United States v. Christie

Defendants, husband and wife, were convicted of charges related to their role as ordained ministers in the Hawaii Cannabis Ministry. Defendants admit to using and distributing large quantities of cannabis, but claim that in doing so they were merely exercising their sincerely held religious beliefs. The court agreed that the government has a compelling interest in mitigating the risk that cannabis from the Ministry will be diverted to recreational users, and that the facts of this case demonstrate that mandating defendants' full compliance with the Controlled Substances Act (CSA), 21 U.S.C. 801 et seq., would help to advance this compelling interest to a meaningful degree. Furthermore, the government could not achieve its compelling interest in mitigating diversion through anything less than mandating defendants' full compliance with the CSA. Therefore, defendant's statutory free exercise rights have not been violated and the court rejected their defense under the Religious Freedom Restoration Act of 1993 (RFRA), 42 U.S.C. 2000bb et seq. The court rejected the wife's claim that she should be exempted from prosecution, even if her husband is not, because he was the founder and leader of the Ministry. The court also rejected defendants' claim that RFRA’s intersection with the CSA violates the Fifth Amendment’s prohibition on vague criminal laws. RFRA cannot be unconstitutionally vague because it is not a penal statute or anything like one. Likewise, the rule of lenity is equally untenable. The court further concluded that defendants' contention that their indictments should be dismissed on the theory that the CSA’s classification of marijuana as a Schedule I controlled substance violates the Due Process Clause of the Fifth Amendment is foreclosed by the court's precedent. Finally, the district court did not abuse its discretion in issuing wiretaps obtained in the course of investigating defendants and the Ministry, and the district court did not clearly err in denying defendants a Franks hearing. Accordingly, the court affirmed the judgment. View "United States v. Christie" on Justia Law