Attorney, Looming Large
Sarah Lee Gossett Parrish is a woman who has been blessed with a 30 hour day. She is a fine art photographer, an author, a frequent guest on radio shows and she sits on 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. More specifically, she has taken issue with three of the regulatory agencies in Oklahoma that govern marijuana businesses and she’s not afraid to talk about it. Nor is she shy about turning over stones. In fact, just this past February Sarah Lee took advantage of the Freedom of Information Open Records Act and filed requests with the following three agencies: the Oklahoma Medical Maijuana Authority (OMMA), the Oklahoma Bureau of Narcotics & Dangerous Drugs (OBNDD) and the Oklahoma State Fire Marshal. If she was the lawyer to any of these agencies, she said, “she’d be having massive heartburn right about now.”
A third-generation attorney, Sarah Lee has been practicing law since 1986 but, once SQ 788 was passed in 2018 and medical marijuana was made legal, she pivoted from contract to cannabis law. She became passionate about the medicinal benefits of marijuana after witnessing her close friend lose her battle with leukemia at just thirty-three years of age, well before cannabis had been made legal. Since then, Sarah Lee has come to learn that marijuana can ease the symptoms of chemotherapy and nausea, assist with pain management and lessen the effects of migraines, anxiety and insomnia. “Instead of xanax,” she says, “why not take a couple of gummies?” This natural and beneficial alternative to medical care feels especially relevant to Sarah Lee in light of the nation’s opioid epidemic, wherein many voters now recognize that medical marijuana could easily replace opioids in the treatment of the very same conditions that turned so many patients into addicts. Sarah Lee believes wholeheartedly that people should have access to natural remedies and she is willing to take to task those entities that she feels may 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 her frequent communion with the Lord 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, on the other hand, was one of the first Oklahoma attorneys willing to jump into the legal fray. Initially, she wasn’t certain that God would sanction her shift in focus, so she prayed for His guidance. Her results, she thought, would serve as her benchmark.
She started networking with the International Cannabis Law Association and shortly began receiving out-of-state referrals. Word got out, and given the fact that she was a well-established attorney from a legacy family, she began to receive in-state referrals. Sarah Lee continued to pray and noticed that she was blessed with a continuous stream of new clients. Her growing practice, she trusted, was evidence that God felt she was doing important work and had blessed her efforts.
Success followed. In short order, Sarah Lee became the recipient of numerous awards and national press, including coverage in prestigious publications such as the San Francisco Chronicle and the NY Times. She feels that this level of recognition is “God’s deal,” and that she could not have done this on her own. “I’m so grateful and I give Him the glory… As far as the honors and the rewards, there are so many other attorneys equally deserving and hard working, but the fact that I got the rewards I attribute to as a nod from the Lord and His blessing.”
Indeed, her “quiet, strong faith in God” has helped her walk through many fires and today she finds the fire leaping once more. Things are heating up because many legitimate Oklahoma cannabis-based businesses are suddenly being put through the ringer. It’s the “wild, wild west out here,” she says. But the cause for so much wildness is not because the floodgates suddenly opened and everyone is grabbing for a piece of the pie, but because the doors are, instead, swiftly closing. The wild west she refers to today has everything to do with compliance, with what she assumes is a grab for authority and, sadly, the irrational and overwhelming difficulty many legitimate businesses have in obtaining their Certificate of Occupancy (COO).
Without a COO, businesses can no longer renew their Certificate of Compliance (COC), meaning that failure to procure a COC is sufficient cause for the OBN to shut down what had formerly been legal. The regulating agencies keep moving the goalpost so that it is not only extraordinarily difficult, but also cost-prohibitive to remain compliant, especially for growers. This begs the question as to 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’s frequently heard that “the Chinese mob is here,” or that “Russian gangsters are here.” And while Sarah Lee is the first to admit that the illicit market is a legitimate concern and should be eradicated, she is nonetheless adamant that the response from the OBN is disproportionate to any actual threat. If you follow the industry news, which she does, the savvy reader will notice that the OBN reports few arrests within the black market. Yet, these agencies are quietly shutting down a lot of legitimate growers. “It’s apparent from this new COC requirement,” she says, “that these agencies are trying to enforce regulations in an unreasonable manner. They don’t seem to care if you are fully compliant and licensed to operate a legal business or if you’re a gangster. They are going after legitimate Moms and Pops who have spent their life savings and re-invested it into their businesses - people who are contributing significant tax monies to our economy.”
About a year ago, OBN decided they would eclipse OMMA. “It is now more difficult to obtain your license registration from OBN than it is to get your license at OMMA, which is insane since OMMA is the regulatory agency. Essentially, this is a battle between the two 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.”
As an example, Sarah Lee currently has a client with a grow operation. He was told by the State Fire Marshal that he would have to install a fire hydrant - to the tune of $100,000 - and that they would not issue the newly requisite COO until the hydrant was in place. (Side bar?: Sarah Lee is quick to acknowledge that the State Fire Marshal is new to the game as far as being implicated in licensing issues but, she hastens to add, “they are certainly in the middle of it now and, I think, much to their dismay. I feel for the State Fire Marshal’s office.”)
Furthermore, if her client didn’t have the COO, then the OBN would shut him down. The irony is that this client had initially secured an operational license in 2018 and his license had been renewed every year since. But now, seemingly out of the blue, he has to obtain the COO in order to remain operational in 2024. Worse, he was told by the OBN that he had only thirty days to provide the COO. Yet, the State Fire Marshal has gone on the record stating that they are so backed up with the onslaught of requests that it will take them six to nine months just to process an application. By requiring the certificate in thirty days, the OBN is effectively issuing an impossible edict. Sadly, Sarah Lee’s client “threw in the towel because he didn't have $100,000. All his money had been invested in the grow. To me, that is unreasonable.”
Another crippling issue for business owners is confusion regarding who is required to complete the application for the COO: the licensee with a lease on a building, or the owner of the building? The Fire Marshal’s office is now claiming that only the landowner can submit the application. In the past, businesses typically had their consultant or contractor apply for the COO - not the landowner, who often knows close to nothing about their tenants' businesses. In Sarah Lee’s estimation, this new requirement is unreasonable, especially when landowners sometimes live out of state and are otherwise oblivious about the various requirements of their tenant’s businesses. “Landowners don’t know about the industry - their tenants do. This requirement defies logic and leaves one with the impression that this is a veiled effort to weed out licensees.”
Heightening her skepticism is the fact that “Governor Stitt has gone on the record gleefully stating how many growers he has shut down. It makes one wonder why he is after legal businesses with the same zeal that he’s going after illegitimate operations. There is a lot to discover in terms of motive. One could look at the facts and draw the conclusion that at least some of these agencies and/or the governor are conspiring and colluding to get rid of licensees - particularly growers, at any cost. I’m not weighing in on the veracity of that, but I think my Freedom of Information Acts request could potentially provide some nuggets to further support that theory.”
Ultimately, Sarah Lee’s passion lies in the future viability of her clients, all of whom she knows to be good, law-abiding people - folks who run astute operations and reinvest their profits, hire locally, give back to their community and, in so doing, build brand loyalty. She is committed to their survival because she believes in a free economy that is neither severely regulated nor levied with punitive fees. More importantly, she champions their cause because she knows in her heart that these are hardworking and deserving people.
Part of Sarah Lee’s prayer practice includes assigning herself a word of the year. Her word for 2024, about which she meditates frequently, is WARRIOR - an apt word for a woman who demonstrates that she is willing to step into the fray and pick a bone for a just cause. “I am fighting hard for my clients and for our industry. I’m working in earnest to keep it afloat and rationally and responsibly regulated.”
Godspeed, Sarah Lee. Godspeed.