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ATTORNEY, LOOMING LARGE

Oklahoma’s leading cannabis legal warrior leads the good fight with some spiritual help. ...
By Elizabeth Mcwilliams
Photo Courtesy - Jeff Hooten
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Sarah Lee Gossett Parrish is remarkably efficient. She is a photographer, an author, a frequent guest on radio shows, and a member of numerous boards. 

But first and foremost, she is a trailblazing attorney with a full-service cannabis law firm, and right now, she has a bone to pick. Specifically, she has taken issue with three regulatory agencies in Oklahoma that govern marijuana businesses, and she’s not afraid to turn over a few suspicious stones.

In February 2024, Sarah Lee took advantage of the Freedom of Information Act and filed requests with three agencies: the Oklahoma Medical Marijuana Authority (OMMA), the Oklahoma Bureau of Narcotics & Dangerous Drugs (OBNDD), and the Oklahoma State Fire Marshal to obtain documents concerning certificates of occupancy (COO) now required to renew existing OMMA licenses and OBNDD registrations. If she were the lawyer for any of these agencies, she says, “I’d be having some heartburn right about now.”

Photo Courtesy – Jeff Hooten

Help from above

A third-generation attorney, Sarah Lee has been practicing law since 1986, but once SQ 788 was passed in 2018 and medical marijuana was legalized in Oklahoma, she pivoted from contract to cannabis law. She became passionate about the medicinal benefits of marijuana after witnessing a close friend lose her battle with leukemia at age 33, well before cannabis was legal. 

Since then, Sarah Lee has learned that marijuana can ease the symptoms of chemotherapy and nausea, assist with pain management, and lessen the effects of migraines, anxiety, and insomnia. 

This natural alternative to medical care feels especially relevant to Sarah Lee in light of the nation’s opioid epidemic, which has hit Oklahoma hard. A majority of voters now recognize that medical marijuana could replace opioids in the treatment of those same conditions that leave many vulnerable to addiction. Sarah Lee believes in the right to access natural remedies, and she is willing to challenge those entities that threaten that right.

Though nothing if not tenacious, Sarah Lee does not walk this path alone. Born into a family of faith, she prays daily and trusts that this practice has enabled much of her success. 

Back in 2018, many other attorneys remained wary about representing cannabis businesses, since marijuana was not yet legal on the federal level. Sarah Lee, however, was one of the first Oklahoma attorneys willing to jump into the fray. Now her law firm has been voted Top Cannabis Business Law Firm in Oklahoma for four straight years. Initially, she wasn’t sure God would sanction her shift in focus, so she prayed for guidance. Her results, she thought, would be her benchmark. 

She started networking with the then-National (now International) Cannabis Bar Association and the National Cannabis Industry Association and quickly received out-of-state referrals. Word got out, and given that she was already a well-established third-generation attorney, she began to receive referrals in Oklahoma. She continued to pray and was blessed with a steady stream of new clients. The growing practice, she trusted, was evidence that God blessed her efforts.

Success followed. In short order, the faithful attorney received numerous awards and national press, including coverage in the San Francisco Chronicle and The New York Times, and recognition as one of the National Law Journal’s 2019 Cannabis Trailblazers and a Global Top 200 Cannabis Attorney. She is also a founding member of the Psychedelic Bar Association and has been named one of the Top 200 Global Psychedelics Attorneys. She believes this level of recognition is “a total God deal” and that she couldn’t have done this alone. 

“I’m so grateful, and I give Him the glory,” she says. “As far as the honors and the awards, there are so many other attorneys equally deserving and hard-working, so when they hit, you just have to be grateful, say ‘thank you God,’ and keep fighting the good fight.” 

As far as the honors and the awards, there are so many other attorneys equally deserving and hard-working, so when they hit, you just have to be grateful, say ‘thank you God,’ and keep fighting the good fight

Photo Courtesy – Jeff Hooten

The Wild West of regulations

Indeed, her “quiet, strong faith in God” has helped Sarah Lee walk through many fires, and today, the flames are leaping again. Things are heating up because many legitimate Oklahoma cannabis-based businesses are suddenly on the firing line. 

“It’s the wild, wild West out here,” she says, and now even more so, referring to the overwhelming difficulty many legitimate businesses face in obtaining their Certificate of Occupancy (COO) from the State Fire Marshal (SFM) under an impossible time frame.

Without a COO, businesses cannot renew their OMMA licenses and OBNDD license registrations, meaning failure to procure a COO within a time period the SFM admits is impossible to meet constitutes sufficient cause for OBN to shut down legally operating businesses for years.  

The regulating agencies keep moving the goalposts, making it challenging and, for many, cost-prohibitive to keep up with changing requirements, especially for growers. This raises the question of why the licensing process has become so stringent.

According to Sarah Lee, the naysayers will point to the illicit market. Rumors swirl about purported “bad actors.” She frequently hears that “the Chinese mob or Russian gangsters are here.”

While Sarah Lee agrees that the illicit market is a legitimate concern that must be addressed and eradicated, she is adamant that the narcotic bureau’s response is disproportionate to any actual threat. If one follows the industry news, the savvy reader will notice that OBN reports relatively few arrests within the illicit market. Yet these agencies are quietly shutting down legitimate growers.

“It’s apparent from this new enforcement of a COO requirement,” she says, “that these agencies are trying to apply regulations unreasonably. They don’t seem to care if you are otherwise fully compliant and have been licensed and operating with the agencies’ approval for years or have been working to obtain a COO for months but unable to do so because the SFM is simply overrun with applications and cannot keep up. They are going after legitimate Moms and Pops who have spent their life savings and reinvested it into their businesses. It is heartbreaking for these businesses.  

 “One could surmise that it is now more difficult to obtain your license registration from OBN than it is to get your commercial business license from OMMA, which is nonsensical since OMMA is the primary regulatory agency,” she says. “Essentially, one could conclude this is a battle between two state agencies for superiority in governing and regulating Oklahoma’s medical marijuana industry. It is playing out to the extreme detriment of law-abiding and legally licensed business owners.” She notes that there are “hard-working public servants at the regulatory agencies who do support the industry,” but “recent agency positions are causing unnecessary and often, cost-prohibitive expenses and stress to licensees, putting many law-abiding companies out of business.”

Another issue for business owners is the confusion regarding who completes the application for the COO: the licensee with a lease on a building or the building owner. 

The Fire Marshal’s office now takes the position that only the landowner can submit the application. In the past, businesses typically had their consultant or contractor apply for the COO rather than the landowner, who often knows little about their tenants’ businesses. 

In Sarah Lee’s estimation, this requirement is unreasonable, especially when landowners sometimes live out of state and are oblivious to their tenants’ business particulars other than the required consent to a medical-pot lessee. “Landowners don’t know about the industry; their tenants do. This requirement that a landowner actually submit the application defies logic and leaves the impression that this is a veiled effort to weed out licensees.” 

Ultimately, Sarah Lee’s passion lies in the viability of her clients, who are good, law-abiding people. “These are folks who run astute operations and reinvest their profits, hire locally, give back to their community, and in so doing, build brand loyalty and fuel Oklahoma’s economy,” she says.

Part of Sarah Lee’s prayer practice includes assigning herself a word with each new year. Her word for 2024, about which she meditates frequently, is WARRIOR, an apt choice for a woman who is willing to step into the fray and pick a bone for a just cause. “I am fighting hard for my clients and our industry,” she says.

I’m working earnestly to keep it afloat and rationally and responsibly regulated. I hope and pray the regulatory agencies and the Oklahoma Legislature will join me in working toward this goal.

 

Photo Courtesy – Jeff Hooten