California Attorney General Opinion 25-102

TO BE PUBLISHED IN THE OFFICIAL REPORTS

OFFICE OF THE ATTORNEY GENERAL

State of California

ROB BONTA

Attorney General

_______________

:

OPINION :

: No. 25-102

of :

: May 28, 2026

ROB BONTA :

Attorney General :

:

HEATHER THOMAS :

Deputy Attorney General :

The HONORABLE ANAMARIE ÁVILA FARÍAS, MEMBER OF THE STATE

ASSEMBLY, has requested an opinion regarding the licensing requirements for a

federally recognized tribe to participate in California’s commercial cannabis industry.

QUESTION PRESENTED AND CONCLUSION

May a federally recognized Indian tribe located exclusively within the exterior

boundaries of the State of California conduct intrastate commercial cannabis activity with

state licensees off tribal lands without obtaining a commercial cannabis license from the

California Department of Cannabis Control, if the tribe has adopted laws substantially

comparable to California’s cannabis regulatory framework?

No. With limited exceptions, California law requires every entity that engages in

intrastate commercial cannabis activity with California licensees to hold a license issued

by the Department of Cannabis Control. To engage in such activity off tribal lands, a

tribe must hold a California commercial cannabis license.

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BACKGROUND

The jurisdictional relationship between tribes and state and federal government is

“of a complex character.” 1 The U.S. Supreme Court “has consistently recognized that

Indian tribes retain ‘attributes of sovereignty over both their members and their

territory.’” 2 “[T]ribal sovereignty is dependent on, and subordinate to, only the Federal

Government, not the States.” 3 But “state laws may be applied to tribal Indians on their

reservations if Congress has expressly so provided.” 4 Off tribal lands, states have greater

authority over tribal activities, as discussed in more detail below. 5 In either

circumstance, tribes retain sovereign immunity against suit “absent a clear waiver by the

tribe or congressional abrogation.” 6

California has been at the forefront of legalizing cannabis at the state level. It

became the first state to legalize cannabis for medicinal use when voters passed

Proposition 215 in 1996. 7 In 2016, voters approved Proposition 64, which legalized

recreational cannabis use for adults 21 and older within specified limits. 8 Shortly

thereafter, in 2017, the Legislature consolidated Proposition 64 with the earlier legislation

governing medicinal use to create a single commercial cannabis framework: the

Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA). 9 Relevant

here, MAUCRSA generally requires any entity engaged in commercial cannabis

activities within California to obtain a state license. 10 Under regulations implementing

1

United States v. Kagama (1886) 118 U.S. 375, 381.

2

California v. Cabazon Band of Mission Indians (1987) 480 U.S. 202, 207 (Cabazon).

3

Washington v. Confederated Tribes of Colville Indian Reservation (1980) 447 U.S. 134,

154.

4

Cabazon, supra, 480 U.S. at p. 207.

5

21 Cal.Jur.3d (2026) Indians, § 21.

6

Okla. Tax Com. v. Citizen Band Potawatomi Indian Tribe of Okla. (1991) 498 U.S. 505,

509.

7

Cal. Dept. of Cannabis Control, California’s Cannabis Laws,

https://cannabis.ca.gov/cannabis-laws/laws-and-regulations/ (as of May 28, 2026); Health

& Saf. Code, § 11362.5; 106 Ops.Cal.Atty.Gen. 119 (2023); Ryan B. Stoa, Tribal

Cannabis Agriculture Law (2023) 2023 Utah L.Rev. 1075, 1077.

8

See, e.g., Health & Saf. Code, §§ 11018, 11357, 11358, 11359, 11360, 11362.1,

11362.2, 11362.3, 11362.4; see also California Courts, Proposition 64: The Adult Use of

Marijuana Act, https://www.courts.ca.gov/prop64.htm (as of May 28, 2026).

9

Bus. & Prof. Code, § 26000 et seq.; Ofc. Of Sen. Floor Analyses, Unfinished Business

Analysis of Sen. Bill No. 94 (2017-2018 Reg. Sess.) as amended June 9, 2017, p. 1.

10

Bus. & Prof. Code, § 26037.5, subd. (a).

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MAUCRSA, a tribe applying for a commercial cannabis license must submit a written

waiver of any sovereign immunity defense it may have or assert in any state

administrative or judicial enforcement action brought against the tribe under state law and

regulations governing commercial cannabis activity. 11

ANALYSIS

The question here is whether a federally recognized Indian tribe may lawfully

conduct commercial cannabis activity with California licensees off tribal lands within the

state, if the tribe has adopted laws that impose requirements substantially comparable to

the California cannabis regulatory framework. 12 We conclude that, to engage in such

activities off tribal lands, a tribe must obtain a commercial cannabis license issued by the

Department of Cannabis Control. California law generally requires any entity engaged in

commercial cannabis activities to obtain a state-issued license. And the state has the

authority to apply its generally applicable cannabis licensing requirements to tribal

activities off tribal lands.

Under California law, a tribe must obtain a state commercial cannabis license to

engage in commercial activity with other licensed entities

Legal cannabis activities in California fall into three overlapping categories: adult

personal use, personal medicinal use, and commercial activity. First, adult personal use

is legalized within certain, narrow limits. People age 21 and older can possess, process,

transport, purchase, obtain, or give away to other adults age 21 and older up to 28.5

grams of nonconcentrated cannabis or eight grams of concentrated cannabis, as well as

grow six living plants. 13 Second, individuals with a physician’s recommendation or

approval can use and cultivate cannabis for personal medicinal purposes. 14 Physicians

can recommend an amount of cannabis consistent with the patient’s needs, and patients

and caregivers are not subject to criminal prosecution or other penalty for medicinal

cannabis activity consistent with California law. 15

Third, a person or entity engages in commercial cannabis activity if they cultivate,

possess, manufacture, distribute, process, store, laboratory test, package, label, transport,

11

Cal. Code Regs., tit. 4, § 15009, subd. (a).

12

This opinion does not address the application of state law to cannabis activities on

tribal lands. We note that the Department of Justice is currently litigating related

questions.

13

Health & Saf. Code, §§ 11362.1, 11362.2.

14

Health & Saf. Code, § 11362.5, subds. (b)(1)(A), (d).

15

Health & Saf. Code, §§ 11362.77, 11362.765; People v. Kelly (2010) 47 Cal.4th 1008.

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deliver, or sell cannabis or cannabis products. 16 Because the definition includes cannabis

activities such as possession and cultivation, it describes activities that may also fall

under the personal adult or personal medicinal use provisions broadly described above.

These activities may be conducted without a license pursuant to those regimes. 17

Because personal adult and personal medicinal activities are not the subject of this

request, we do not discuss them here.

Instead, this opinion addresses commercial cannabis activities such as large-scale

cannabis cultivation, laboratory testing, storage, or distribution. To engage in these

activities, an entity must obtain and maintain a license from the California Department of

Cannabis Control and comply with MAUCRSA. 18 That Act “establish[es] a

comprehensive system to control and regulate” commercial cannabis activity concerning

both medicinal and adult use. 19 All commercial activity must be conducted between

licensees, subject to exceptions not relevant here. 20 Licensees must operate within the

scope of their license, and they may conduct commercial cannabis activities only “on the

premises licensed for the activity.” 21

Otherwise, cannabis remains a controlled substance under state law. 22 Those who

engage in commercial cannabis activity without a license, or who aid and abet such

16

Bus. & Prof. Code, § 26001, subd. (q); 37 Cal.Jur.3d (2026) Health & Sanitation, § 28;

but see Bus. & Prof. Code, § 26033, subd. (a). Commercial cannabis activity also

includes “acting as a cannabis event organizer for temporary cannabis events.” (Bus. &

Prof. Code, § 26001, subd. (q).)

17

Health & Saf. Code, § 11362.1; Bus. & Prof. Code, §§ 26033, 26037.5.

18

Bus. & Prof. Code, §§ 26037.5, subd. (a), 26030, subd. (a), 26000, subds. (b), (c),

26001, subds. (ah), (ai), (ao); Cal. Code Regs., tit. 4, § 15000.1, subd. (a).

19

Bus. & Prof. Code, § 26000, subd. (b); see generally Bus. & Prof. Code, § 26000 et

seq.; Cal. Code Regs., tit. 4, § 15000 et seq.

20

For example, a licensed retailer and a licensed microbusiness may sell cannabis to

customers or nonprofits. (Cal. Code regs., tit. 4, §§ 15000.1, subd. (b), 15404, 15409.)

MAUCRSA also exempts other entities from licensing requirements, including qualified

patients, primary caregivers, and those who cultivate cannabis consistent with provisions

governing personal adult recreational use, as well as certain nonprofits who obtain

temporary local licenses to provide cannabis to low-income persons. (Bus. & Prof. Code,

§§ 26033, 26037.5, subd. (b), 26070.5, subd. (b).)

21

Bus. & Prof. Code, § 26053, subd. (a); Cal. Code Regs., tit. 4, § 15000.1, subds. (b),

(c).

22

Health & Saf. Code, §§ 11007, 11054, subd. (d)(13).

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unlicensed activities, can face civil and criminal penalties. 23 State law continues to

prohibit activities such as possession for sale; planting, harvesting, or processing; and

unlawful transportation, importation, sale, or gift of cannabis outside the framework

described above. 24

Turning to the question before us, our requestor has asked whether a tribe may

conduct commercial cannabis activity with California licensees off tribal lands without

obtaining a state-issued license, if the tribe has adopted laws substantially comparable to

California’s cannabis regulatory framework. Under current law, it cannot. As discussed,

cannabis is a controlled substance, and cannabis activity remains illegal outside of the

framework described above. That framework generally requires all commercial cannabis

activity to occur only between California licensees. 25 And a licensee who operates

contrary to the law may face civil or criminal penalties. 26 In short, state law does not

allow a California cannabis licensee to lawfully conduct commercial cannabis activity

with an entity who holds a commercial cannabis license issued by a tribal authority

instead of the state.

Finally, state law expressly contemplates tribal participation in the commercial

cannabis market as California licensees. Department of Cannabis Control regulations

specifically reference federally recognized tribes, requiring them to waive any relevant

sovereign immunity defense to obtain a commercial cannabis license. 27 The inclusion of

tribes in the state’s commercial cannabis licensing regulations as licensees reinforces our

23

Bus. & Prof. Code, §§ 26030, 26038, subds. (a), (e); see generally Bus. & Prof. Code,

§§ 26030-26039.6.

24

Health & Saf. Code, §§ 11359, 11358, 11360. Cannabis remains a controlled

substance under federal law. (Federal Controlled Substances Act, 21 U.S.C. § 801 et

seq.) While analysis of any potential application of federal law to tribal cannabis activity

is beyond the scope of this opinion, we note that California courts have held that the

federal Controlled Substances Act does not preempt California’s cannabis laws. (See

Qualified Patients Assn. v. City of Anaheim (2010) 187 Cal.App.4th 734; Kirby v. Cnty.

of Fresno (2015) 242 Cal.App.4th 940; City of Garden Grove v. Superior Ct. (2007) 157

Cal.App.4th 355.)

25

Bus. & Prof. Code, § 26037.5 (“A person or entity shall not engage in commercial

cannabis activity without a state license issued by the department pursuant to this

division”); Cal. Code Regs., tit. 4, § 15000.1, subd. (b) (“Commercial cannabis activity

shall only be conducted between licensees”). As described above, the law contains

exceptions to the license requirement that are not relevant here. (See ante, fn. 20.)

26

Bus. & Prof. Code, §§ 26030, 26038, subd. (e); see generally Bus. & Prof. Code,

§§ 26030-26039.6.

27

Cal. Code Regs., tit. 4, § 15009, subd. (a).

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conclusion that tribes without a state license may not engage in commercial cannabis

activities. 28

California has the authority to require Department of Cannabis Control licensees to

conduct commercial cannabis activities occurring off tribal lands only with state-

licensed entities.

We next consider whether applying state licensing laws to a tribe’s commercial

cannabis activities conducted off tribal lands is consistent with limits on state authority

concerning tribal activities. We conclude that it is.

As noted above, tribes have a complex jurisdictional relationship with states and

the federal government. Tribes have the inherent power to preserve their own self-

government, and they have powers granted or reserved to them by Congress. 29 The

existence and degree of a state’s authority regarding tribal activities can be a complex

question, particularly if the activity at issue occurs on tribal land. 30

Off tribal land, however, “state power over Indian affairs is considerably more

expansive.” 31 When a tribe “travels beyond its reservation borders for the purpose of

carrying on a business enterprise,” it “does not have expansive immunity from ordinary

28

See generally In re J.W. (2002) 29 Cal.4th 200, 209 (under expressio unius principle,

“the expression of one thing in a statute ordinarily implies the exclusion of other things”).

29

Montana v. United States (1981) 450 U.S. 544, 563-564 (“Thus, in addition to the

power to punish tribal offenders, the Indian tribes retain their inherent power to determine

tribal membership, to regulate domestic relations among members, and to prescribe rules

of inheritance for members. . . . But exercise of tribal power beyond what is necessary to

protect tribal self-government or to control internal relations . . . cannot survive without

express congressional delegation”); see also Mescalero Apache Tribe v. Jones (1973) 411

U.S. 145, 148 (Mescalero); Rice v. Rehner (1983) 463 U.S. 713, 718.

30

American Indian Law Deskbook, ch. 5, General Civil Regulatory Jurisdiction,

Introduction (“Among the most difficult and recurring issues in Indian law is the scope of

federal, tribal, and state civil regulatory authority in Indian country. . . . [E]ven today

there remain significant differences within the [Supreme] Court both as to governing

principles and how accepted principles should be applied”); see also White Mountain

Apache Tribe v. Bracker (1980) 448 U.S. 136, 151 (Bracker) (“[T]hough the reservation

boundary is not absolute, it remains an important factor to weigh in determining whether

state authority has exceeded the permissible limits”).

31

Washington v. Confederated Tribes of Colville Indian Reservation, supra, 447 U.S. at

p. 162.

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regulation that applies to businesses throughout the State.” 32 Instead, as the U.S.

Supreme Court held in Mescalero Apache Tribe v. Jones, tribal members “going beyond

reservation boundaries have generally been held subject to non-discriminatory state law

otherwise applicable to all citizens of the State,” “[a]bsent express federal law to the

contrary.” 33 Applying that rule, the Court in Mescalero upheld a state’s taxation of a ski

resort operated by a tribe off tribal lands. 34 The Ninth Circuit has similarly upheld state

laws taxing and regulating tribal cigarette sales off tribal lands. 35

Here, our focus is likewise on commercial activities occurring off tribal lands.

The state may therefore enforce its law governing those activities if it satisfies the rule

from Mescalero. That rule has two prongs: The state law must be nondiscriminatory,

and it cannot be prohibited by express federal law to the contrary.

Under the first prong, an application of state law is nondiscriminatory when it

treats tribes or tribal entities the same as other similarly situated entities. 36 So, for

example, a state law that treats tribal law enforcement entities differently from law

enforcement entities of other jurisdictions is discriminatory. 37 On the other hand,

requirements that every entity that distributes cigarettes must obtain state licensing are

nondiscriminatory. 38 Here, California’s commercial cannabis licensing scheme treats all

similarly situated entities the same because all participants must hold a license issued by

California to participate in the market. Therefore, state law is nondiscriminatory.

32

Big Sandy Rancheria Enterprises v. Bonta (9th Cir. 2021) 1 F.4th 710, 729, internal

quotation marks omitted (Big Sandy Rancheria Enterprises).

33

Mescalero, supra, 411 U.S. at pp. 148-149; Twenty-Nine Palms Band of Mission

Indians v. Blanche (9th Cir. May 6, 2026, No. 25-2340) _ F.4th _ [2026 WL 1239758]

(Blanche).

34

Mescalero, supra, 411 U.S. at pp. 155, 158.

35

See Big Sandy Rancheria Enterprises, supra, 1 F.4th at pp. 728-729; King Mountain

Tobacco Co., Inc. v. McKenna (9th Cir. 2014) 768 F.3d 989, 998 (King Mountain

Tobacco).

36

King Mountain Tobacco, supra, 768 F.3d at p. 993 (state statute requiring all cigarette

sellers within the state to pay money into an escrow fund was nondiscriminatory).

37

Cabazon Band of Mission Indians v. Smith (9th Cir. 2004) 388 F.3d 691, 697-701

(under state law at the time, a statute that limited display of emergency light bars to

“authorized emergency vehicles” was discriminatory because tribal law enforcement

vehicles were treated differently from law enforcement entities from bordering states).

38

Big Sandy Rancheria Enterprises, supra, 1 F.4th at pp. 728-729.

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Under the second prong, “express federal law to the contrary” exists if federal law

grants or reserves for the tribe a right or privilege that is inconsistent with state law. 39

For example, in People v. McCovey, California criminally charged a member of the

Hoopa Valley Reservation who sold fish off tribal lands that were caught on tribal lands

with a type of fishing net prohibited under state law. 40 But federal regulations expressly

permitted tribal members to fish on tribal lands using the prohibited net, then sell the fish

off tribal lands. 41 The California Supreme Court held that the “comprehensive” and

“pervasive” federal regulatory scheme constituted an “express federal law to the

contrary” that prohibited the state from enforcing its fishing net requirements upon tribal

members. 42

In cases where federal law is ambiguous, it “must be interpreted in the light most

favorable to the Indians, and extrinsic evidence may be used to show the federal

government’s and Indians’ intent.” 43 For example, the Ninth Circuit held that a treaty

between the federal government and a particular tribe that reserved for the tribe the right

“to travel upon all public highways” created an express right to travel. 44 Upon close,

fact-specific examination of extrinsic evidence to determine the extent of that right, the

court held that the treaty prohibited the state from enforcing its truck licensing and permit

fee requirements upon the tribe. 45 In a different case, however, the Ninth Circuit held

that the same treaty was silent on the tribe’s right to trade, and therefore it did not contain

an express provision exempting the tribe from a state law governing cigarette sales. 46

Here, express federal law does not prohibit the state from enforcing its cannabis

licensing laws upon tribal activities off tribal land. 47 We are not aware of any federal law

or treaty that reserves for tribes the right to engage in commercial cannabis activity off

39

King Mountain Tobacco, supra, 768 F.3d at pp. 994-997; Ramsey v. United States (9th

Cir. 2002) 302 F.3d 1074, 1077; Cree v. Waterbury (9th Cir. 1996) 78 F.3d 1400, 1403-

1405; People v. McCovey (1984) 36 Cal.3d 517.

40

People v. McCovey, supra, 36 Cal.3d at p. 522.

41

Id. at pp. 523-524, 526, 530-531.

42

Id. at pp. 526, 534-535 (unlike Mescalero, “‘express federal law to the contrary’ is

present here. The federal regulations expressly govern off-reservation sales of

reservation-caught fish and impose sanctions at odds with state law”).

43

Ramsey v. United States, supra, 302 F.3d at p. 1079.

44

Cree v. Flores (9th Cir. 1998) 157 F.3d 762, 764, 774.

45

Ibid.

46

King Mountain Tobacco, supra, 768 F.3d at p. 998.

47

As noted above, California courts have held that the federal Controlled Substances Act

does not preempt California cannabis law, as a general matter. (See ante, fn. 24.)

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tribal land without obtaining a state license. Therefore, express federal law does not

prohibit enforcement of California’s commercial cannabis licensing requirements off

tribal lands under the second prong of Mescalero. 48

In conclusion, the question before us asks whether the State of California may

require tribes to become California-licensed to engage in commercial cannabis activity

with California licensees off tribal land. California can so require. As discussed above,

California’s commercial cannabis licensing requirement satisfies the rule from Mescalero

because it is a nondiscriminatory law that is not preempted by federal law. And courts

have upheld analogous state laws as applied to tribal activities off tribal land, such as

state fishing requirements, state licensing requirements for cigarette sales, and state taxes

on business income. 49 Thus, tribes must obtain a California license to engage in

commercial cannabis activity with California cannabis licensees off tribal lands. 50

Some observers urged us to reach a different conclusion. In their view, allowing

tribes to conduct commercial cannabis activity off tribal lands without obtaining a

California license would best respect tribal sovereignty. 51 As a general matter, tribal

48

We note, without analyzing, that California may have some authority to enforce state

law on tribal land, particularly against nontribal members. (See, e.g., Bracker, supra, 448

U.S. at pp. 141-145.) Because the question of state authority over cannabis activities on

tribal land is beyond the scope of this opinion, we do not address it here.

49

Organized Village of Kake v. Egan (1962) 369 U.S. 60, 76 (state fishing laws); Big

Sandy Rancheria Enterprises, supra, 1 F.4th at pp. 728-729 (tribe-to-tribe cigarette sales

treated as “off tribal land” and thus subject to state law); Mescalero, supra, 411 U.S. at

pp. 148-155 (ski resort off tribal land subject to state taxes); see also Michigan v. Bay

Mills Indian Community (2014) 572 U.S. 782, 795-796 (while the state could not sue the

tribe due to its sovereign immunity, the state had a number of other civil and criminal

tools at its disposal, including licensing requirements, to enforce state law against a tribe

or tribal members for a tribal casino located off tribal land).

50

Some states have addressed the issue of tribal participation in state cannabis markets by

authorizing their governor to enter into a government-to-government compact with tribes.

These compacts allow an entity licensed by a tribe to engage in commercial cannabis

activity with state-licensed entities. Such legislation exists in Nevada, Washington,

Michigan, and Oregon. (See N.R.S. § 223.250; Wash. Rev. Code Ann. § 43.06.490;

O.R.S. § 475C.521; M.C.L.A. § 333.27957, subd. (h)(2)(b) [authorizing the Michigan

cannabis regulatory agency to enter into tribal compacts].) In California, similar bills

were introduced in 2017, but none were enacted. (See Assem. Bill No. 924 (2017-2018

Reg. Sess.); Assem. Bill No. 1096 (2017-2018 Reg. Sess.).)

See Elk Valley Rancheria, California, letter to Heather Thomas, Deputy Attorney

51

General, Opinion Unit, California Department of Justice, May 6, 2024, p. 2 (describing

(continued…)

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sovereignty refers to a tribe’s ability to govern its own internal relations, by creating its

own laws to regulate activities on its own lands and to be governed by them. 52 But

where, as here, tribal activities occur off tribal lands, courts have concluded that state

regulation does not ordinarily infringe upon tribal sovereignty. 53 The Ninth Circuit has

held, for example, that licensing requirements in an analogous context—wholesale

cigarette sales off tribal lands—were consistent with tribal sovereignty if the laws

satisfied the rule from Mescalero discussed above. 54 Tribal sovereignty principles

therefore do not prevent California from enforcing its licensing requirements for

commercial cannabis activity occurring off tribal land.

Observers may also cite Public Law 280 (PL 280), a federal law that grants certain

states, including California, relatively broad criminal jurisdiction, and more limited civil

jurisdiction, over tribal members on tribal lands. 55 Under PL 280, the state’s authority

concerning tribal activities on tribal lands turns on whether a particular law is criminal

and prohibitive in nature, or civil and regulatory. 56 However, because the question

concerns only commercial cannabis activity off tribal lands, we need not engage in that

inquiry here. Thus, we do not further analyze or comment on California’s authority

under PL 280 to enforce state cannabis law on tribal land.

tribal sovereignty as “a fundamental principle recognized by the federal and state

governments” that “grants tribes the authority to self-govern and make decisions about

their own economic development”).

52

See, e.g., New Mexico v. Mescalero Apache Tribe (1983) 462 U.S. 324, 332 (“We have

continued to stress that ‘Indian tribes are unique aggregations possessing attributes of

sovereignty over both their members and their territory.’ . . . The sovereignty retained by

tribes includes ‘the power of regulating their internal and social relations’”) (finding that

concurrent state jurisdiction over hunting and fishing by non-members on tribal lands

would interfere with tribal self-governance).

53

Big Sandy Rancheria Enterprises, supra, 1 F.4th at pp. 728-729 (concluding that tribal

sovereignty principles did not prohibit the state from regulating tribal sales of cigarettes

off tribal land); Blanche, supra, __ F.4th at __ [2026 WL 1239758] (same).

54

Big Sandy Rancheria Enterprises, supra, 1 F.4th at pp. 728-729.

55

Pub.L. No. 83-280 (Aug. 15, 1953) 67 Stat. 588, codified at 11 U.S.C. § 1162 and 28

U.S.C. § 1360; Bryan v. Itasca County, Minnesota (1976) 426 U.S. 373.

56

Cabazon, supra, 480 U.S. at pp. 207-212, superseded by statute; Doe v. Mann (9th Cir.

2005) 415 F.3d 1038, 1053-1058.

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CONCLUSION

For these reasons, we conclude that tribes must obtain a license from the

Department of Cannabis Control to engage in commercial cannabis activity with

California cannabis licensees off tribal lands.

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