Cannabis Blog

When a DCC Embargo Can Become the Practical Equivalent of Destruction
Baghoomian Law

By Steve S. Baghoomian, Esq. A cannabis embargo can be tantamount to destruction when it prevents the steps needed to keep a living crop viable. The Department of Cannabis Control does not have to send someone to cut down the plants for the loss to become permanent. If mature plants deteriorate while a licensee waits…

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How to Appeal a Los Angeles DCR Notice of Violation or Revocation
Baghoomian Law

Receiving an enforcement notice from the Los Angeles Department of Cannabis Regulation (DCR) is not the same thing as losing an appeal. But the type of notice matters enormously: a Notice of Violation, administrative hold, suspension, and revocation do not all use the same deadline or allow the same operations while a hearing is pending.…

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DCC METRC Discrepancies and Cannabis Embargoes: Can Inventory Be Saved?
Baghoomian Law

A mismatch between physical cannabis inventory and California’s track-and-trace records can lead to an investigation, a notice to comply, or an embargo. But a discrepancy is not a diagnosis. The key questions are what the records actually show, whether the products have a lawful source, and whether the problem can be documented and corrected under…

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Can Los Angeles DCR Revoke a Cannabis License for One Violation?
Baghoomian Law

A single incident can create serious licensing exposure for a Los Angeles cannabis business, but the Department of Cannabis Regulation (DCR) cannot skip the rules that govern a proposed revocation. The relevant ordinance requires consideration of several factors before issuing a Notice of Revocation. Those factors give licensees a framework for disputing the agency’s factual…

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DCC Emergency Decision and Order: How to Challenge a Cannabis License Suspension
Baghoomian Law

A California Department of Cannabis Control (DCC) Emergency Decision and Order, often called an EDO, is a form of temporary enforcement designed to address immediate danger. It can also shut down a licensed cannabis business before the ordinary disciplinary process has run its course. For an affected licensee, the first questions are what the agency…

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Can the California DCC Destroy Cannabis Without a Hearing?
Baghoomian Law

An embargo can stop a cannabis business from selling or moving inventory, but an embargo does not automatically mean the California Department of Cannabis Control (DCC) has ordered lawful destruction. The distinction can determine whether a licensee has an opportunity to correct a problem, protect valuable property, or contest condemnation. What does a DCC embargo…

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Buying or Selling a Cannabis Business in Los Angeles: The DCR Change of Ownership Rules and Forms
Baghoomian Law

Short answer: In the City of Los Angeles, you cannot buy or sell a licensed cannabis business by signing a purchase agreement. Every change to a licensed entity’s ownership structure requires prior written approval from the Los Angeles Department of Cannabis Regulation (DCR). The core filing is LIC-4004-MOD (Application Modification Request – Ownership Structure), submitted…

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