—concluding that no medical necessity defense exists for the illegal distribution of marijuana because the Controlled Substances Act "reflects a determination that marijuana has no medical benefits worthy of an exception

There, the Supreme Court held that there is no medical necessity exception to the CSA's prohibition on the manufacture and distribution of marijuana.

Under federal law, marijuana is a Schedule I substance that cannot be dispensed and prescribed for medicinal use

—concluding that "a medical necessity exception for marijuana is at odds with the terms of the Controlled Substances Act

The Supreme Court has ruled that "when district courts are properly acting as courts of equity, they have discretion unless a statute clearly provides otherwise."

The Court held "that medical necessity is not a defense to manufacturing and distributing marijuana."

I] t is an open question whether federal courts ever have authority to recognize a necessity defense not provided by statute

—holding that "the canon of constitutional avoidance has no application in the absence of statutory ambiguity

The Supreme Court has since explained that the drastic result in Hill stemmed from the strong and undisputed showing of irreparable harm that would occur absent an injunction: an entire species would become extinct.

After all, "a court sitting in equity cannot ignore the judgment of Congress deliberately expressed in legislation. A district court cannot, for example, override Congress's policy choice, articulated in a statute, as to what behavior should be prohibited."