RN Collins has written a new series (3) of 18 articles for cannabis law report on 2026 Psychedelics & Legal Issues.

This is the 1st

Contact RN Collins: https://www.linkedin.com/in/rn-collins/

 

 

The ADA’s Illegal Drug Use Exclusion and State-Licensed Psilocybin Services: Where Disclosure and Protection May Diverge

Schedule I Status, State Therapeutic Licensing, and an Unresolved Question in Employment Law

RN Collins, M.S., JD Candidate

https://www.linkedin.com/in/rn-collins/

Abstract

In 2023, Oregon began licensing psilocybin service centers as a framework for addressing mental health conditions. In the same period, an employee with treatment-resistant depression who accesses one of those licensed service centers for therapeutic purposes and discloses that fact to an employer may become an employee the ADA does not protect, because psilocybin remains Schedule I and the ADA’s illegal drug use exclusion under 42 U.S.C. § 12114(a) appears to apply regardless of state licensing, therapeutic intent, or the underlying mental health condition. This tension is not obviously an oversight; it may instead be read as a structural consequence of the federal-state divide on psilocybin’s legal status.

This article traces the legal architecture surrounding this tension and its possible implications for how the employment relationship is understood on both sides. The analysis proceeds through six doctrinal strands: the ADA illegal drug use exclusion and its three operative components (currently engaging, illegal use, on the basis of such use); the federal contractor Drug-Free Workplace Act and Executive Order 12564 obligations; the DOT drug testing framework and the five-panel gap; the state cannabis employment protection framework and why it does not extend to psilocybin; the RFRA dimension for employees with sincere religious beliefs; and the accommodation requests that state-licensed service center use may increasingly generate.

The article’s central contribution is the analysis, developed in Part VII, of what might be called a disclosure dilemma: an employee who discloses therapeutic psilocybin use to an employer in support of an accommodation request for the underlying mental health disability may, under current law, be found to have relinquished ADA protection for any subsequent adverse action based on the disclosed use. The disclosure that appears necessary to obtain accommodation for the disability may be the same disclosure that removes the disability’s ADA protection. One possible response, discussed below, involves sequencing: the disability may be disclosed without disclosing the specific treatment modality, which could preserve ADA protection while allowing the accommodation process to proceed, though this approach has not been tested by any court and offers no guarantee.

I. Introduction

The practice of microdosing psilocybin, consuming sub-perceptual doses of a Schedule I psychedelic, typically one-tenth of a full dose at intervals of several days, for reported cognitive, mood, and productivity benefits, has moved from the margins of psychedelic culture into more mainstream professional conversation. A 2021 survey in the journal Psychopharmacology identified over 4,000 self-identified microdosers across multiple countries, with reported improvements in wellbeing, mood, and focus cited as primary motivators. Some surveys suggest that meaningful proportions of knowledge workers in technology, finance, and creative industries have experimented with psilocybin microdosing, often without disclosure to employers and often without full awareness of the legal exposure this may create.

The legal framework governing microdosing in the employment context is both largely categorical on its face and largely uncharted in application: psilocybin is Schedule I under the CSA; the ADA’s illegal drug use exclusion under 42 U.S.C. § 12114(a) appears to apply in full; the SAMHSA and DOT five-panel testing frameworks do not include psilocybin; and no state has enacted employment protection for psilocybin microdosing comparable to the protections a growing number of states have enacted for off-duty cannabis use. This article attempts a comprehensive analysis of this legal framework, with particular attention to the disclosure dilemma that the ADA may create for employees who access state-licensed psilocybin services.

The article proceeds as follows. Part II develops the ADA illegal drug use exclusion. Parts III and IV address federal contractor and DOT obligations. Part V considers state employment protection frameworks and why they do not extend to psilocybin. Part VI addresses RFRA. Part VII develops the disclosure dilemma. Part VIII considers what this analysis may mean for regulators and legislators going forward. Part IX concludes.

II. The ADA and the Illegal Drug Use Exclusion

A. The Statutory Framework

Section 12114 of the ADA, captioned “Illegal use of drugs and alcohol,” creates a specific exclusion from the ADA’s protection for current illegal drug users. Subsection (a) provides: “[f]or purposes of this subchapter, a qualified individual with a disability shall not include any employee or applicant who is currently engaging in the illegal use of drugs, when the covered entity acts on the basis of such use.” 42 U.S.C. § 12114(a). The statutory text has three operative components: (1) the person must be “currently engaging in” the illegal use; (2) the use must be “illegal use of drugs” as defined by the Act; and (3) the employer must act “on the basis of such use.” Each component carries independent doctrinal significance for the microdosing analysis, though how courts would weigh them in this specific context remains untested.

Section 12114(b) creates three categories not excluded by subsection (a): individuals who have successfully completed supervised drug rehabilitation and are no longer using; individuals participating in supervised rehabilitation and no longer using; and individuals erroneously regarded as engaging in such use but who are not. 42 U.S.C. § 12114(b). The third category, erroneously regarded as engaging in illegal drug use, may be the only one with potential relevance to a psilocybin microdosing context, and even then only where the employee is not, in fact, engaging in such use.

B. Currently Engaging In: The Temporal Standard

The statutory phrase “currently engaging in the illegal use of drugs” has been interpreted by the Department of Justice and by courts to require use that “occurred recently enough to justify a reasonable belief that a person’s drug use is current or that continuing use is a real and ongoing problem.” DOJ, The ADA and Opioid Use Disorder, https://www.ada.gov/resources/opioid-use-disorder/. In Shafer v. Preston Memorial Hospital Corp., 107 F.3d 274 (4th Cir. 1997), the Fourth Circuit held that a nurse anesthetist who had diverted Fentanyl, a Schedule II narcotic, from the hospital pharmacy and who had entered treatment was not protected by the ADA, because her use was found sufficiently recent to establish that she was “currently engaging” in it at the time of termination.

For psilocybin microdosing specifically, a protocol of one dose every three days does not read as intermittent or occasional drug use. It appears closer to a regular, scheduled practice. If that characterization holds, the “currently engaging” standard would likely be satisfied by a microdosing schedule, which is by its nature an ongoing practice with continuing use as a defining feature. The sub-perceptual dose and the absence of workplace impairment may be largely irrelevant to this standard, which asks primarily about the ongoing character of the use rather than its intensity or visible effect. This is an inference from the statutory text and case law rather than a settled conclusion, since no court has addressed microdosing specifically.

C. Illegal Use of Drugs: The Schedule I Hook

The ADA defines “illegal use of drugs” to mean the use of drugs the possession or distribution of which is unlawful under the CSA. 42 U.S.C. § 12111(6)(A). The definition expressly excludes use of a controlled substance under the supervision of a licensed health care professional. 42 U.S.C. § 12111(6)(B). Psilocybin is Schedule I under the CSA, 21 U.S.C. § 812(c)(Schedule I)(d)(1). On this basis, psilocybin microdosing by a private individual, whether in a non-therapeutic context, a self-administered wellness practice, or in conjunction with state-licensed service center sessions, would appear to constitute “illegal use of drugs” within the ADA’s definition.

The health care professional exception in 42 U.S.C. § 12111(6)(B) does not offer a pathway for psilocybin microdosing to escape the illegal use exclusion. Psilocybin has no FDA-approved use, cannot currently be lawfully prescribed by a licensed health care professional, and does not appear usable under medical supervision in a legally authorized manner in the private employment context. A facilitator-supervised session at an Oregon licensed service center is unlikely to qualify as medical supervision of a controlled substance under 42 U.S.C. § 12111(6)(B), both because the facilitator may not be a licensed health care professional in the statutory sense and because ORS 475A explicitly disclaims medical status for psilocybin services.

D. Cannabis Rescheduling and Its ADA Implications

The DEA’s April 2026 proposed rule to reschedule cannabis from Schedule I to Schedule III, if finalized, could change the “illegal use” analysis for cannabis: a Schedule III substance may be prescribed by a licensed practitioner and used under medical supervision, potentially bringing it within the 42 U.S.C. § 12111(6)(B) exception for employees with valid prescriptions. Psilocybin remains Schedule I and does not receive comparable treatment under any pending proposal. The cannabis rescheduling development illustrates how the ADA’s illegal use exclusion tracks Schedule I status generally: as the federal scheduling determination changes, the ADA analysis could change with it. For psilocybin, there is no pending rescheduling action as of June 2026.

III. Federal Drug-Free Workplace Requirements

The Drug-Free Workplace Act of 1988, 41 U.S.C. §§ 8101–8106, requires federal contractors receiving grants of $25,000 or more to maintain a drug-free workplace program, including a written drug-free workplace policy, drug-free awareness program, and a condition of employment requiring employee compliance with the policy. The Act does not itself mandate drug testing, but the combination of the policy requirement and the “good faith efforts” requirement has been interpreted by most federal contractors as requiring drug testing as the practical enforcement mechanism.

Executive Order 12564, 51 Fed. Reg. 32889 (Sept. 17, 1986), directs federal agencies to adopt drug-free workplace policies and requires testing of employees in “sensitive positions.” The SAMHSA Mandatory Guidelines, most recently revised at 88 Fed. Reg. 70768 (effective Feb. 1, 2024) and supplemented at 91 Fed. Reg. 12308 (effective July 7, 2025), specify five analyte categories for federal workplace drug testing: marijuana metabolites, cocaine metabolites, amphetamines, opiates/opioids, and PCP. As of the July 7, 2025 update, fentanyl was added to the federal agency panel. Psilocybin is not on the panel. This means that federal civilian employees who microdose psilocybin would likely test negative on a standard federal panel test, even though the underlying use may still violate applicable drug-free workplace policies, which typically cover all illegal drug use rather than merely the substances captured by the testing panel.

IV. DOT Drug Testing and Safety-Sensitive Employees

The DOT five-panel drug test covers the same five analyte categories as the SAMHSA federal agency panel. 49 C.F.R. § 40.85 (specifying testing for these drug classes); 49 C.F.R. § 40.87 (cutoff concentrations). As of June 2026, psilocybin is not on the DOT testing panel. A commercial truck driver, airline pilot, or railroad engineer who microdoses psilocybin would likely test negative on the standard DOT pre-employment, random, reasonable suspicion, post-accident, and return-to-duty drug tests.

That testing gap does not create a legal safe harbor. A DOT safety-sensitive employee who is known to be using psilocybin would likely be found in violation of applicable DOT regulations, regardless of whether a panel test would detect it. For DOT safety-sensitive employees, the analysis reads as close to categorical: any use of psilocybin may violate applicable federal drug-free workplace obligations as currently written, regardless of whether it is detected, and this exposure is not mitigated by dose size, off-duty timing, or therapeutic rationale.

The defining characteristic of microdosing, that the dose is sub-perceptual, means that a properly executed microdose is unlikely to produce observable behavioral changes that would generate the articulable observations required under the reasonable suspicion standard of 49 C.F.R. § 382.307. From the employer’s perspective, psilocybin microdosing may be largely invisible to the DOT reasonable suspicion framework, much as it appears invisible to the standard panel test. If this reading holds, the result is a population of employees whose legal exposure may be severe while the corresponding detection risk remains comparatively low, a gap that a substantial number of employees may not be aware of.

V. State Employment Protections and the Psilocybin Gap

A substantial number of states with legalized cannabis have enacted employment protections for employees who use cannabis lawfully off-duty. California’s Government Code § 12954 (effective January 1, 2024) prohibits employers from discriminating against employees based on off-duty, off-premises cannabis use and bars employers from using hair or urine test results that detect cannabis metabolites as the basis for employment decisions. New York’s Labor Law § 201-d prohibits employers from testing current and prospective employees for cannabis use and from discriminating based on off-duty cannabis use. Connecticut, New Jersey, Illinois, Minnesota, Montana, Nevada, New Mexico, Rhode Island, and Virginia have enacted varying degrees of employment protection for off-duty, state-legal cannabis use.

These statutes share structural features that are relevant to the psilocybin analysis. First, each is specifically limited to cannabis. Second, each contains carve-outs for safety-sensitive positions. Third, each is limited to state-legal use. Psilocybin has been legalized for personal use in no state; Oregon and Colorado have licensed commercial service centers, but neither has legalized personal home use or possession outside the service center context. On this basis, there is no legal foundation for a state employment protection statute for personal psilocybin use analogous to the state cannabis employment protection statutes, absent new legislative action.

Coats v. Dish Network, LLC, 350 P.3d 849 (Colo. 2015), illustrates the controlling principle here: the Colorado Supreme Court held that an employee who was a state-licensed medical cannabis patient could lawfully be terminated for failing a drug test, because Colorado’s “lawful activities” statute protecting off-duty conduct only covered activities “lawful” under both state and federal law, and cannabis was not federally lawful. This suggests that protection of off-duty drug use may require specific state legislative action, rather than following merely from the absence of state prohibition. Psilocybin has not received such legislative action in any state to date.

VI. The RFRA Dimension

RFRA, 42 U.S.C. § 2000bb et seq., prohibits the federal government from substantially burdening a person’s exercise of religion unless the burden serves a compelling governmental interest through the least restrictive means. In the employment context, RFRA does not directly govern private employer conduct. Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-2, requires employers to make reasonable accommodations for employees’ sincerely held religious beliefs unless doing so would impose an undue hardship. Groff v. DeJoy, 600 U.S. 447 (2023), raised the undue hardship standard to require a showing of “substantial increased costs in relation to the conduct of [the employer’s] particular business.”

An employee with a sincere religious belief requiring psilocybin use could conceivably present a Title VII accommodation request. This tension has not been addressed by the Supreme Court or any circuit court in the psilocybin context specifically. The closest analogous situation, Title VII claims by medical cannabis users, has generally been resolved against the employee on the ground that the employer’s obligation to comply with federal law constitutes an undue hardship precluding accommodation. Whether the same reasoning would apply to religious psilocybin use may depend on whether the employer carries a legally mandated drug-free workplace obligation and on the specific strength and sincerity of the religious claim presented. This appears to be genuinely unresolved doctrine, and this article does not attempt to predict how it would be decided.

VII. The Disclosure Dilemma

A. The Catch-22

The most acute problem raised by this body of law may be the situation of an employee who uses psilocybin therapeutically, through a state-licensed service center or through self-administration informed by the clinical research on psilocybin for mental health conditions, and who wishes to request workplace accommodation for the underlying mental health condition. This employee faces a disclosure dilemma that has no clean legal resolution under current law.

Consider a specific scenario: an employee with treatment-resistant depression has accessed psilocybin therapy at an Oregon licensed service center, has experienced significant remission of depressive symptoms, and continues to access service center sessions periodically. This employee has a qualifying disability (major depressive disorder), has used a treatment that is state-lawful and supported by clinical research as potentially effective, and may wish to disclose the treatment to an employer in connection with a leave request, reduced schedule, or other accommodation for integration periods following service center sessions. Under current law, this disclosure triggers the ADA’s illegal drug use exclusion: an employer may be able to terminate the employee’s ADA-protected status as to any subsequent adverse action taken on the basis of the disclosed psilocybin use.

This doctrinal structure may produce an outcome that sits in tension with the therapeutic policy goals Oregon and Colorado pursued in creating licensed service center frameworks. An employee who accesses psilocybin services specifically to address a mental health condition that qualifies for ADA protection may effectively be forced to choose between employment protection under the ADA and the ability to disclose therapeutic treatment to an employer. Oregon Measure 109 was framed around the potential mental health benefits of psilocybin services; the ADA’s illegal drug use exclusion could be read as that policy’s federal counterpart, a structural tension arising from the federal-state divide on psilocybin’s legal status that may persist until either psilocybin is rescheduled below Schedule I or Congress amends the ADA’s illegal drug use exclusion to account for state-licensed therapeutic use. This is an inference from the structure of the statutes rather than a conclusion any court has reached, and it should be read with that caveat.

B. A Possible Sequencing Approach

In the absence of a federal legislative or regulatory solution, one option worth considering is careful sequencing of disclosure. The underlying mental health disability, depression, PTSD, anxiety disorder, could potentially be disclosed to an employer without disclosing the specific treatment modality. An employee might be able to request accommodation for treatment-resistant depression without identifying psilocybin as the treatment. The employer’s right to a medical inquiry in the ADA interactive process appears limited to information necessary to understand the disability and evaluate potential accommodations; on this reading, the employer would not be entitled to know the specific treatment the employee is using.

This approach might allow an employee to preserve ADA protection for the underlying disability while not triggering the illegal drug use exclusion through voluntary disclosure of the treatment itself. It is not a permanent or guaranteed solution. If the employer discovers the psilocybin use through other means, the ADA exclusion would likely still apply. It also has not been tested by any court, and no authority currently confirms that this sequencing would hold up if challenged. It may nonetheless represent one of the more cautious positions available under current law.

The disclosure dilemma may be among the more likely near-term sources of employment litigation in the psychedelic sector. As state-licensed psilocybin services mature, as the clinical evidence base for psilocybin’s mental health efficacy develops further, and as more employed professionals access those services, the tension between the therapeutic access framework and the ADA’s illegal drug use exclusion could generate cases in which employees who disclosed their treatment lose ADA protection for the underlying disability claim as a consequence. Such cases, if they arise, may press courts and Congress to address this doctrinal gap, a gap that could plausibly be addressed proactively, through legislative attention to a state-licensed therapeutic use exception to the ADA’s illegal drug use exclusion, rather than left to be resolved through adversarial litigation after harm has already occurred.

VIII. Considerations for Regulators and Legislators

The tensions traced in this article suggest several areas where legislative or regulatory attention could reduce the uncertainty currently facing employees, employers, and the state-licensed psilocybin service framework itself. These are offered as considerations for policymakers rather than as predictions of how any body will act.

1. Congress may wish to consider a state-licensed therapeutic use exception to 42 U.S.C. § 12114. A narrowly drawn amendment addressing psilocybin use obtained through a state-licensed service center could address the disclosure dilemma directly, without disturbing the illegal drug use exclusion as applied to unregulated or non-therapeutic use. Any such amendment would presumably need to define “state-licensed therapeutic use” carefully to avoid extending protection to microdosing practices that fall outside a licensed service center framework.

1. Federal agencies responsible for workplace drug-testing panels could consider whether the SAMHSA and DOT panels should be revisited in light of the growing use of psilocybin in licensed therapeutic contexts, though any such change would raise independent safety-sensitive-position considerations that regulators would need to weigh carefully, particularly for DOT-covered positions.

1. State legislatures that have licensed psilocybin service centers may want to examine whether an employment protection framework analogous to existing state cannabis statutes should be considered, and if so, how such a framework might address the safety-sensitive carve-outs and federal-preemption concerns that have shaped the cannabis employment statutes to date.

1. Agencies overseeing state-licensed psilocybin programs could consider whether facilitator documentation practices might be adjusted to support employees seeking to establish a disability diagnosis without necessarily documenting the specific treatment modality, which could give employees more flexibility in how they approach the ADA interactive process.

1. The EEOC or DOJ could consider issuing interpretive guidance addressing how the illegal drug use exclusion applies to state-licensed therapeutic use of Schedule I substances, similar to existing guidance on opioid use disorder, which might reduce inconsistent case-by-case outcomes as more employees encounter this issue.

None of these represent existing law; they are offered as possible directions raised by the doctrinal gap this article identifies, and their feasibility would depend on considerations, political, administrative, and constitutional, well beyond the scope of this article.

IX. Conclusion

Psilocybin microdosing presents a body of law that is largely categorical in its terms but practically difficult to observe in application. The legal analysis, as traced above, points toward a fairly consistent picture: psilocybin is Schedule I, its use falls within the ADA’s illegal drug use exclusion, federal drug-free workplace obligations cover it, and no state employment protection currently extends to it. At the same time, the practical visibility of this use seems limited: the substance is not on the standard testing panel, sub-perceptual use is unlikely to produce behavioral cues, and it seems plausible that a large share of microdosing employees go undetected. If this reading is correct, the legal exposure may be severe even as the detection risk remains comparatively low.

The disclosure dilemma developed in Part VII may be the most specific and actionable observation this article offers, though it remains an inference rather than a settled rule. An employee with treatment-resistant depression who accesses Oregon’s state-licensed psilocybin services and discloses that treatment in order to obtain ADA accommodation for the underlying disability may, under current law, be found to have relinquished ADA protection for any subsequent adverse action based on the disclosed use. The sequencing approach discussed above, disclosing the disability without the specific treatment, may be among the more cautious options available under current law, though it has not been tested by any court and offers no guarantee of protection. Legislative attention to a state-licensed therapeutic use exception to the ADA’s illegal drug use exclusion may represent a more durable, longer-term response to the structural gap this article identifies, though this inference cannot be stated with the confidence that a formal legislative or regulatory resolution would provide.

Endnotes

1. Americans with Disabilities Act of 1990, Pub. L. 101-336, 104 Stat. 327 (July 26, 1990), codified as amended at 42 U.S.C. §§ 12101–12213; ADA Amendments Act of 2008, Pub. L. 110-325, 122 Stat. 3553 (Sept. 25, 2008); 42 U.S.C. § 12114(a) (“a qualified individual with a disability shall not include any employee or applicant who is currently engaging in the illegal use of drugs, when the covered entity acts on the basis of such use”), https://www.law.cornell.edu/uscode/text/42/12114; 42 U.S.C. § 12111(6)(A) (definition of “illegal use of drugs” incorporates CSA); 42 U.S.C. § 12111(6)(B) (health care professional exception), https://www.law.cornell.edu/uscode/text/42/12111; DOJ, The ADA and Opioid Use Disorder (defining “currently engaging in illegal use of drugs” as use “recently enough to justify a reasonable belief that a person’s drug use is current”), https://www.ada.gov/resources/opioid-use-disorder/.

1. Shafer v. Preston Mem’l Hosp. Corp., 107 F.3d 274 (4th Cir. 1997) (diversion of Fentanyl, a Schedule II narcotic, occurring in weeks and months prior to discharge held sufficiently recent to establish “currently engaging in” exclusion); Wallace v. Veterans Administration, 683 F. Supp. 758 (D. Kan. 1988) (intermittent prior cannabis use constituted “currently engaging” even when most recent use not contemporaneous with termination); 21 U.S.C. § 812(c)(Schedule I)(d)(1) (psilocybin listed as Schedule I hallucinogen).

1. Drug-Free Workplace Act of 1988, Pub. L. 100-690, tit. V, subtit. D, 102 Stat. 4181 (codified at 41 U.S.C. §§ 8101–8106), https://uscode.house.gov/view.xhtml?path=%2Fprelim%40title41%2Fsubtitle4%2Fchapter81&edition=prelim; Exec. Order No. 12564, 51 Fed. Reg. 32889 (Sept. 17, 1986) (Drug-Free Federal Workplace); HHS, Mandatory Guidelines for Federal Workplace Drug Testing Programs Using Urine, 88 Fed. Reg. 70768 (Oct. 12, 2023) (effective Feb. 1, 2024); SAMHSA, Mandatory Guidelines — Authorized Testing Panels, 91 Fed. Reg. 12308 (Mar. 13, 2026) (effective July 7, 2025; adding fentanyl; psilocybin not included), https://www.federalregister.gov/documents/2026/03/13/2026-04981/mandatory-guidelines-for-federal-workplace-drug-testing-programs-authorized-testing-panels; 49 C.F.R. Part 40 (DOT drug testing procedures), https://www.ecfr.gov/current/title-49/subtitle-A/part-40; 49 C.F.R. §§ 40.85, 40.87 (DOT five-panel specifications); 49 C.F.R. § 382.307 (FMCSA reasonable suspicion testing standard).

1. Cal. Gov. Code § 12954, https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=12954.&lawCode=GOV (as amended by AB 2188, ch. 723, 2022 Cal. Stat., effective Jan. 1, 2024); N.Y. Lab. Law § 201-d, https://www.nysenate.gov/legislation/laws/LAB/201-D; Coats v. Dish Network, LLC, 350 P.3d 849 (Colo. 2015) (off-duty cannabis use not protected by lawful activities statute where cannabis not federally lawful); Groff v. DeJoy, 600 U.S. 447 (2023) (Title VII undue hardship standard: “substantial increased costs in relation to the conduct of [the employer’s] particular business”), https://supreme.justia.com/cases/federal/us/600/22-174/; RFRA, 42 U.S.C. §§ 2000bb–2000bb-4; Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 546 U.S. 418 (2006) (Roberts, C.J., unanimous) (RFRA compelling interest test applied to specific religious claimant), https://supreme.justia.com/cases/federal/us/546/418/; 42 U.S.C. § 2000e-2 (Title VII), https://www.law.cornell.edu/uscode/text/42/2000e-2; ORS 475A (Oregon Psilocybin Services Act; psilocybin services not medical treatment), https://www.oregonlegislature.gov/bills_laws/ors/ors475A.html; Minn. Stat. § 181.950 (as amended by S.F. 2370, effective May 24, 2025, adding 14-day notice requirement before adverse action against registered medical cannabis users).