Rastafarian's Marijuana Suit dismissed On Jurisdictional Grounds

In Brown v. United States, 2007 U.S. Dist. LEXIS 65015 (MD FL, Sept. 4, 2007), a Florida federal district court dismissed declaratory judgment action brought by a practicing Rastafarian who uses marijuana as a holy sacrament. Plaintiff asked to court to rule that Florida's exclusion of violations of its Drug Abuse and Prevention Law from the state's Religious Freedom Restoration Act amounts to favoritism of some religions over others. The court dismissed the case under the Rooker-Feldman doctrine, finding that plaintiff had lost virtually identical claims in Florida state courts. The court also found no case or controversy existed since "Plaintiff is simply seeking a declaration ... as to what legal analysis the Florida courts should use in the off-chance he is arrested for growing, using, and/or distributing marijuana..."