charges not covered in 215. Allows probationers, parolees, and prisoners to apply for permission to use medical marijuana; however, such permission may be refused at the discretion of the authorities. Makes it a crime to fraudulently provide misinformation to obtain a card, to steal or misuse the card of another, to counterfeit a card, or to breach the confidentiality of patient records in the card program. People v. Kelly Concerning limits on possession created by the bill, the California Supreme Court decision in People v. Kelly decided multiple issues. First, it reiterated that "unlike [Proposition 215], which did not immunize medical marijuana users from arrest but instead provided a limited 'immunity' defense to prosecution under state law for cultivation or possession of marijuana ... the [Medical Marijuana Program]'s identification card system is designed to protect against unnecessary arrest." Secondly, it agreed with both Kelly and the California Attorney General that the limits were an "unconstitutionally amendatory insofar as it limits an in-court CUA defense". However, the section concerning limits on possession "should remain an enforceable part of the MMP, applicable to the extent possible — including to those persons who voluntarily participate in the program by registering and obtaining identification cards that provide protection against arrest" because it provided more rights, namely the immunity against arrest. A qualified patient or primary caregiver that participates in the voluntary MMIC program also maintains his or her separate rights under California Health and Safety Code Section 11362.5, which are not included in the legislature-driven amendments seven years later. City of Garden Grove v. Superior Court On December 1, 2008, the Supreme Court decided not to hear arguments in City of Garden Grove v. Superior Court of Orange County, leaving a lower court ruling standing which requires local police officers to enforce state law, not federal law. The case stems from a traffic stop of Felix Kha, who had 8.1 grams of medical marijuana in a container, which the police officers confiscated. The ruling requires police officers to return the seized medicine. But it must be remembered it is not the job of the local police to enforce the federal drug laws as such. People v. Jovan Jackson Concerning the scope of the legal defense created by the bill, the California Fourth Appellate District clarified the law in regards to the Medical Marijuana Program Act (MMPA), and was upheld by the California Supreme Court.