With Lionel Messi, he divided the football world from the late 2000s to the 2010s, and even in his late 30s, he showed world-class skills and fought for the world's best place for 15 years. In the evaluation of various media conducted until 2017, it was ranked up to 4th 소년을 위로해줘 드라마 다시보기 1화-2화-3화place [23], and since 2020, its status has risen further and has been ranked up to 3rd place.[24] In the evaluation of various major media, Ronaldo and Johan Cruyff form an average of 4th to 5th place.[25] Accordingly, he is regarded as one of the best players in European football history[26] and one of the best scorers in football history.
5 Ballon d'Or winners, 3 consecutive Champions League victories, and a hat-trick in the 2018 Russia World Cup match against Spain, he received admiration and praise from various media and legends. It was evaluated as the 5th place of all time after [27], and it was said that there is a possibility that it will rise to the 3rd place 소년을 위로해줘 드라마 다시보기 1화-2화-3화depending on his active life in the future. [28]
His playing style has changed several times as he moved Manchester United FC, Real Madrid CF, and Juventus FC, but he is proving why he is world class by performing outstandingly in any role in any position. During his Manchester United days, he was the best winger ever in the EPL[29], and as the best winger and striker ever [30] during his Real Madrid days, he showed all-time 소년을 위로해줘 드라마 다시보기 1화-2화-3화performance no matter what role he played. His performances at Juventus are also showing class. Despite transferring at the age of 33, who had come down from his heyday, he still changed Serie A records with a sense of scoring, achieved his first championship and even collected trophies in Serie A, winning three major leagues[31] and scoring in the third year He won the king and achieved the feat of being the top 3 league scorer [32].
Especially noteworthy is the tournament record. It is said that he is strong in so-called big games, but Ronaldo's record in these tournaments is directly related to the team's victory. Unlike the league, even if one game was sluggish, it could be the cause of the team's elimination, but it consistently showed a strong appearance in the tournament and shows the appearance of saving the team when it is in crisis. In 21st century European football, the status of the Champions League in club careers is rated higher than the 소년을 위로해줘 드라마 다시보기 1화-2화-3화double (League + Cup), so Ronaldo's appearance as a tournament powerhouse is also being reevaluated.[33] In particular, he is showing off his strength in the Champions League for nearly 10 years, showing off his strong side against strong teams by scoring several goals against strong teams that have dominated other leagues for several years.
In the past, it was evaluated that the performance of the national team was disappointing, but in 2016, Portugal achieved the UEFA Euro championship as the first major tournament trophy in history, and in the 2018-19 season, it won the UEFA Nations League and won two consecutive European national competitions. It has 소년을 위로해줘 드라마 다시보기 1화-2화-3화become a thing of the past. Currently, he is leading the best golden era as the best player in the history of the Portuguese national football team. In particular, it was selected as the All Time Best 11 at the UEFA Euro, and in the UEFA Nations League, all three goals scored by Ronaldo in the semifinals were selected as the top 3 best goals of the tournament. In the A-match match, he has also scored 118 goals, the highest number of A-match goals in football history.[34] However, the main evaluation was that his performance in the World Cup was not 소년을 위로해줘 드라마 다시보기 1화-2화-3화worthy of the name, and his World Cup career record was not bad with 8 goals and 2 assists, but the blemish that he had no offensive points in the World Cup tournament remained. There is no World Cup individual award other than the 2018 World Cup Dream Team, so his career on the World Cup stage is clearly declining.
However, it is not an exaggeration to say that his career is brilliant, except for his career in a single competition, the World Cup. Manchester United FC won the Premier League and UEFA 소년을 위로해줘 드라마 다시보기 1화-2화-3화Champions League by leading the heyday, gave Real Madrid CF its first ever three Champions League titles and won all competitions he played in La Liga, and as a member of Juventus FC, he won Serie A. He grabbed both the team award [35] and the individual award [36] that could be given in the . With this, he not only achieved the conquest of Europe's top three leagues, but also became the best player in the history of the competition through his performance in the top European competition, the UEFA Champions League. Moving his attention to the national team as well as the club team, he has had a great소년을 위로해줘 드라마 다시보기 1화-2화-3화 career. This is because he won the UEFA European Championship for the first time with the Portuguese national football team, won the first championship in the newly created UEFA Nations League, and won two consecutive national competitions.
In particular, by winning the Euro to Portugal, which was not considered a favorite at the time, and by defeating the strongest teams in each league in the Champions League, the initial stigma of being a good student or a colleague was quelled, and he was confident as a player who was strong in big games, big stages and strong teams. completely overturned the evaluation of In addition, as soon as Ronaldo left Real Madrid, Real Madrid struggled with sluggishness for the first time in decades, and even the world-famous Real Madrid CF Galactico Corps, which achieved three 소년을 위로해줘 드라마 다시보기 1화-2화-3화consecutive Champions League titles together, was thanks to Ronaldo's strength. Soccer fans, various media and soccer legends There were many evaluations.
In fact, Ronaldo's career has already written tremendous records that are incomparable to the majority of strikers on his individual basis, and in itself has a degree of perfection that can be recognized by many. Just because Lionel Messi is the target of 소년을 위로해줘 드라마 다시보기 1화-2화-3화comparison in the proposition, "Who is the best player of all time?"
In the end, due to the aging curve that came rapidly from the 22-23 season, the rudeness shown by his team Manchester United FC without accepting it, and the failure to remain in major European leagues in the subsequent transfer market [37], Ronaldo was in a rivalry with Messi. It fell behind by an even greater gap.[38] Not only in terms of comparison with Messi, but also as an individual player, the progress he shows in his later years leaves a greater 소년을 위로해줘 드라마 다시보기 1화-2화-3화regret as it is enough to cut down the brilliant career he has built so far. This contrasts with the precedent in which Zlatan Ibrahimovic, who played the same position in the previous season, made a significant contribution to AC Milan's league championship at the age of 40. In the same 소년을 위로해줘 드라마 다시보기 1화-2화-3화season, Dani Alves, just before 40, returned at the request of FC Barcelona and signed a contract with a salary close to unpaid considering the team's financial difficulties, and also showed outstanding performance in the game. Aside from the fact that Ronaldo's status is by no means lower than the above two players, the fact that only Ronaldo is showing a uniquely contrasting late age among players of the same level acts as a very large negative factor in his evaluation.
Gyere és játsz velünk! Hány számot, dallamot, grúvot, bármi ilyesmit ismersz fel az elkövetkezendő egy órában? Kösd fel a füled, hiszen majdnem száz szám hangzik el, kevesebb mint egy óra alatt!
Spoilerek és számcímek következnek:
0:00 Scorpions - Wind Of Change
0:28 Nino Rota - The Godfather Theme
0:33 Tomayasu Hotei - Battle Without Honor Or Humanity
0:58 Abba - Dancing Queen (Dj Deckstream Version)
1:39 Bobby Hebb - Sunny
2:51 ATB - 9 Pm (Till I Come)
3:24 Kenny Dope Pres. The Mad Racket - Supa (Deep In Brooklyn Mix)
3:41 Kaláka - Magyar Népmesék
4:04 Lou Reed - Walk In the Wilde Side
4:18 Paul Mc Douglas - Theme From Dallas
4:43 Red Hot Chili Peppers - Danni California
4:51 Suzane Vega - Tom's Dinner
5:10 Joan Osborne - One Of Us
5:28 The Bangles - Manic Monday
5:37 Elton John - Imagine
6:10 Hot Chocolate - You Sexy Thing
6:54 Red Hot Chili Peppers - Can’t Stop
7:17 Wax Tailor - Positively Inclined
7:52 Hans Hammerschmid - Die Schwarzwaldklinik
8:15 Rolling Stones - You Can't Always Get What You Want
9:02 Run D.M.C. - Sucker MC’s
9:20 Elton John - Sacrifice
9:23 G.L.O.B.E. & Whiz Kid - Play that Beat Mr. D.J
9:59 Janet Jackson - Nasty
10:58 A Tribe Called Quest - Can I Kick It?
11:25 Red Hot Chili Peppers - Californication
11:37 Red Hot Chili Peppers - Scar Tissue
12:21 George Benson - Breezin’
13:07 Blackstreet - No Diggity (Smov & Dedy Dread’s No Diggin’)
13:35 John Barry - James Bond Theme
14:16 Henry Manchini - Peter Gunn Theme
15:35 Genesis - I Can’t Dance
15:39 Daft Punk - Lose Yourself To Dance
18:00 Rigo Tovar - Mi Testemanto
19:01 Daft Punk - Da Funk
19:10 Deep Purple - Smoke On The Water
19:27 Usher - Yeah!
20:24 Nirvana - Smeels Like Teen Spirit
20:46 Jackson 5 - I Want You Back
21:21 Beastie Boys - Hey Ladies
21:56 Skrillex - Bangarang
22:10 Deep Purple - Burn
22:45 Gorillaz - 19-2000
24:00 The Champs - Tequila
24:23 Queen - Another Bites Of Dust
24:36 Queen - We Will Rock You
25:13 INXS - Need You Tonight
25:38 The Braids - Bohemian Rhapsody
26:03 Queen - Bohemian Rhapsody
29:11 Queen - I Want To Break Free
29:45 Kool & The Gang - Hollywood Swinging
29:54 The Queen Kings - Another Bites Of Dust
30:20 Red Hot Chili Peppers - Snow (Hey Oh)
30:36 Eagle Eye Cherry - Save Tonight
31:03 Chemical Brothers - Galvanize
31:12 Blue Boy - Remember Me
32:00 John Williams - Imperial March Theme
32:27 Pink Floyd - Another Brick On The Wall
32:31 Bee Gees - Stayin Alive
33:33 Röyksopp - Eple
34:10 Eric B & Rakim - Don’t Sweat The Technique
35:14 Röyksopp - Eple (Fat Boy Slim Remix)
35:29 Ten Yeas After - Love Like A Man
36:02 Aretha Franklin - Rock Steady (Fdel’s Rocksteady)
37:08 Stevie Wonder - Superstition
37:33 Stu Phillips - Knight Rider Theme (Dave Allison Edit)
38:25 Vaya Con Dios - Nah Neh Nah
39:18 Tom Dissevelt & Kid Baltan - Song Of The Second Moon
39:46 Mark Snow - The X Files Theme
40:17 Paul McDoughas - Theme From Dallas (Disco Version)
40:58 Lips Inc - Funkytown
41:16 Tom Jones - Kiss
42:06 AC/DC - Thunderstuck
43:09 Black Machine - How Gee
44:36 Rolling Stones - Brown Sugar
45:03 Ray Parker Jr - Ghostbusters
46:14 Mike Post & Pete Carpenter - Theme From Magnum P.I
46:20 Run Dmc Vs Jason Nevins - It’s Like That
46:21 Tag Team - Whoomp, There It Is
46:27 Kraftwerk - The Robots
46:54 Elvis - Little Less Conservation
47:31 Led Zeppelin - Whole Lotta Love
48:04 Lilly Wood & The Prick - Prayer in C (Robin Schulz Remix)
48:26 Red Hot Chili Peppers - Otherside
48:55 Guns ’n’ Roses - Sweet Child Of Mine
50:07 David Stewart & Candy Dulfer - Lily Was Here
51:16 Ennio Morricone - La Resa Dei Conti
51:39 Eagles - One Of These Nights
54:04 Madonna - Like A Prayer
54:24 Beethowen - Moonlight Sonata (Ringmad125’s Remix)
54:50 Eagles - Hotel California
56:08 Maria Callas - L'altra Notte In Fondo Al Mare
56:35 The Piano Guys - Moonlight
58:32 Francis Lai - Theme From Love Story
59:01 Pécsi József - Dörmögő Dömötör, Istók Gazda Udvarán
A felvétel a jeles Babka Budapest felső szintjén készült, valamikor idén februárban, Tarr Dávid gitáros kellemes társaságában. A felvételről azt kell tudni hogy élő, és ami él, az a maga módján mindig tökéletes, de főleg a hibáival együtt. A dj béna, a gitár hangolódik, a zenész fárad, az este telik. Teljesen véletlenül ezt az estét sikerült viszonylag elfogadható minőségben felvenni, és ebben az órában még technikai problémák se voltak; ó a technika is él, pláne ha élők nyomkodják; ebbe más is belehalt már.
Dávidról pedig azt kell tudni, hogy amikor egy francia túrista részegen elkezdi ordibálni hogy BABÚÚÚÚÚÚZÉÉ ÓÓ, akkor ő egyből bólint, hogy oké, Gipsy King, és már játsza is a Bambó Leót. Bármilyen hangnemben, bármilyen tempóban, bármire. Ja és gitározott a Boney-M-be, igen, abba a Boney-M-be, Daddy Cool, meg minden; ezt még mindig nem akarom elhinni neki, pedig a telefonjában is benne van, azt meg lehet tudni, hogy az ember telefonja sose hazudik.
Imádok vele játszani, pedig valójában iszonyú fárasztó; annyi ötlete van, hogy néha már azt érzem, nem is neki támadnak ötletei, hanem az ötetletek támadnak neki, ő meg hagyja magát. Nem áltatom magam azzal, hogy akár a töredékét is felfognám annak az elképesztő zenei tudásnak, amit vigyorogva belenyom a gitárjába; a legjobb esetben is csak minden ötödik grúvot ismerem meg, de már arról is annyi minden eszembe jut, és azok általában annyira vad ötletek, hogy muszáj kipróbálni.
Az ötlet nem más, mint farkaséhség. Elfojtott vágy. Az ötletes embernél nincs veszélyesebb a világon, mert hajlandó kockáztatni. Járt utat az ötleteidért fiam, el ne hagyd! Az az ötletem támadt, hogy játszunk kellemes jazzes hiphopot, és kevesebb mint egy óra után azon kapom magam, hogy Beethovent játszok dubsteppel.
A borító egy művészetpedagógiai foglalkozáson készült, de művészet és pedagógia nélkül is mindig jó móka szavak nélkül beszélgetni.
Mint a legtöbb asszociációs játék, ehhez is legalább ketten jó ha vagytok; egyikőtök elkezd rajzolni valamit, ami eszébe jut, törekedve arra, hogy ne emelje fel a kezét, és az ő vonalát folytatja a másik, ugyanígy.
És olyan nincs hogy nem tudsz rajzolni; én például tényleg nem tudok. De a rajz is a meditáció egy formája, vagy szelep a meg nem született gondolatok számára, ezeket a szelepeket meg jó ha nyitogatod, legalább szellőzik ami odabent marad.
Egyszer, réges régen, amikor még a kétfarkú is a Kertembe járt, nem hogy a Panda, meg amikor még volt egyáltalán Kertem, szóval nem mostanában, odajött hozzám egy szép leány. Pont Emmanuel Top török bazárját kevertem Z’zi Labor és a Veresegyházi Asszonykórus válallhatatlan Rolling Stones feldolgozásával, és a Prodigy pofozkodásával, amire ráhúztam a kacsamesék zseniális basszusfunkját. Még szerencse hogy csak négy deck van, ugye. Csillogtak a fények, koccantak a sörök, szép este volt, úgy éreztem elememben vagyok. Gyere csak, te szép leány, megmutatom a felhőimet, számot is kérhetsz ha elkérhetem a számod, és hasonló huncutságok. Minden dj ugyanolyan, fekete-fehér, ezt jobb ha tőlem tudjátok.
Pedig elhinni, hogy egy szórakozóhelyen rátalálhatsz az igazira, az kábé olyan, mintha
Tényleg te vagy a Dj Panda?
Aha, ragyotam boldogan.
‘Ó pedig reménykedtem hogy csak valami félreértés lesz, azért akartam ellenőrizni. Tudod egy időben sokat hallgattam az egyik mixedet, és nem akartam elhinni hogy ez a kommersz szar is te vagy.’
Pedig szép szája volt, erre határozottan emlékszem.
‘Hát, na mindegy, én biztosan bánnám a helyedben hogy ide jutottam’, mondta az a bizonyos szép száj, és elment a tulajdonsával együtt.
Mindig is jó kapcsolatot ápoltam a rajongóimmal.
Már vége lett a Smack My Bitch Upnak, és lett némi csönd, mire megtaláltam a bosszúmat; gyere Edit, Piaf! Olyan bús zavart voltam, hogy nem kevertem semmivel, magában ment le, csak úgy egyszerűen, semmi gombnyomogatás. Közhely, közhely, röhej.
Ma már egyébként hiphop boyzt játszanék egy ilyen helyzetben, de ma már nincsenek ilyen helyzetek, ma már csak a kommersz szar van, a művészet kilovagolt Budapestről, mögötte vágtattak lobogó hajjal a szép leányok.
Most például már az első szám Abba! Ó bárcsak előbb hagytam volna abba, nem jutottam volna el eddig a rémes rímek és a kínos slágerekig. Ushert játszok basszus! És még Beatles sincs, hogy mentse a menthetőt.
Szerencse, hogy a telefonomon rajta van már a MEGBÁNÁS alkalmazás. Megkérdezhetem tőle, hogy megbánjam-e, hogy ide jutottam.
HOVA, kérdezi az app.
Oda, hogy egy tök hangulatos vendéglátói intézményben egy zseniálisan perverz gitárossal azon röhögünk, hogy a Magyar Népmeséknek ugyanaz a köre mint a Dallasnak, és emiatt elfelejtek Beatlest játszani.
NE AGGÓDJ, HELYESEN DÖNTÖTTÉL, így az app.
Egyébként mindig ezt mondja.
A MEGBÁNÁSnak az a célja, hogy boldogabbá tegye a világot. A boldogtalanságot egyfelől a megbánás, másfelől a jövőtől való rettegés táplálja. Ahogy szaporodnak a lehetőségek, annál bonyolutabbá vált az élet. Az emberek az egyik világban élnek, de mellette létezik egymillió másik világ, amelyben élhetnének. Az emberek számtalan kihagyott életút miatt érezhetnek megbánást.
Minden egyes kihagyott lehetőség a jelent terheli. És itt még nincs vége. A jövőben új választások milliói adódnak majd, és minden millióból újabb millió következik. Amikor végül megszületik egy döntés, valami rendkívüli dolog történik. Minden nem választott opció megbánássá alakul. Következésképpen az emberek folyamatosan a jövő súlya és a múlt nyomása közé szorulva sínylődnek, és ez soha nem fordul jobbra. A választások sokasodnak, a megbánás ezzel egyenes arányban növekedik, míg végül az emberek mozdulni sem tudnak, annyira belegabalyodnak a láthatatlan hálóba. Ekkor jön a felmentő MEGBÁNÁS, (már elérhető minden rendszeren, keresd az online áruházakban!) és rendbe rakja a múltat. A MEGBÁNÁS szerint az ember minden egyes döntése az egyetlen helyes döntés. Minden egyes ember élete veszélyben forog, és épphogy megmenekült az EGYETLEN HELYES döntést meghozva. Így kötelességünk örülni. Hiszen mindennek dacára, még mindig életben vagyunk.
Tại vòng 7 Premier League, Liverpool sẽ được chơi trên sân nhà Anfield, trong cuộc tiếp đón đối thủ Wolves. Một trận đấu mà giới soi kèo bóng đá đánh giá là vô cùng khó khăn cho chủ nhà Liverpool.
Soi kèo bóng đá trận Liverpool vs Wolves, 21h00 ngày 10/09/2022
Liverpool sẽ trở về Premier League để so tài với Wolves, vào thứ 5 đoàn quân của Jurgen Klopp đã có trận đấu mở màn tại UEFA Champions League. Và Á quân của giải đấu đã phải làm khách trên sân của Napoli. Đó là một trận đấu mà hàng phòng ngự của Liverpool thi đấu như mơ ngủ, và để cho đối thủ xuyên thủng mành lưới của Alisson Becker tới 4 lần chỉ sau 46 phút thi đấu. Bàn thắng danh dự của Luiz Diaz ở phút thứ 49 là không đủ để cho The Kop tránh khỏi một trận thua tủi hổ.
Phía bên kia chiến tuyến, Wolves sẽ là đội có ưu thế hơn khi không phải thi đấu tại Cúp Châu Âu. Ở vòng đấu trước Bầy sói đã có chiến thắng tối thiểu trước Southampton để tạm leo lên vị trí thứ 14 trên BXH. Đó cũng chính là trận thắng của Wolves tại mùa giải năm nay. Đoàn quân của HLV Bruno Nascimento đang thể hiện một phong độ rất ấn tượng. Nhất là ở hàng phòng ngự, họ đã giữ sạch lưới trong 2 trận gần nhất.
Chuyến làm khách trên sân Anfield sẽ là một thử thách khó khăn cho Wolves. Tuy nhiên, với phong độ hiện tại của Liverpool thì đội khách hoàn toàn có thể tạo nên bất ngờ trong trận đấu này. Một kết quả hòa sẽ là mục tiêu của thẩy trò Bruno Nascimento trong màn so tài lần này.
Phong độ thi đấu gần đây của Liverpool vs Wolves
Phong độ của Liverpool
- 08/09/2022 Napoli 4-1 Liverpool
- 03/09/2022 Everton 0-0 Liverpool
- 01/09/2022 Liverpool 2-1 Newcastle
- 27/08/2022 Liverpool 9-0 AFC Bournemouth
- 23/08/2022 Manchester United 2-1 Liverpool
The Kop chỉ thắng 2/5 trận đấu gần nhất của mình
Phong độ của Wolves
- 03/09/2022 Wolves 1-0 Southampton
- 01/09/2022 AFC Bournemouth 0-0 Wolves
- 28/08/2022 Wolves 1-1 Newcastle
- 24/08/2022 Wolves 2-1 Preston North End
- 20/08/2022 Tottenham Hotspur 1-0 Wolves
Wolves đã bất bại trong 4 trận đấu gần nhất của mình, trong đó có tới 2 chiến thắng.
Lịch sử trận đấu giữa Liverpool vs Wolves
- 22/05/2022 Liverpool 3-1 Wolves
- 04/12/2021 Wolves 0-1 Liverpool
- 16/03/2021 Wolves 0-1 Liverpool
Liverpool đã giành chiến thắng trong 3 lần gần nhất đối đầu với Wolves, trong đó có 2/3 trận đấu kết thúc với tỉ số tối thiểu.
Tỷ lệ chấp trận Liverpool vs Wolves: 1.5 trái
Liverpool đang không có được phong độ tốt nhất trong thời gian gần đây. Nhất là ở mặt trận tấn công, nơi mà Mohamed Salah và Darwin Nunez vẫn chưa có được cảm giác tốt nhất. Điều đó được thể hiện rõ nhất trong 2 trận đấu giữa Napoli và Everton. Phong độ đấu kèo Châu Á của Liverpool cũng rất thất, chỉ là 20% (chỉ thắng 1/5 loại kèo Châu Á gần nhất).
Trong khi đó, Wolves cho thấy sự khó chịu của mình khi đã bất bại trong 4 trận gần nhất. Và 2/3 lần gần nhất gặp mặt Liverpool, bầy sói chỉ khuất phục với tỉ số tối thiểu. Vì vậy, Wolves sẽ là đội bóng đáng chú ý hơn trong kèo đấu này khi chơi tại nhà cái Bong88 từ trang chính thức Bong88pro.com.
Dự đoán: Liverpool 1-1 Wolves
Tỷ lệ tài/xỉu trận Liverpool vs Wolves: 3 trái
Đội khách Wolves đã kết thúc 12 trận đấu gần nhất của mình với không quá 2 bàn thắng được ghi. Và họ cũng đang là đội bóng sở hữu hàng phòng ngự tốt nhất tại EPL tính đến thời điểm hiện tại.
Chỉ để thua 4 bàn sau 6 trận đầu tiên, điều này sẽ mang lại rất nhiều khó khăn cho hàng tấn công của Liverpool. 4/6 lần gần nhất hai đội gặp nhau đã kết thúc với không quá 3 bàn được ghi. Vì vậy, dự đoán trận đấu này Wolves sẽ chủ động chơi phòng ngự phản công trước Liverpool, và sẽ không có quá nhiều bàn thắng được ghi.
Dự đoán: Tổng số bàn thắng 2 – chọn Xỉu
Dự kiến đội hình ra sân thi đấu
Wolves: Sa; Jonny; Collins, Kilman, Ait-Nouri; Nunes, Neves, Moutinho; Podence, Jimenez, Neto.
Liverpool: Alisson, Alexander-Arnold, Gomez, Van Dijk, Robertson,Elliott, Fabinho, Henderson, Salah, Firmino, Diaz.
Bài soi kèo trận trận Liverpool vs Wolves ngày 10/09, dự đoán đội chủ nhà sẽ có một trận đấu khó khăn trước Wolves. Và trận đấu sẽ kết thúc với một kết quả hòa khi mà Bầy sói đang có được một phong độ rất cao.
Người chơi cũng nên khám phá thêm phương pháp và cách quản lý thời gian trong cá độ bóng đá để có thể nhận định chuẩn nhất trong trận đấu này.
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Guest Post: Marijuana: Big Opportunities and Challenges for Insurers
Paul T. Curley
One of the more interesting businesses to emerge in recent years has been the legal marijuana industry. Because of lingering legal issues, this industry’s emergence has been accompanied by a host of complications. These complications in turn raise a number of challenges for insurers seeking to get involving in this industry. In the following guest post, Paul T. Curley takes a look at the opportunities and challenges for insurers in connection with the legal marijuana industry. Paul is a partner in the Insurance Coverage and Coverage Litigation Group at Kaufman Borgeest & Ryan LLP. I would like to thank Paul for allowing me to publish his article as a guest post on this site. I welcome guest post submissions from responsible authors on topics of interest to this blog’s readers. Please contact me directly if you would like to submit a guest post. Here is Paul’s article.
*********************************
The legal marijuana industry is booming, and so is the need for insurance for industry participants. This article discusses some of the opportunities and challenges for insurers presented by this thriving industry.
First Of All, Is It “Cannabis” Or “Marijuana”?
Cannabis is a family of plants, and marijuana is a primary species within that family. Hemp is the other primary species. The main difference between marijuana and hemp is the level of THC: marijuana typically contains anywhere from 15-40% THC, whereas hemp contains no more than 0.3% THC, which is too low to create a psychoactive effect. Hemp also contains cannabidiol (CBD), which is used in hundreds of products (tinctures, topicals, capsules, beverages, etc.) that are marketed for the treatment of various ailments, including epilepsy, anxiety, inflammation, and sleeplessness. This article focuses on marijuana, leaving hemp and CBD-infused products for another day.[i]
So, What Are The Opportunities?
As of this writing, 33 states and the District of Columbia have passed laws legalizing marijuana in some form. DC and 10 of the states have legalized marijuana for both medicinal and recreational (aka adult) use. The other 23 states allow only for medical use under various circumstances. It is anticipated that 2019 will see more states legalize marijuana.
Increased legalization has resulted in soaring marijuana sales, the creation of new businesses, and tremendous job growth. According to recent reports:
in 2018, legal marijuana sales increased 34% in the U.S. to $10.8 billion;
sales are forecast to grow to $24 billion by 2021;
the legal marijuana industry now provides more than 211,000 full-time jobs, up from 120,000 in 2017; and
in 2017, there were as many as 28,000 marijuana-related businesses in the U.S.
Generally speaking, companies in the marijuana industry can be separated into two categories: plant-touching and ancillary. Plant-touching companies actually handle marijuana and include cultivators (aka growers), distributors, laboratories, extractors, processors, product manufacturers, and dispensaries (i.e., retail stores). Ancillary companies, which do not handle marijuana, support the plant-touching businesses and provide products and services such as grow equipment, greenhouses, extraction equipment, consumption devices, bottling, packaging, branding, compliance, consulting, physical security, point-of-sale software, transportation, and media.
As more and more states legalize marijuana in some fashion, the industry is undergoing rapid growth and presents a huge underwriting opportunity for insurers that offer coverages such as D&O, E&O, EPL, CGL, property, fidelity/crime, product liability, cyber, crops, and commercial auto.
Sounds Great, But What Are The Challenges?
Perhaps the first thing insurers must get comfortable with is the fact that it is illegal under federal law to use, sell or possess marijuana because it is a Schedule I drug under the Controlled Substances Act of 1970 (the CSA).
Given the illegal status of marijuana under federal law, plant-touching companies, which use, sell, and/or possess marijuana, are subject to federal criminal prosecution under the CSA. As for ancillary businesses that support the plant-touching industry, they potentially are subject to federal criminal prosecution for violations of the CSA, aiding and abetting, and money laundering.
That being said, the federal government has yet to crack-down on participants in the legal marijuana industry and, indeed, has shown a tolerance of such businesses, albeit in a somewhat conflicting fashion. For example, in 2013, former U.S. Attorney General James Comey issued a memo (the Cole Memo) that urged federal prosecutors to refrain from targeting state-legal marijuana operations. However, in 2018, then U.S. Attorney General Jeff Sessions rescinded the Cole Memo. Also, in February 2019, President Trump signed a federal budget that contains an amendment that prevents the DOJ from using funds to stop states from implementing their medical marijuana laws (the so-called Rohrabacher-Blumenauer Amendment). In signing the budget, however, Trump added a statement that advised that “I will treat [the Rohrabacher-Blumenauer Amendment] consistently with my constitutional responsibility to take care that the laws be faithfully executed.”
Besides potential federal criminal prosecution of industry participants, other underwriting concerns include product liability claims (which have been made against cultivators and dispensaries), lack of banking opportunities for plant-touching businesses (federally chartered banks are reluctant to accept cash from a business that is illegal under federal law), the prevalence of large amounts of cash (given the lack of banking relationships), crop/inventory theft or damage, business interruption (wildfires, for example, can destroy a crop and disrupt the whole chain of distribution), cyber threats to customers’ personal information (especially medical marijuana dispensaries that store customers’ medical data), claims by disgruntled investors (including crowd funders, private equity, and venture capital), extensive regulatory compliance, RICO claims by property owners against cultivators and distributors alleging decreased property values from odors, the lack of claims data, and the absence of a robust body of case law addressing coverage under marijuana insurance policies.
Speaking Of Case Law, What Do Courts Think Of Marijuana Insurance?
Considering the legal marijuana industry is relatively young, it’s not surprising that there are few coverage decisions. And, as discussed below, they are a mixed bag.
In Tracy v. USAA Cas. Ins. Co., No. 11-00487, 2012 U.S. Dist. LEXIS 35913 (D. Haw. Mar. 16, 2012), plaintiff was a homeowner who grew marijuana at home for her personal medical use as allowed under Hawaii’s medical marijuana law. Someone stole her plants and she filed a claim under her homeowners insurance policy, which the insurer denied. In siding with the insurer, the Court held that, even if the policy covers plaintiff’s medical marijuana plants, the “Court cannot enforce the [insurance policy] because Plaintiff’s possession and cultivation of marijuana, even for State-authorized medical use, clearly violates federal law. To require Defendant to pay insurance proceeds for the replacement of medical marijuana plants would be contrary to federal law and public policy, as reflected in the CSA, Gonzales [a U.S. Supreme Court decision], and its progeny.” Id. at *39.
A few years later, however, a federal court in Colorado reached the opposite conclusion in Green Earth Wellness Ctr., LLC v. Atain Specialty Ins. Co., 163 F. Supp. 3d 821 (D. Col. Feb. 17, 2016). Green Earth ran a legal grow operation and dispensary. Smoke and ash from a wildfire damaged both its potted plants and its harvested buds.[ii] Green Earth submitted a claim under its commercial property and general liability policy, and the insurer denied the claim. The Court first addressed coverage for the potted plants, noting that the policy provided coverage for “Stock,” which includes raw materials, but excludes coverage for “growing crops.” The Court held that even if the potted plants could be considered raw materials, they nonetheless also were growing crops and therefore excluded from coverage.
The Court next addressed the harvested buds, which the parties agreed were “finished product” and therefore covered Stock. The insurer, however, argued that coverage for the buds was barred (i) by an exclusion for Contraband and (ii) as against public policy. The Court disagreed.
First, the Court found that the Contraband exclusion was ambiguous and that extrinsic evidence compelled the conclusion that the parties shared a mutual intention that the policy would insure Green Earth’s inventory and that the Contraband exclusion would not apply to it. In finding the exclusion ambiguous, the Court noted that “federal authorities had made public statements that reflected an ambivalence towards enforcement of the Controlled Substances Act in circumstances where a person or entity’s possession and distribution of marijuana was consistent with well-regulated state law.” Id. at 833. The Court held that “the Policy’s ‘Contraband’ exclusion is rendered ambiguous by the difference between the federal government’s de jure and de facto public policies regarding state-regulated medical marijuana.” Id.
Second, for the same reasons the Court found the Contraband exclusion ambiguous, “and particularly in light of several additional years evidencing a continued erosion of any clear and consistent federal public policy in this area,” the Court declined to declare the policy void on public policy grounds and, in doing so, explicitly rejected Tracy.
Finally, in K.V.G. Props., Inc. v. Westfield Ins. Co., 900 F.3d 818 (6th Cir. 2018), the Court found the application of a criminal/dishonest acts exclusion to be a close call but ultimately found it barred coverage. KVG is a commercial landlord and rented properties to a tenant who, unbeknownst to KVG, used them to grow marijuana. The tenant surreptitiously made alterations to the property, causing about $500,000 in damages. Eventually, the DEA raided the properties, KVG evicted the tenants, and KVG made a claim under its commercial property policy for the damages, which the insurer denied. In a straight forward fashion, the District Court found that coverage was precluded by the criminal/dishonest acts exclusion. The Court of Appeals, however, took a more nuanced approached, noting that “whether the tenants committed a ‘criminal act’ within the meaning of the policy . . . is an interesting question” considering the conflict between federal law and Michigan law, which, at the time, allowed for medical marijuana (and now also allows for recreational marijuana). Id. at 821. The Court of Appeals advised that “we would hesitate before reading a Michigan insurance policy to bar coverage for a ‘criminal act’ when Michigan law confers criminal and civil immunity for the conduct at issue.” Id. at 822. The problem for KVG, however, was that there was no evidence in the record that its tenants were growing marijuana in compliance with Michigan law. Indeed, in the eviction proceedings, KVG argued the exact opposite. Accordingly, the Court of Appeals found the criminal/dishonest acts exclusion barred coverage but noted that “[u]nder different circumstances, KVG might have a strong federalism argument in favor of coverage.” Id. at 821-22.
To recap the coverage decisions: one found it would be against public policy to cover the claim (Tracy), one rejected application of a Contraband exclusion and a public policy argument (Green Earth), and one upheld application of a criminal/dishonest acts exclusion but very well could have rejected the coverage defense if the grow operation had been legal under state law (KVG). It seems fair to say that this limited and conflicting case law offers little guidance to both insurers and insureds.
Wrap-Up
While approximately 25 insurers (mostly nonadmitted) offer coverage to industry participants, most major insurers have opted out, with federal illegality being the main stumbling block. If and when the federal government officially allows for the use, sale and possession of marijuana, it is expected that many more insurers will join the market. That day may not be too far off, given the numerous bills recently introduced into Congress that seek to address the issue by, for example, removing cannabis from Schedule I of the CSA, prohibiting federal prosecution, and/or leaving it up to the states to decide. Until then, however, it seems most insurers will continue to monitor the situation and maintain a wait and see approach.
_________________________
[i] And they deserve additional discussion given the recent passage of the 2018 Farm Bill, which drastically changed hemp policy in the United States, allowing for greatly expanded hemp cultivation and creating exceptions to CBD’s Schedule I status (so that CBD products may be sold legally in interstate commerce). The hemp and CBD industries are expected to enjoy tremendous growth as a result of the 2018 Farm Bill – presenting additional opportunities and challenges for insurers.
[ii] The potted plants included “mother plants” and “clones.” As explained by the Court, mother plants “are plants of each individual strain of marijuana that Green Earth offers. Mother plants are not cultivated to produce useable marijuana on their own; rather, they are maintained by the grower solely for the purpose of producing a constant and reliable supply of genetically-identical ‘clones.’ A clone is a portion of the mother plant that is cut off and planted in a growing medium until it produces its own root, becoming a viable marijuana plant in its own right. The clones then grow to maturity. . . . At the appropriate time, the grower harvests the flowering clone, cutting off flowers and buds (and sometimes other portions of the plants), drying that material, and selling it.” Id. at 826.
The post Guest Post: Marijuana: Big Opportunities and Challenges for Insurers appeared first on The D&O Diary.
Guest Post: Marijuana: Big Opportunities and Challenges for Insurers syndicated from https://ronenkurzfeldweb.wordpress.com/
Guest Post: Marijuana: Big Opportunities and Challenges for Insurers
Paul T. Curley
One of the more interesting businesses to emerge in recent years has been the legal marijuana industry. Because of lingering legal issues, this industry’s emergence has been accompanied by a host of complications. These complications in turn raise a number of challenges for insurers seeking to get involving in this industry. In the following guest post, Paul T. Curley takes a look at the opportunities and challenges for insurers in connection with the legal marijuana industry. Paul is a partner in the Insurance Coverage and Coverage Litigation Group at Kaufman Borgeest & Ryan LLP. I would like to thank Paul for allowing me to publish his article as a guest post on this site. I welcome guest post submissions from responsible authors on topics of interest to this blog’s readers. Please contact me directly if you would like to submit a guest post. Here is Paul’s article.
*********************************
The legal marijuana industry is booming, and so is the need for insurance for industry participants. This article discusses some of the opportunities and challenges for insurers presented by this thriving industry.
First Of All, Is It “Cannabis” Or “Marijuana”?
Cannabis is a family of plants, and marijuana is a primary species within that family. Hemp is the other primary species. The main difference between marijuana and hemp is the level of THC: marijuana typically contains anywhere from 15-40% THC, whereas hemp contains no more than 0.3% THC, which is too low to create a psychoactive effect. Hemp also contains cannabidiol (CBD), which is used in hundreds of products (tinctures, topicals, capsules, beverages, etc.) that are marketed for the treatment of various ailments, including epilepsy, anxiety, inflammation, and sleeplessness. This article focuses on marijuana, leaving hemp and CBD-infused products for another day.[i]
So, What Are The Opportunities?
As of this writing, 33 states and the District of Columbia have passed laws legalizing marijuana in some form. DC and 10 of the states have legalized marijuana for both medicinal and recreational (aka adult) use. The other 23 states allow only for medical use under various circumstances. It is anticipated that 2019 will see more states legalize marijuana.
Increased legalization has resulted in soaring marijuana sales, the creation of new businesses, and tremendous job growth. According to recent reports:
in 2018, legal marijuana sales increased 34% in the U.S. to $10.8 billion;
sales are forecast to grow to $24 billion by 2021;
the legal marijuana industry now provides more than 211,000 full-time jobs, up from 120,000 in 2017; and
in 2017, there were as many as 28,000 marijuana-related businesses in the U.S.
Generally speaking, companies in the marijuana industry can be separated into two categories: plant-touching and ancillary. Plant-touching companies actually handle marijuana and include cultivators (aka growers), distributors, laboratories, extractors, processors, product manufacturers, and dispensaries (i.e., retail stores). Ancillary companies, which do not handle marijuana, support the plant-touching businesses and provide products and services such as grow equipment, greenhouses, extraction equipment, consumption devices, bottling, packaging, branding, compliance, consulting, physical security, point-of-sale software, transportation, and media.
As more and more states legalize marijuana in some fashion, the industry is undergoing rapid growth and presents a huge underwriting opportunity for insurers that offer coverages such as D&O, E&O, EPL, CGL, property, fidelity/crime, product liability, cyber, crops, and commercial auto.
Sounds Great, But What Are The Challenges?
Perhaps the first thing insurers must get comfortable with is the fact that it is illegal under federal law to use, sell or possess marijuana because it is a Schedule I drug under the Controlled Substances Act of 1970 (the CSA).
Given the illegal status of marijuana under federal law, plant-touching companies, which use, sell, and/or possess marijuana, are subject to federal criminal prosecution under the CSA. As for ancillary businesses that support the plant-touching industry, they potentially are subject to federal criminal prosecution for violations of the CSA, aiding and abetting, and money laundering.
That being said, the federal government has yet to crack-down on participants in the legal marijuana industry and, indeed, has shown a tolerance of such businesses, albeit in a somewhat conflicting fashion. For example, in 2013, former U.S. Attorney General James Comey issued a memo (the Cole Memo) that urged federal prosecutors to refrain from targeting state-legal marijuana operations. However, in 2018, then U.S. Attorney General Jeff Sessions rescinded the Cole Memo. Also, in February 2019, President Trump signed a federal budget that contains an amendment that prevents the DOJ from using funds to stop states from implementing their medical marijuana laws (the so-called Rohrabacher-Blumenauer Amendment). In signing the budget, however, Trump added a statement that advised that “I will treat [the Rohrabacher-Blumenauer Amendment] consistently with my constitutional responsibility to take care that the laws be faithfully executed.”
Besides potential federal criminal prosecution of industry participants, other underwriting concerns include product liability claims (which have been made against cultivators and dispensaries), lack of banking opportunities for plant-touching businesses (federally chartered banks are reluctant to accept cash from a business that is illegal under federal law), the prevalence of large amounts of cash (given the lack of banking relationships), crop/inventory theft or damage, business interruption (wildfires, for example, can destroy a crop and disrupt the whole chain of distribution), cyber threats to customers’ personal information (especially medical marijuana dispensaries that store customers’ medical data), claims by disgruntled investors (including crowd funders, private equity, and venture capital), extensive regulatory compliance, RICO claims by property owners against cultivators and distributors alleging decreased property values from odors, the lack of claims data, and the absence of a robust body of case law addressing coverage under marijuana insurance policies.
Speaking Of Case Law, What Do Courts Think Of Marijuana Insurance?
Considering the legal marijuana industry is relatively young, it’s not surprising that there are few coverage decisions. And, as discussed below, they are a mixed bag.
In Tracy v. USAA Cas. Ins. Co., No. 11-00487, 2012 U.S. Dist. LEXIS 35913 (D. Haw. Mar. 16, 2012), plaintiff was a homeowner who grew marijuana at home for her personal medical use as allowed under Hawaii’s medical marijuana law. Someone stole her plants and she filed a claim under her homeowners insurance policy, which the insurer denied. In siding with the insurer, the Court held that, even if the policy covers plaintiff’s medical marijuana plants, the “Court cannot enforce the [insurance policy] because Plaintiff’s possession and cultivation of marijuana, even for State-authorized medical use, clearly violates federal law. To require Defendant to pay insurance proceeds for the replacement of medical marijuana plants would be contrary to federal law and public policy, as reflected in the CSA, Gonzales [a U.S. Supreme Court decision], and its progeny.” Id. at *39.
A few years later, however, a federal court in Colorado reached the opposite conclusion in Green Earth Wellness Ctr., LLC v. Atain Specialty Ins. Co., 163 F. Supp. 3d 821 (D. Col. Feb. 17, 2016). Green Earth ran a legal grow operation and dispensary. Smoke and ash from a wildfire damaged both its potted plants and its harvested buds.[ii] Green Earth submitted a claim under its commercial property and general liability policy, and the insurer denied the claim. The Court first addressed coverage for the potted plants, noting that the policy provided coverage for “Stock,” which includes raw materials, but excludes coverage for “growing crops.” The Court held that even if the potted plants could be considered raw materials, they nonetheless also were growing crops and therefore excluded from coverage.
The Court next addressed the harvested buds, which the parties agreed were “finished product” and therefore covered Stock. The insurer, however, argued that coverage for the buds was barred (i) by an exclusion for Contraband and (ii) as against public policy. The Court disagreed.
First, the Court found that the Contraband exclusion was ambiguous and that extrinsic evidence compelled the conclusion that the parties shared a mutual intention that the policy would insure Green Earth’s inventory and that the Contraband exclusion would not apply to it. In finding the exclusion ambiguous, the Court noted that “federal authorities had made public statements that reflected an ambivalence towards enforcement of the Controlled Substances Act in circumstances where a person or entity’s possession and distribution of marijuana was consistent with well-regulated state law.” Id. at 833. The Court held that “the Policy’s ‘Contraband’ exclusion is rendered ambiguous by the difference between the federal government’s de jure and de facto public policies regarding state-regulated medical marijuana.” Id.
Second, for the same reasons the Court found the Contraband exclusion ambiguous, “and particularly in light of several additional years evidencing a continued erosion of any clear and consistent federal public policy in this area,” the Court declined to declare the policy void on public policy grounds and, in doing so, explicitly rejected Tracy.
Finally, in K.V.G. Props., Inc. v. Westfield Ins. Co., 900 F.3d 818 (6th Cir. 2018), the Court found the application of a criminal/dishonest acts exclusion to be a close call but ultimately found it barred coverage. KVG is a commercial landlord and rented properties to a tenant who, unbeknownst to KVG, used them to grow marijuana. The tenant surreptitiously made alterations to the property, causing about $500,000 in damages. Eventually, the DEA raided the properties, KVG evicted the tenants, and KVG made a claim under its commercial property policy for the damages, which the insurer denied. In a straight forward fashion, the District Court found that coverage was precluded by the criminal/dishonest acts exclusion. The Court of Appeals, however, took a more nuanced approached, noting that “whether the tenants committed a ‘criminal act’ within the meaning of the policy . . . is an interesting question” considering the conflict between federal law and Michigan law, which, at the time, allowed for medical marijuana (and now also allows for recreational marijuana). Id. at 821. The Court of Appeals advised that “we would hesitate before reading a Michigan insurance policy to bar coverage for a ‘criminal act’ when Michigan law confers criminal and civil immunity for the conduct at issue.” Id. at 822. The problem for KVG, however, was that there was no evidence in the record that its tenants were growing marijuana in compliance with Michigan law. Indeed, in the eviction proceedings, KVG argued the exact opposite. Accordingly, the Court of Appeals found the criminal/dishonest acts exclusion barred coverage but noted that “[u]nder different circumstances, KVG might have a strong federalism argument in favor of coverage.” Id. at 821-22.
To recap the coverage decisions: one found it would be against public policy to cover the claim (Tracy), one rejected application of a Contraband exclusion and a public policy argument (Green Earth), and one upheld application of a criminal/dishonest acts exclusion but very well could have rejected the coverage defense if the grow operation had been legal under state law (KVG). It seems fair to say that this limited and conflicting case law offers little guidance to both insurers and insureds.
Wrap-Up
While approximately 25 insurers (mostly nonadmitted) offer coverage to industry participants, most major insurers have opted out, with federal illegality being the main stumbling block. If and when the federal government officially allows for the use, sale and possession of marijuana, it is expected that many more insurers will join the market. That day may not be too far off, given the numerous bills recently introduced into Congress that seek to address the issue by, for example, removing cannabis from Schedule I of the CSA, prohibiting federal prosecution, and/or leaving it up to the states to decide. Until then, however, it seems most insurers will continue to monitor the situation and maintain a wait and see approach.
_________________________
[i] And they deserve additional discussion given the recent passage of the 2018 Farm Bill, which drastically changed hemp policy in the United States, allowing for greatly expanded hemp cultivation and creating exceptions to CBD’s Schedule I status (so that CBD products may be sold legally in interstate commerce). The hemp and CBD industries are expected to enjoy tremendous growth as a result of the 2018 Farm Bill – presenting additional opportunities and challenges for insurers.
[ii] The potted plants included “mother plants” and “clones.” As explained by the Court, mother plants “are plants of each individual strain of marijuana that Green Earth offers. Mother plants are not cultivated to produce useable marijuana on their own; rather, they are maintained by the grower solely for the purpose of producing a constant and reliable supply of genetically-identical ‘clones.’ A clone is a portion of the mother plant that is cut off and planted in a growing medium until it produces its own root, becoming a viable marijuana plant in its own right. The clones then grow to maturity. . . . At the appropriate time, the grower harvests the flowering clone, cutting off flowers and buds (and sometimes other portions of the plants), drying that material, and selling it.” Id. at 826.
The post Guest Post: Marijuana: Big Opportunities and Challenges for Insurers appeared first on The D&O Diary.
Guest Post: Marijuana: Big Opportunities and Challenges for Insurers published first on
Guest Post: Marijuana: Big Opportunities and Challenges for Insurers
Paul T. Curley
One of the more interesting businesses to emerge in recent years has been the legal marijuana industry. Because of lingering legal issues, this industry’s emergence has been accompanied by a host of complications. These complications in turn raise a number of challenges for insurers seeking to get involving in this industry. In the following guest post, Paul T. Curley takes a look at the opportunities and challenges for insurers in connection with the legal marijuana industry. Paul is a partner in the Insurance Coverage and Coverage Litigation Group at Kaufman Borgeest & Ryan LLP. I would like to thank Paul for allowing me to publish his article as a guest post on this site. I welcome guest post submissions from responsible authors on topics of interest to this blog’s readers. Please contact me directly if you would like to submit a guest post. Here is Paul’s article.
*********************************
The legal marijuana industry is booming, and so is the need for insurance for industry participants. This article discusses some of the opportunities and challenges for insurers presented by this thriving industry.
First Of All, Is It “Cannabis” Or “Marijuana”?
Cannabis is a family of plants, and marijuana is a primary species within that family. Hemp is the other primary species. The main difference between marijuana and hemp is the level of THC: marijuana typically contains anywhere from 15-40% THC, whereas hemp contains no more than 0.3% THC, which is too low to create a psychoactive effect. Hemp also contains cannabidiol (CBD), which is used in hundreds of products (tinctures, topicals, capsules, beverages, etc.) that are marketed for the treatment of various ailments, including epilepsy, anxiety, inflammation, and sleeplessness. This article focuses on marijuana, leaving hemp and CBD-infused products for another day.[i]
So, What Are The Opportunities?
As of this writing, 33 states and the District of Columbia have passed laws legalizing marijuana in some form. DC and 10 of the states have legalized marijuana for both medicinal and recreational (aka adult) use. The other 23 states allow only for medical use under various circumstances. It is anticipated that 2019 will see more states legalize marijuana.
Increased legalization has resulted in soaring marijuana sales, the creation of new businesses, and tremendous job growth. According to recent reports:
in 2018, legal marijuana sales increased 34% in the U.S. to $10.8 billion;
sales are forecast to grow to $24 billion by 2021;
the legal marijuana industry now provides more than 211,000 full-time jobs, up from 120,000 in 2017; and
in 2017, there were as many as 28,000 marijuana-related businesses in the U.S.
Generally speaking, companies in the marijuana industry can be separated into two categories: plant-touching and ancillary. Plant-touching companies actually handle marijuana and include cultivators (aka growers), distributors, laboratories, extractors, processors, product manufacturers, and dispensaries (i.e., retail stores). Ancillary companies, which do not handle marijuana, support the plant-touching businesses and provide products and services such as grow equipment, greenhouses, extraction equipment, consumption devices, bottling, packaging, branding, compliance, consulting, physical security, point-of-sale software, transportation, and media.
As more and more states legalize marijuana in some fashion, the industry is undergoing rapid growth and presents a huge underwriting opportunity for insurers that offer coverages such as D&O, E&O, EPL, CGL, property, fidelity/crime, product liability, cyber, crops, and commercial auto.
Sounds Great, But What Are The Challenges?
Perhaps the first thing insurers must get comfortable with is the fact that it is illegal under federal law to use, sell or possess marijuana because it is a Schedule I drug under the Controlled Substances Act of 1970 (the CSA).
Given the illegal status of marijuana under federal law, plant-touching companies, which use, sell, and/or possess marijuana, are subject to federal criminal prosecution under the CSA. As for ancillary businesses that support the plant-touching industry, they potentially are subject to federal criminal prosecution for violations of the CSA, aiding and abetting, and money laundering.
That being said, the federal government has yet to crack-down on participants in the legal marijuana industry and, indeed, has shown a tolerance of such businesses, albeit in a somewhat conflicting fashion. For example, in 2013, former U.S. Attorney General James Comey issued a memo (the Cole Memo) that urged federal prosecutors to refrain from targeting state-legal marijuana operations. However, in 2018, then U.S. Attorney General Jeff Sessions rescinded the Cole Memo. Also, in February 2019, President Trump signed a federal budget that contains an amendment that prevents the DOJ from using funds to stop states from implementing their medical marijuana laws (the so-called Rohrabacher-Blumenauer Amendment). In signing the budget, however, Trump added a statement that advised that “I will treat [the Rohrabacher-Blumenauer Amendment] consistently with my constitutional responsibility to take care that the laws be faithfully executed.”
Besides potential federal criminal prosecution of industry participants, other underwriting concerns include product liability claims (which have been made against cultivators and dispensaries), lack of banking opportunities for plant-touching businesses (federally chartered banks are reluctant to accept cash from a business that is illegal under federal law), the prevalence of large amounts of cash (given the lack of banking relationships), crop/inventory theft or damage, business interruption (wildfires, for example, can destroy a crop and disrupt the whole chain of distribution), cyber threats to customers’ personal information (especially medical marijuana dispensaries that store customers’ medical data), claims by disgruntled investors (including crowd funders, private equity, and venture capital), extensive regulatory compliance, RICO claims by property owners against cultivators and distributors alleging decreased property values from odors, the lack of claims data, and the absence of a robust body of case law addressing coverage under marijuana insurance policies.
Speaking Of Case Law, What Do Courts Think Of Marijuana Insurance?
Considering the legal marijuana industry is relatively young, it’s not surprising that there are few coverage decisions. And, as discussed below, they are a mixed bag.
In Tracy v. USAA Cas. Ins. Co., No. 11-00487, 2012 U.S. Dist. LEXIS 35913 (D. Haw. Mar. 16, 2012), plaintiff was a homeowner who grew marijuana at home for her personal medical use as allowed under Hawaii’s medical marijuana law. Someone stole her plants and she filed a claim under her homeowners insurance policy, which the insurer denied. In siding with the insurer, the Court held that, even if the policy covers plaintiff’s medical marijuana plants, the “Court cannot enforce the [insurance policy] because Plaintiff’s possession and cultivation of marijuana, even for State-authorized medical use, clearly violates federal law. To require Defendant to pay insurance proceeds for the replacement of medical marijuana plants would be contrary to federal law and public policy, as reflected in the CSA, Gonzales [a U.S. Supreme Court decision], and its progeny.” Id. at *39.
A few years later, however, a federal court in Colorado reached the opposite conclusion in Green Earth Wellness Ctr., LLC v. Atain Specialty Ins. Co., 163 F. Supp. 3d 821 (D. Col. Feb. 17, 2016). Green Earth ran a legal grow operation and dispensary. Smoke and ash from a wildfire damaged both its potted plants and its harvested buds.[ii] Green Earth submitted a claim under its commercial property and general liability policy, and the insurer denied the claim. The Court first addressed coverage for the potted plants, noting that the policy provided coverage for “Stock,” which includes raw materials, but excludes coverage for “growing crops.” The Court held that even if the potted plants could be considered raw materials, they nonetheless also were growing crops and therefore excluded from coverage.
The Court next addressed the harvested buds, which the parties agreed were “finished product” and therefore covered Stock. The insurer, however, argued that coverage for the buds was barred (i) by an exclusion for Contraband and (ii) as against public policy. The Court disagreed.
First, the Court found that the Contraband exclusion was ambiguous and that extrinsic evidence compelled the conclusion that the parties shared a mutual intention that the policy would insure Green Earth’s inventory and that the Contraband exclusion would not apply to it. In finding the exclusion ambiguous, the Court noted that “federal authorities had made public statements that reflected an ambivalence towards enforcement of the Controlled Substances Act in circumstances where a person or entity’s possession and distribution of marijuana was consistent with well-regulated state law.” Id. at 833. The Court held that “the Policy’s ‘Contraband’ exclusion is rendered ambiguous by the difference between the federal government’s de jure and de facto public policies regarding state-regulated medical marijuana.” Id.
Second, for the same reasons the Court found the Contraband exclusion ambiguous, “and particularly in light of several additional years evidencing a continued erosion of any clear and consistent federal public policy in this area,” the Court declined to declare the policy void on public policy grounds and, in doing so, explicitly rejected Tracy.
Finally, in K.V.G. Props., Inc. v. Westfield Ins. Co., 900 F.3d 818 (6th Cir. 2018), the Court found the application of a criminal/dishonest acts exclusion to be a close call but ultimately found it barred coverage. KVG is a commercial landlord and rented properties to a tenant who, unbeknownst to KVG, used them to grow marijuana. The tenant surreptitiously made alterations to the property, causing about $500,000 in damages. Eventually, the DEA raided the properties, KVG evicted the tenants, and KVG made a claim under its commercial property policy for the damages, which the insurer denied. In a straight forward fashion, the District Court found that coverage was precluded by the criminal/dishonest acts exclusion. The Court of Appeals, however, took a more nuanced approached, noting that “whether the tenants committed a ‘criminal act’ within the meaning of the policy . . . is an interesting question” considering the conflict between federal law and Michigan law, which, at the time, allowed for medical marijuana (and now also allows for recreational marijuana). Id. at 821. The Court of Appeals advised that “we would hesitate before reading a Michigan insurance policy to bar coverage for a ‘criminal act’ when Michigan law confers criminal and civil immunity for the conduct at issue.” Id. at 822. The problem for KVG, however, was that there was no evidence in the record that its tenants were growing marijuana in compliance with Michigan law. Indeed, in the eviction proceedings, KVG argued the exact opposite. Accordingly, the Court of Appeals found the criminal/dishonest acts exclusion barred coverage but noted that “[u]nder different circumstances, KVG might have a strong federalism argument in favor of coverage.” Id. at 821-22.
To recap the coverage decisions: one found it would be against public policy to cover the claim (Tracy), one rejected application of a Contraband exclusion and a public policy argument (Green Earth), and one upheld application of a criminal/dishonest acts exclusion but very well could have rejected the coverage defense if the grow operation had been legal under state law (KVG). It seems fair to say that this limited and conflicting case law offers little guidance to both insurers and insureds.
Wrap-Up
While approximately 25 insurers (mostly nonadmitted) offer coverage to industry participants, most major insurers have opted out, with federal illegality being the main stumbling block. If and when the federal government officially allows for the use, sale and possession of marijuana, it is expected that many more insurers will join the market. That day may not be too far off, given the numerous bills recently introduced into Congress that seek to address the issue by, for example, removing cannabis from Schedule I of the CSA, prohibiting federal prosecution, and/or leaving it up to the states to decide. Until then, however, it seems most insurers will continue to monitor the situation and maintain a wait and see approach.
_________________________
[i] And they deserve additional discussion given the recent passage of the 2018 Farm Bill, which drastically changed hemp policy in the United States, allowing for greatly expanded hemp cultivation and creating exceptions to CBD’s Schedule I status (so that CBD products may be sold legally in interstate commerce). The hemp and CBD industries are expected to enjoy tremendous growth as a result of the 2018 Farm Bill – presenting additional opportunities and challenges for insurers.
[ii] The potted plants included “mother plants” and “clones.” As explained by the Court, mother plants “are plants of each individual strain of marijuana that Green Earth offers. Mother plants are not cultivated to produce useable marijuana on their own; rather, they are maintained by the grower solely for the purpose of producing a constant and reliable supply of genetically-identical ‘clones.’ A clone is a portion of the mother plant that is cut off and planted in a growing medium until it produces its own root, becoming a viable marijuana plant in its own right. The clones then grow to maturity. . . . At the appropriate time, the grower harvests the flowering clone, cutting off flowers and buds (and sometimes other portions of the plants), drying that material, and selling it.” Id. at 826.
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Through Benjamin Newman Created on: December 24, 2017 eight:24 am Remaining Up to date: December 24, 2017 eight:24 am
Everton Zero – Chelsea Zero
Sam Allardyce maintained his unbeaten document at Everton on Saturday towards Chelsea.
Large Sam has recorded 4 wins and two attracts since he was once appointed as Ronald Koeman’s successor.
Chelsea arguably had the simpler probabilities at Goodison Park with out discovering the objective.
Eden Danger got here on the subject of breaking the impasse, whilst Ashley Williams despatched a header onto his personal bar within the ultimate phases of the sport.
A l’symbol de ce tir d’@hazardeden10, @ChelseaFC n’a pas trouvé l. a. faille en déplacement à @Everton (Zero-Zero) http://pic.twitter.com/dHvDuO9ye2
— VOOsport (@VOOsport) December 23, 2017
The outcome left Chelsea 3rd within the desk, 3 issues at the back of Guy United. Everton moved as much as 9th with 26 issues from 19 video games.
Idrissa Gueye & Phil Jagielka
However, whilst Everton stored their unbeaten Large Sam document intact towards Chelsea, the Toffees did undergo two damage blows.
The primary was once to key midfielder Idrissa Gueye.
Gueye is Everton’s highest defensive defend in the course of the park, however he’ll most probably be out of motion for the Christmas duration. Certainly, Allardyce has prompt Gueye will omit Everton’s subsequent 4 fixtures after he limped out of the Chelsea fit.
Beni Baningime changed Gueye after he perceived to tweak his hamstring towards the Blues.
“The disappointing factor about an damage is [Gueye] misses four video games even though he’s again in 2 weeks,” stated Allardyce. “Somebody getting injured now misses an enormous quantity of video games. Within the subsequent 13 days we are going to play four suits – if somebody will get injured they omit they all.” #EFC
— Ben Dinnery (@BenDinnery) December 23, 2017
Centre part Phil Jagielka may be sidelined after the Chelsea sport. Whilst the defender finished the 90 mins, the veteran appeared to undergo an unspecified knock towards the Pensioners.
Jagielka more likely to omit the shuttle to the Hawthorns. “I don’t suppose I can be making an allowance for him for West Brom,” stated Allardyce. “This time will likely be difficult however some avid gamers must step on top of things.” #EFC
— Ben Dinnery (@BenDinnery) December 23, 2017
West Brom vs Everton
West Brom host Everton on Boxing Day on the Hawthorns.
Will Alan Pardew dissatisfied Allardyce by way of recording his first Premier League win with the Baggies?
Albion have been as soon as once more crushed on Saturday within the EPL as Stoke recorded a Three-1 house win.
The outcome left West Brom 2nd backside of the league, whilst Stoke jumped as much as 14th within the department.
Additionally see: Tottenham’s Guy United & Everton January offers.
Horror information for Everton striker Henry Onyekuru.
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Bowel cancer is the development of cancer from the bowel or colon. A cancer is the abnormal growth of cells that have the ability to invade or spread to other parts of the body. Signs and symptoms may include blood in the stool, a change in bowel movements, weight loss, and feeling tired all the time. Most diagnosis are due to old age and lifestyle factors with only a small number of cases due genetic disorders.
Cause
Most cases are caused by no link to genetic risk. Risk factors include older age, being male, high intake of fat, alcohol, red meat, processed meats, obesity, smoking, and a lack of physical exercise.
People with ulcerative colitis and Crohn’s disease are at increased risk the risk increases the longer a person has the disease, and the worse the severity of inflammation.
Genetic syndromes are also associated with higher rates of colorectal cancer such as: hereditary nonpolyposis colorectal cancer (HNPCC or Lynch syndrome), Gardner syndrome and familial adenomatous polyposis (FAP).
Diagnosis
PET, MRI and CT scans are usually used which then it used in partner with the TNM system which produces staging results using T stages:
Or Duke’s stages:
Surgery
If the cancer is found at a very early stage, small and localised it may be removed during a colonoscopy. , with the attempt of achieving a cure. This can either be done by an open laparotomy or sometimes laparoscopically. The colon may then be reconnected or a person may have a colostomy. Sometimes chemotherapy is used before surgery to shrink the cancer before attempting to remove it. The two most common sites of recurrence of colorectal cancer are the liver and lungs.
In both cancer of the colon, chemotherapy may be used in addition to surgery in certain cases. In Stage I colon cancer, no chemotherapy is offered, and surgery is the treatment. In Stage II colon cancer is and is usually not offered. For stage III and Stage IV colon cancer, chemotherapy is an integral part of treatment. If cancer has spread to the lymph nodes or distant organs, which is the case with stage III and stage IV colon cancer respectively, adding chemotherapy agents increases life expectancy. If the lymph nodes do not contain cancer, the benefits of chemotherapy are debatable. If the cancer is widely metastatic or unresectable, treatment is then palliative.
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