In the People v. Jovan Jackson, (2012) 210 Cal.App.4th 1371, the court held that the MMPA does not require active participation by all members of a collective in the cultivation process and membership may be limited to financial support by way of marijuana purchases. The court stated the three elements of the MMPA are that the collective 1. Are qualified patients or primary caregivers; and, 2. Collectively associate to cultivate marijuana; and, 3. The collective must be a nonprofit enterprise. In addition, the court provided factors for a jury to consider as to whether a medical marijuana collective is a non-profit, specifically: The size of the collective's membership; the volume of purchases from the collective; the members participation in the operation and governance of the collective; the testimony of the operator[s] of the collective; its formal establishment as a nonprofit organization; the presence or absence of any financial records; the presence or absence of processes by which the collective is accountable to its members; the volume of business it conducts; any other evidence of profit or loss. See also Cannabis in California Drug policy of California Legal history of marijuana in the United States Medical cannabis Proposition 215 Valerie Corral 420 (cannabis culture) References External links Official California Legislative Information relating to SB 420 in the 2003/2004 session Ukiah Daily Journal http://www.courtinfo.ca.gov/opinions/revpub/B195624.PDF Cannabis law reform in the United States Drug control law in the United States 2003 in American law Senate Bill 420 2003 in cannabis