medical benefits of cannabis, and in anticipation of forthcoming changes to federal policy, a number of states passed laws in the late 1970s and early 1980s addressing the medical use of cannabis. New Mexico was the first to do so in 1978, and by the end of 1982 over thirty states had followed suit. The majority of these laws sought to provide cannabis through federally-approved research programs administered by the states, using cannabis supplied by the National Institute on Drug Abuse. Only seven states ended up implementing the programs, however, due to the large bureaucratic and regulatory obstacles imposed by the federal government. Other states passed legislation allowing doctors to prescribe cannabis, or reclassifying cannabis in a state's internal drug scheduling system. These laws were largely ineffectual though, due to the continued prohibition of medical cannabis at the federal level. A few states passed laws affirming the right of individuals to present a medical necessity defense at trial. By the mid-80s, however, efforts to pass new medical cannabis laws had ground to a halt, and a number of existing laws were either repealed or allowed to expire. California (early and mid-1990s) Medical cannabis advocates began to gain ground in the early 1990s with a series of legislative achievements in the state of California. Proposition P was approved by 79% of San Francisco voters in November 1991, calling on state lawmakers to pass legislation allowing the medical use of cannabis. Additionally, the city board of supervisors passed a resolution in August 1992 urging the police commission and district attorney to "make lowest priority the arrest or prosecution of those involved in the possession or cultivation of [cannabis] for medicinal purposes" and to "allow a letter from a treating physician to be used as prima facia evidence that marijuana can alleviate the pain and suffering of that patient's medical condition". The resolution enabled the open sale of cannabis to AIDS patients and others within the city, most notably through the San Francisco Cannabis Buyers Club which was operated by medical cannabis activist Dennis Peron (who spearheaded Proposition P and later the statewide Proposition 215). Similar clubs appeared outside San Francisco in the ensuing years as other cities passed legislation to support the medical use of cannabis. The Wo/Men's Alliance for Medical Marijuana was founded in 1993 after 75% of Santa Cruz voters approved Measure A in November 1992. And the Oakland Cannabis