California DCC license and enforcement defense
When the Department of Cannabis Control or your city moves against a California cannabis license, everything is on the table: revenue, inventory, contracts, investors, the value of the company, and for registrants, the federal registration priced on top of it. Kocot Law defends licensees at every stage, from the first Notice to Comply to an accusation seeking revocation, and builds the compliance record the Department looks at when it decides how a matter resolves.
Call or text (916) 572-6445This page covers California only. For other states: New York (OCM) · Massachusetts (CCC). Ryan Kocot · licensed in California, New York & Massachusetts. Attorney advertising. Contacting me does not create an attorney-client relationship; please do not send confidential details until we have spoken and confirmed there is no conflict.
Default periods under 4 CCR §§ 17801, 17801.5, 17815 and Gov. Code §§ 11505, 11506. The document you received controls. Last reviewed October 21, 2026.
Small problems become license problems
License problems rarely start as license problems. They start as a failed inspection, a Metrc discrepancy, a records request, a renewal deficiency, or a complaint to the city. Handled well early, most issues resolve as corrections. Handled late or casually, they escalate, and every stage of escalation costs more to fight than the one before it.
There is a second front operators underestimate: a California cannabis business needs both state licensure and local authorization, and a city or county permit action can take down an operation while the DCC license sits in good standing. The two tracks interact. Defending one without watching the other is how operators win a battle and lose the license.
If an accusation has been filed
An accusation is the Department’s formal case to suspend or revoke the license, prosecuted by a Deputy Attorney General under the Administrative Procedure Act. The first fact about it is a date: the notice of defense is due within 15 days of service. In the Department’s posted 2026 decisions, a large share of the revocations were entered by default, which means the licensee never filed that one-page form. One matter went from emergency suspension to default revocation in about seven weeks. How accusations work · Can you keep operating while DCC seeks revocation?
The second fact is that almost every contested accusation ends in a stipulation, and the terms are set by the record the licensee brings to the table. The same violation ends in a stayed revocation with probation for one operator and in revocation for another; the difference is what each one could prove. So the defense file is evidentiary from day one:
- Count-by-count analysis. Which license each count attaches to, which regulation and version was in force, what the Department must prove, and what it has actually cited. Counts that do not identify a license are a pleading and proportionality problem for the Department, not for you.
- Chronology and evidence matrix. Every inspection, notice, response, plan, approval, and communication, dated and sourced, with the Department’s position and yours side by side.
- Numbers and track-and-trace reconstruction. Measurements, conversions, and Metrc histories independently verified. A discrepancy that is contractor entry error, late entry, or a tagging failure is a different case from diversion, and the Department carries the burden on diversion.
- Mitigation packet and settlement proposal. Background, response to the principal allegations, cooperation and corrective action mapped to the Disciplinary Guidelines, proposed license-preserving terms, and why the resolution protects the public. Built from documents that exist, not promises.
- Hearing and appeal. If the Department insists on revocation without proof that supports it, we try the case at the Office of Administrative Hearings and protect the record for the Cannabis Control Appeals Panel.
For DEA registrants, state discipline is a federal event
Under the federal rescheduling order, a DEA registration issued through the state-license pathway is automatically suspended if the underlying state license is suspended, revoked, or expires (21 C.F.R. § 1301.13(k)(3)). If you have registered for the federal medical channel, or plan to, a state disciplinary action no longer risks only your California operation. It risks the federal registration and everything priced on it: your 280E position, your banking and capital relationships, and your place in line for whatever interstate commerce becomes.
That changes the defense calculus. Outcomes short of suspension matter more than they ever did, resolutions have to account for federal collateral consequences, and even a lapsed renewal is a federal risk item. License defense is handled with the federal layer in view.
Enforcement defense informed by compliance work
Corrective action backed by records
Regulators respond to operators who can show what happened, what was fixed, and what system now prevents recurrence, with records behind every sentence. Kocot Law builds and audits cannabis compliance programs for a living. A corrective action plan is built from the actual system work: SOPs, training records, reconciliations, and premises documentation.
In-house and private practice experience
Ryan Kocot has served California cannabis operators since 2015, ran legal and compliance inside a cannabis company that grew from startup to multinational public company, and practices across the state and federal layers of cannabis regulation, including DEA registration work.
What we handle
From the first call to an engagement letter
- First contact. Call or text (916) 572-6445, or use the form on this page. Tell us what kind of document arrived, who issued it, and the date it was served or received. Do not send confidential details yet.
- Conflict check. Before discussing the substance, Ryan confirms the firm can represent you, checking the people and businesses involved on every side of the matter.
- Review and scope. A free 30-minute consultation identifies the enforcement tool, the deadlines it starts, what is at risk, and what has to happen first. Where the scope is clear, you receive a written fee proposal.
- Engagement letter. Nothing is filed on your behalf until an engagement letter is signed. It sets out the scope, the fees, and who does what.
Enforcement work is often scoped in phases, so you decide at each stage whether to continue. Typical phases for an accusation: the immediate response (the notice of defense and protective steps), building the defense file and mitigation packet, negotiating the resolution, and, only if needed, the hearing and appeal. Smaller matters, such as a Notice to Comply response, are often a single phase.
Referring a client with a DCC matter
If you represent a client who has received a DCC enforcement document, call or use the form. After a conflict check, Ryan can handle the DCC matter alone or work alongside you on it. How responsibility and client communication are divided is agreed at the start and set out in the engagement letter.
Facing enforcement, or want to get ahead of it?
If nothing has happened yet, that is the better call to make. Training, SOP review, and an honest internal check cost far less than a defense. If something has arrived, call first: the document names the clock, and the clock is already running.
Frequently asked questions
The Department can take your default and the license can be revoked without a hearing. Government Code section 11520 allows a motion to vacate a default decision for good cause within seven days after service of the decision, and defaults have been vacated, but you do not want to be litigating that motion. File the notice of defense. It is a one-page form, usually in the packet, and filing it is the difference between a hearing and a revocation entered on the pleadings.
It is the fork in the road. Addressed completely and on time, with documentation, most compliance issues end there. Ignored or half-answered, they become the foundation for escalating discipline. And the Department does not have to issue one first; in 2026 it has often opened with an embargo, an emergency order, or an accusation. Treat whatever deadline your notice contains as unmissable.
Sometimes that is the right call, but not automatically. Paying can leave findings on your record that surface in renewals, future enforcement, transactions, and, for registrants, federal review. The decision should account for what the record will say later, not just the fine amount.
No. State licensure requires local authorization, so losing the local permit threatens the whole operation, and local trouble tends to surface in state review. Local enforcement deserves the same urgency as a DCC action, and the two defenses should be coordinated.
If you hold one, yes. A registration issued through the state-license pathway is automatically suspended upon suspension, revocation, or expiration of the underlying state license. For registrants, keeping the state license in good standing is a federal compliance obligation.
A free 30-minute consult is enough to identify what you received, what it puts at risk, and what has to happen before the deadline. If you want help from there, you receive a written fee proposal before any work begins.
Read the guides
Every DCC enforcement tool, the deadline it starts, and every article the firm has written on it are collected on one page: California cannabis enforcement.
Attorney advertising. This page is general information, not legal advice. Reading it, calling, or submitting a form does not create an attorney-client relationship; none is formed unless and until Kocot Law completes a conflict check and both parties sign an engagement letter. Any deadline in your matter is controlled by your notice and the applicable statute or regulation. Prior results do not guarantee a similar outcome.
Received a DCC document?
Free 30-minute consult: what you received, what it puts at risk, and what has to happen before the deadline. A written fee proposal before any work begins, if you want help from there.
Call or text (916) 572-6445 Book a free consultation