiff's cannabis plants, claiming it violated the CSA, which classifies marijuana as a Schedule I substance for which there is no legally permissible [Page 326]use. Because federal law is supreme under Article VI of the Constitution, the federal government believed that the CSA preempted California's ...