California Cannabis Licensing
& DCC Defense
& DCC Defense
We get operators licensed — and defend those licenses when the state takes action.
Government Investigations
California Cannabis Enforcement & DCC Administrative-Action Defense
A single enforcement action can put everything a cannabis operator has built at risk. When the California Department of Cannabis Control (DCC) — or a local regulator such as the Los Angeles Department of Cannabis Regulation (DCR) — opens an investigation, issues a citation, or files an accusation, the deadlines are short and the potential penalties include steep fines, license suspension, and revocation. Baghoomian Law defends licensed cannabis businesses across California at every stage of the administrative enforcement process.
How DCC Enforcement Works: From Notice to Comply to Revocation
California cannabis enforcement generally escalates through predictable stages. Knowing where you are in that process — and acting before the next deadline — is critical:
- Notice to Comply — a written notice identifying minor violations and giving you a chance to correct them. Ignoring it invites escalation.
- Citation and administrative fine — for more serious violations. Fines can reach $5,000 per violation for licensees and up to $30,000 per violation for unlicensed activity, and each day a violation continues can count separately.
- Accusation — the formal charging document that begins a disciplinary case seeking to suspend or revoke a license.
- Administrative hearing before the Office of Administrative Hearings (OAH) — where an administrative law judge hears evidence and issues a proposed decision.
- Final decision — the DCC can impose discipline ranging from fines and probationary terms to outright suspension or revocation.
- Appeal to the Cannabis Control Appeals Panel (CCAP) and, if necessary, judicial review by the California Court of Appeal.
The Deadlines That Matter Most
Missing a deadline can cost you your license by default. Two are especially important: you generally have 15 days from service of an accusation to file a Notice of Defense, and only a short window (generally 30 days) to contest a citation. If you do not respond in time, the DCC can obtain a default decision against you without a hearing. The most important thing you can do after receiving any enforcement notice is to contact a cannabis attorney immediately.
Common Reasons the DCC Takes Action
- Track-and-trace (Metrc) discrepancies and reporting failures
- Operating outside the licensed premises or with an expired or lapsed license
- Video surveillance, security, and record-keeping deficiencies
- Packaging, labeling, and product-testing violations
- Sales to minors or diversion involving the unlicensed market
- Unreported changes in ownership or financial interest holders
- Distribution or sale of adulterated, mislabeled, or recalled products
How We Defend Cannabis Businesses
Our defense is tailored to the stage and facts of your case. We:
- Respond to DCC and local investigations and communicate with regulators on your behalf
- Contest citations and administrative fines, including through the informal conference process
- File a timely Notice of Defense and build a strategic response to accusations
- Scrutinize whether the agency followed proper procedure and can prove each alleged violation
- Represent operators at OAH hearings and in settlement negotiations
- Negotiate stipulated settlements that reduce penalties and keep businesses operating where possible
- Pursue appeals before the Cannabis Control Appeals Panel and judicial review when warranted
Proactive Compliance Audits
The best way to win an enforcement action is to avoid one. We conduct compliance audits that identify vulnerabilities — in track-and-trace, premises, standard operating procedures, and recordkeeping — before regulators do, and we help implement corrective measures that reduce risk. Ongoing compliance support is available through our general counsel services.
Frequently Asked Questions About DCC Enforcement
What is the difference between a citation and an accusation?
A citation is an order to correct a violation and/or pay an administrative fine. An accusation is a formal charging document that begins a disciplinary proceeding to suspend or revoke your license. Accusations are more serious and carry a strict 15-day deadline to file a Notice of Defense.
How much can the DCC fine a cannabis business?
Administrative fines can reach up to $5,000 per violation for licensed businesses and up to $30,000 per violation for unlicensed activity, and each day a violation continues may be treated as a separate violation. Actual amounts depend on the DCC’s disciplinary guidelines and the specific facts.
Can I appeal a license suspension or revocation?
Yes. After a final DCC decision, you can appeal to the Cannabis Control Appeals Panel (CCAP), which reviews whether the DCC acted within its authority and whether the decision is supported by the evidence. Further review is available in the California Court of Appeal.
What should I do if the DCC shows up for an inspection?
Stay calm and cooperative, but know your rights. Do not guess or volunteer conclusions. Note what inspectors request and review, preserve your records, and contact a cannabis attorney as soon as possible — especially if you receive any written notice.
Can a settlement keep my business open?
Often, yes. Many enforcement matters resolve through a stipulated settlement that reduces penalties or imposes probationary conditions rather than revocation. We negotiate settlements aimed at keeping compliant operators in business.
Served with a DCC notice, citation, or accusation? Time matters. Call Baghoomian Law at (818) 514-9272 or contact us online right away.