Administrative Law Judge Mary Ellen Bittner
Drug Enforcement Administration
Office of Administrative Law Judges
Washington, D.C. 20537
Re: Professor Lyle Craker, Ph.D., Docket No. 05-16
Dear Judge Bittner:
I am writing in the matter of Craker v. DEA, Docket No. 05-16, to express our view that it is in the public interest for the DEA to issue research licenses to appropriate researchers and facilities to produce marijuana exclusively for federally-approved research.
The United Methodist Church (UMC) is the second largest Protestant denomination in the United States, with more than eight million members. Our positions on sociopolitical issues are established through resolutions passed by the General Conference, comprised of up to 1,000 delegates half clergy, half lay from throughout the world.
On May 4, 2004, the General Conference passed a resolution with by a vote of 877 to 19, which reads: “Some countries permit the use of marijuana in medicines. Recently, some states in the United States have passed legislation permitting the medical use of marijuana. The medical use of any drug should not be seen as encouraging recreational use of the drug. We urge all persons to abstain from all use of marijuana, unless it has been legally prescribed in a form appropriate for treating a particular medical condition.”
The United Methodist General Board of Church and Society (GBCS), on which I serve as General Secretary, is the international social witness and advocacy agency of the UMC, charged by the denomination to speak its convictions, interpretations and concerns to the Church and to the world.
Shortly after the passage of the resolution by the UMC General Conference affirming that marijuana may be used as a legitimate medicine, the GBCS joined several other denominations in signing a statement of principle on the role of the criminal justice system in this matter: “Licensed medical doctors should not be punished for recommending the medical use of marijuana to seriously ill people, and seriously ill people should not be subject to criminal sanctions for using marijuana if the patient’s physician has told the patient that such use is likely to be beneficial.” This position is grounded in the moral values of justice and compassion.
On several occasions, we have petitioned the U.S. Congress and several state legislatures to stop persecuting medical marijuana patients and providers. We are committed to pursuing all legal channels to end this cruel and counterproductive war on patients. One avenue is the FDA approval process; indeed, this would be the obvious route for obtaining the approval of a medicine, if not for the misguided barriers erected by the federal government. For mercys sake, it is time to tear down these walls.
In particular, the National Institute on Drug Abuse currently maintains a monopoly on the supply of marijuana for research in the United States. This has made it nearly impossible for researchers to obtain the substance to conduct the kind of studies that would lead to natural marijuana being approved by the FDA as a prescription medicine.
Marijuana should not be more difficult to research than any other potentially therapeutic substance, all of which have risks and dangers. Therefore, we urge the DEA to license Prof. Lyle Craker, Director, Medicinal Plant Program, Dept. of Plant and Soil Sciences, UMass Amherst, to establish a privately-funded facility to produce marijuana exclusively for FDA-approved and privately-funded research.