was considered to take a significantly more deferential approach towards the states (compared to the 2011 Cole memo), similar in nature to how the 2009 Ogden memo was originally widely interpreted. Federal enforcement efforts were further scaled back with the enactment of the Rohrabacher–Farr amendment in December 2014, although the Justice Department initially continued with a number of prosecutions until a pair of court rulings determined it was interpreting the amendment incorrectly. Rohrabacher–Farr amendment On December 16, 2014, a landmark victory was achieved for medical cannabis at the federal level with the signing into law of the Rohrabacher–Farr amendment. Initially introduced by Rep. Maurice Hinchey in 2001, the amendment prohibits the Justice Department from spending funds to interfere with the implementation of state medical cannabis laws. It failed 152–273 upon its initial vote in 2003, and was defeated five more times over the next decade until it passed the House by a 219–189 margin on May 30, 2014, as an attachment to the CJS Appropriations bill for fiscal year 2015. It did not receive a vote in the Senate, but was inserted into the $1.1 trillion "cromnibus" spending bill during final negotiations, which became law with President Obama's signature on December 16, 2014. The Rohrabacher–Farr amendment passed the House by an even larger margin (242–186) in June 2015, then won approval in a 21–9 Senate Appropriations Committee vote, and was signed into law as part of the FY 2016 omnibus appropriations bill on December 18, 2015. The amendment was subsequently included in a series of spending bills with the most recent extension effective through September 30, 2023. Although state medical cannabis programs are protected by the amendment, it does not change the legal status of cannabis, and must be renewed each fiscal year in order to remain in effect. The Justice Department has also interpreted the amendment in a manner vastly different from the authors' intent, which it has used to justify a number of raids and prosecutions after the law's enactment. U.S. District Judge Charles Breyer ruled against the Justice Department in October 2015, however, stating that the DOJ interpretation "defies language and logic" and "tortures the plain meaning of the statute", and was "counterintuitive and opportunistic". The Ninth Circuit Court of Appeals similarly rejected the DOJ's arguments in an August 2016 ruling. State policy Early laws (late 1970s and early 80s) Due to increasing public awareness of the