CRA Adds Former Licensee to Michigan’s Marijuana Industry Exclusion List

December 14, 2023 – On November 14, 2023, the Cannabis Regulatory Agency issued a consent order and stipulation, resolving the formal complaint that had been issued on March 31, 2023, against the medical marijuana provisioning center license PC-000254 of Clark Street Investment Group Inc. dba The Reef, located at 6640 E. 8 Mile Road, Detroit, Michigan 48234.

Clark Street Investment Group Inc. dba The Reef and Anthony Czuchra are permanently prohibited from applying for or otherwise seeking any new marijuana business license in the State of Michigan; exercising managerial control over a such a business; or otherwise meeting the criteria to be deemed an applicant, supplemental applicant, or otherwise subject to a background investigation of any such business.

In addition, Clark Street Investment Group Inc. dba The Reef and Mr. Czuchra are permanently prohibited from obtaining any new ownership interest in a licensed marijuana business in the State of Michigan. Mr. Czuchra is permanently prohibited from being employed or working in any capacity at a licensed marijuana business in the State of Michigan, including but not limited to, performing the functions of a regular or managerial employee, rendering any services as an independent contractor, or rendering any services via another party.

The following lapsed or closed licenses held by Clark Street Investment Group Inc. dba The Reef and Anthony Czuchra, will not be renewed, reinstated, reissued, or reactivated, limited or otherwise, at any future date: PC-000254, GR-C-0001040, GR-C-0001041, GR-C-0001021.

On October 13, 2022, the CRA received a complaint alleging Clark Street Investment Group Inc. dba The Reef was selling marijuana product to individuals without a medical marijuana card. On November 29th, CRA investigators made an unannounced site visit to the provisioning center.

The factual allegations are detailed in the formal complaint and resulted in 14 counts of violated administrative rules in the following categories:

• Licensees may sell or transfer marijuana to a registered qualifying patient or registered primary caregiver only after it has been tested and bears the label required for retail sale.
• Licensees must accurately identify, enter, and track all transactions, current inventory, and other information into the statewide monitoring system as required.
• Licensees must not have marijuana products that are not identified and recorded in the statewide monitoring system, nor without a batch number or identification tag or label.
• Marijuana product that is to be destroyed or is considered waste must be rendered into an unusable and unrecognizable form.
• Licensees must securely lock the marijuana business.
• Licensees must ensure the video surveillance system records any areas where marijuana products are weighed, packed, stored, loaded, and unloaded for transportation, prepared, or moved within the marijuana business.
• Marijuana products sold or transferred must be clearly labeled with the tracking identification numbers assigned by the statewide monitoring system affixed, tagged, or labeled and recorded, and any other information required. Before a marijuana product is sold or transferred, the container, bag, or product holding the marijuana product must be sealed and labeled with all of the required information.
• Licensees may not advertise a marijuana product in a way that is deceptive, false, or misleading, or make any deceptive, false, or misleading assertions or statements on any marijuana product, sign, or document provided.
• Licensees must ensure that employees handle marijuana product in compliance with Current Good Manufacturing Practice, Hazard Analysis, and Risk Based Preventative Controls for Human Food, 21 CFR part 1107.
• Consumption of food and beverages by employees or visitors is prohibited where marijuana product is stored, processed, or packaged or where hazardous materials are used, handled, or stored.

Clark Street Investment Group Inc. dba The Reef and Anthony Czuchra have been added to Michigan’s marijuana industry exclusion lists, which are available online and include individuals excluded from participating in the licensed marijuana industry in Michigan.

Licensees must screen prospective employees, supplemental applicants, and owners against the exclusion list as they are prohibited from employing excluded individuals or allowing them to be supplemental applicants on a license.

MCL Admin

The Michigan Cannabis Lawyer Admin is the profile for the cannabis attorneys here at Covert Law Firm.