Interesting piece in Cannabis Business Times illustrating that the smaller end of the market suffer in the courts for the smallest of infractions that they obviously can’t afford yet at the other end of the scale companies like Glasshouse (remember all the infractions they could have been called up for post last year’s ICE raid) seem to carry on business as usual.
If the CA govt want a fair and equitable long term cannabis market not run by the equivalent to 4 fast food giants they are going to have to sort out METRC. and similar issues.
Unlikely that will happen though
Cannabis Business Times reports
Aiden Rafii had his cannabis distribution and manufacturing operations come to a screeching halt in April 2025, when California state regulators embargoed 390 pounds of product at his facility outside of San Fransico.
Rafii is the managing owner of Euphoric Life in Hollister, Calif., which has held adult-use and medicinal licenses since 2019, according to the state’s Department of Cannabis Control (DCC). He and his father, Ahmad Rafii, are listed as co-owners on the license. They run a small operation, regularly sourcing product from the Emerald Triangle, with the capacity to store about 1,000 pounds of fresh-frozen flower.
But the Rafiis have been fighting to keep their doors open for the past 17 months, with no clear route to appeal a subsequent product-destruction order from the DCC, despite a nearly passed legislative fix that could have provided such an appeal route for all California businesses facing destruction orders.
This 17-month battle began April 29, 2025, when DCC regulators inspected Euphoric Life’s facility while a new compliance officer was actively photocopying state-mandated unique identification tags to apply to fresh-frozen flower and cannabis concentrate in the company’s freezers, the younger Rafii told Cannabis Business Times. In other words, roughly 390 pounds of Euphoric Life’s product were temporarily untagged.
Depicted here is the DCC’s handwritten description of the Freezer 1 product that regulators placed under embargo during their April 2025 site visit. There were nine freezers containing products without proper tagging, according to the department.
According to a DCC investigative report, Euphoric Life’s head of operations attempted to provide the department’s investigators with documents showing the products were compliantly sourced and logged in Metrc, the state’s track-and-trace provider. Department officials declined to review the paperwork and instead embargoed the products on-site, according to the report.
Euphoric Life submitted a corrective action plan less than two months later, but the DCC rejected the plan 51 days later. Euphoric Life’s lawyer, Nooshin Dalili, sent a letter to the department asking what sourcing documents the company could provide to lift the embargo, but the DCC directed the company to instead submit a product-destruction plan in September 2025 –nearly five months after the site visit.
“Your demand that our client submit a destruction plan by 5 p.m. today, while continuing to ignore our outstanding concerns and evidence, is procedurally improper and inconsistent with BPC §26039.3(c), which expressly permits correction of misbranding or adulteration through labeling or processing,” Dalili wrote in response to the destruction order.
That’s when Euphoric Life’s long-standing legal battle ensued.
Editor’s note: Read more about what happened during the DCC’s inspection visit below under the subhead “How Did This All Start?”
Although a legislative fix appeared to exist for California cannabis businesses to appeal product-destruction orders, Gov. Gavin Newsom’s administration pushed back on a widely backed bill earlier this year over budget concerns (more on this later).
With no fix in sight, Euphoric Life’s series of legal battles with the DCC has led the company to perhaps its last hope: the state’s Sixth Appellate District in San Jose.
Such an appeal directly to a higher court is through what is called a writ of mandate petition only and is therefore discretionary, meaning the court can decide whether or not to take the case. A writ of mandate is a court order that forces a government entity, whether a trial court or an administrative body such as the DCC, to perform a legal duty or take a corrective action.
As the younger Rafii has come to learn, this means California’s state-licensed cannabis businesses have no guaranteed path to challenge a DCC condemnation order before their product is destroyed, creating a major due process problem for all California operators facing destruction of valuable property.
“To me, it’s a completely broken system,” said Rafii, who contends that the 390 pounds of cannabis at his facility were sourced legally and tracked lawfully in Metrc, the state’s seed-and-sale system provider.
The Rafiis declined the directive to destroy the product voluntarily in September 2025, when the DCC gave them fewer than eight hours to comply, and have faced an uphill legal battle ever since.
The Due Process Problem
Without a voluntary destruction plan from Euphoric Life, the DCC initiated condemnation proceedings – a legal effort to force the company to comply – through California’s Office of Administrative Hearings (OAH) in October 2025.
After two hearings in February 2026, Administrative Law Judge Juliet E. Cox ruled in the DCC’s favor and ordered Euphoric Life to destroy the embargoed products and pay nearly $36,000 to reimburse the department for its “reasonable costs incurred” to investigate and prosecute the matter.
The DCC argued in the proceedings that its destruction order was valid because the cannabis was not labeled and packaged according to state law, and therefore misbranded, and that Euphoric Life did not demonstrate the ability to correct the errors, according to the OAH ruling.
Euphoric Life argued that it properly proposed to correct, and can correct, any inadequate labeling and packaging issues. The company provided the court with sourcing documents, arguing it could prove the embargoed products were legally sourced through freezer-by-freezer records, Metrc transfer manifests and package histories (more on this later).
Read more