New Regulations Pose Threat of License Revocation for Missouri Cannabis Enterprises Hosting Events with Violations

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As Missouri marked its inaugural 4/20 celebration subsequent to the state’s legalization of recreational marijuana, a licensed cannabis enterprise situated in Kansas City orchestrated a grand-scale festival. This event granted individuals the unprecedented freedom to openly indulge in cannabis consumption in a large public gathering, with the endorsement of local government regulations.

“It was a pioneering endeavor,” Amy Moore, the state’s cannabis regulation director, affirmed during a legislative committee hearing in May. Although event organizers earnestly endeavored to adhere to state stipulations, the same level of success wasn’t consistently replicated. The Missouri Department of Health and Senior Services regulators faced challenges in holding medical marijuana businesses accountable when their events transgressed established guidelines.

Moore articulated that businesses granted state licenses to cultivate or vend marijuana should assume responsibility for the outcomes of events they host for the public. Thus, with the imminent enactment of new cannabis regulations, authorities will possess the authority to levy fines, suspend operations, or even rescind licenses of marijuana establishments that host events involving illicit activities.

The extent to which an event’s organization and structure contributed to the unfolding circumstances will play a pivotal role in determining the course of action. This discretion was emphasized by Moore as she interacted with legislators in May, clarifying that the penalties outlined in the rules are contingent upon the term “may.”

Notwithstanding, some legislators expressed reservations regarding vesting the department with such powers. Sen. Nick Schroer, a Republican from St. Charles and chairman of the Joint Committee on Administrative Rules, questioned the discrepancy in treatment between the cannabis and alcohol industries during a May 8 committee session.

With Missouri voters’ endorsement of recreational marijuana in November, the state’s regulatory agency had the task of formulating a fresh set of rules to implement the constitutional amendment. Following their introduction in January, these guidelines underwent public review before the ultimate hurdle—the joint committee.

The provision regarding event organization occupies a mere sentence within the comprehensive 127-page compendium of new rules. It stipulates that licensees responsible for organizing events could incur penalties for any violations arising at such gatherings. Despite its brevity, this clause prompted vehement discussions among legislators during the aforementioned meeting.

State Rep. Peter Merideth, a representative from St. Louis, pressed Moore for clarification on the potential extent of the rule’s enforcement. Concerns were raised about the apparent absence of differentiation between violations stemming from negligence and those caused by external factors. Moore stressed that the penalties would be exercised at the discretion of authorities, as the term “may” implies.

Sen. John Rizzo, hailing from Kansas City, sought tangible instances of actions deemed punishable under the new rule. Moore illustrated a scenario wherein medical marijuana business proprietors facilitated on-the-spot physician certifications for patients at a fair. These physicians, however, failed to comply with the law’s mandate to review patients’ medical histories. Moore acknowledged that this example wasn’t singular, emphasizing the need for open dialogue regarding past occurrences and ongoing investigations.

In correspondence with the Independent, department spokesperson Lisa Cox elaborated on the new rule’s implications. She recounted instances where home cultivators set up booths to sell their yields, contravening both regulatory statutes and criminal law. Cox articulated that businesses arranging events featuring facility licensees engaged in rule-violating sales could also be held accountable under the new regulation.


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