January, 2009 only 6,369 new patient applications were received by the CDPHE. In 2009 there was a confluence of three major policy decisions: (1) Attorney General Eric H. Holder Jr. announced an end to raids on distributors of medical marijuana in states where medical marijuana was legal (Johnston, 2009); (2) the Justice Department noted that federal resources should not be focused on prosecuting medical marijuana patients and caregivers who were operating in “clear and unambiguous compliance with existing state law” (Ogden, 2009); and, (3) a Denver District Court ruling determined that a “caregiver” need only dispense marijuana to a registered patient and was not required to provide any additional care, which opened the way for large-scale retail medical marijuana centers (hereafter referred to as dispensaries; Elliott, 2009).
