Today, Chief Counsel Thomas Beveridge of the Cannabis Industry Law Group (“CILG”), a division of Civil Rights Defense Firm, P.C. (“CRDF”), filed a Comment in Opposition to ATF’s proposed changes to the ATF 4473 Form.
ATF’s proposed changes, inter alia, included changing the text of Question 11.e to include a statement that:
Warning: The use of possession of marijuana remains unlawful under Federal law regardless of whether it has been legalized or decriminalized for medicinal or recreational purposes in the state where you reside.
Among other issues raised by CILG, it challenges whether ATF is an inappropriate administrative agency for determining whether an individual is prohibited under 18 U.S.C. 922(g)(3) and that ATF’s own prior implemented regulation, 27 C.F.R. 478.11, acknowledges that the use of physician prescribed controlled substances does not result in a prohibition.
We are excited to see how ATF will respond to these challenges.