Independent MMTC License Rejection Review in select states

Were you denied your medical marijuana license in select states?

We've successfully consulted with and testified for growers, processors, and distributors of medical cannabis.

A rejection is not always the end of the story. In many cases, the outcome turns on how scores were calculated, combined, and ranked — not simply on the underlying quality of the application. A focused expert review can help you decide, before deadlines pass, whether a challenge is warranted.

Request Consultation Share the basic details of your license denial in select states and receive a confidential, expert-level assessment of your options.

Who we help when a license rejection threatens your strategy

YOU OR A CLIENT have had an application to grow, process, or distribute medical cannabis rejected. Market Consulting Corporation may be able to help.

For many operators and investors, an MMTC or comparable license is the cornerstone of a long-term plan. When a single scoring round determines who participates in the market — and who is locked out — it is critical to understand whether that decision rests on solid quantitative ground.

Typical clients

  • Growers, processors, and distributors seeking MMTC or equivalent licenses.
  • Existing operators expanding into new jurisdictions.
  • Law firms representing multiple denied applicants.
  • Investor groups evaluating appeal-based acquisition opportunities.

Questions we help you answer

  • Did the evaluators apply the scoring rules consistently?
  • Are there obvious numerical or ranking anomalies?
  • How strong is the quantitative basis for an appeal in select states?

A focused first step

A consultation is not about re-writing your application. It is about understanding whether the numerical and structural design of the contest itself — the scoring model, the aggregation, the ranking rules — provides a credible basis to challenge the outcome.

If the data support a challenge, you and your counsel can move forward with confidence. If they do not, you avoid investing time and resources in a weak case.

Start with a data-driven review →

Why strong applications still lose

State licensing procedures vary tremendously. While some state Departments of Health (or their equivalent) issue medical marijuana licenses to nearly all who apply, others require competition among candidates that results in a license for only a small segment of those who apply. Such is the case in Florida, where the Department of Health recently awarded 22 licenses, a number well less than how many applications they received, and fewer than many expected.

In these competitive frameworks, small differences in scoring rules, weighting, or aggregation can drive large differences in outcomes.

When expert analysis changes the outcome

These contests may be subject to structural flaws in the testing, ranking, and scoring procedures. This was the situation in the Nature's Way case Dr. Cornew, President and Senior Consultant of Market Consulting Corporation, worked on in Florida in which he analyzed the Department of Health's methodology. The values assigned in the ranking process they used contained significant relative error, among other calculation errors. The administrative law judge agreed with Dr. Cornew's expert report and more than 10 additional rejected applicants were ultimately licensed. While every state's medical cannabis licensing procedures differ, some problems seem to be widespread; Dr. Cornew has worked on cases in other jurisdictions with similar scoring/ranking issues.

The question for your matter in select states is whether similar types of errors can be shown — and explained clearly — based on the record and scoring data available.

December 2025 • Licensing Disputes Watchlist

Competitive licensing denials: where the scoring record and ranking mechanics may matter most

This update is written for counsel, denied applicants, and operators evaluating whether an administrative record supports a challenge. The focus is narrow: scoring models, evaluator application of criteria, aggregation math, tie/rank rules, and procedural deviations that can be outcome-determinative in competitive (non-lottery) licensing.

Submit Materials for a Confidential Preliminary Review Go to the Watchlist

How to use this section

Each state entry below is written as a quick triage note for counsel: last known posture, what tends to be decisive in the record, and what the matter is waiting on.

Best fit

Competitive scoring contests (not lotteries) where small deltas can change awards.

What the analysis tests

Criterion application, scoring variance, roll-up math, tie/rank logic, and rule adherence.

Typical work product

Neutral memorandum → expert report → testimony support (as needed).

Florida • MMTC (Vertically Integrated)

Competitive scoring disputes: narrow margins, ranking sensitivity, and record-driven review

Florida MMTC determinations are frequently “small-delta” contests. Where scores are close, the decisive issues are often found in the scoring record: evaluator application of criteria, category roll-ups, ranking/tie mechanics, and documented deviations from published procedures.

Record items that tend to matter

  • • Per-evaluator score sheets and any narrative notes
  • • Aggregation/weighting rules and proof of arithmetic roll-up
  • • Ranking lists, tie-break rules, and any post-scoring adjustments

What the matter is waiting on

Resolution of pending administrative proceedings and any judicial clarification affecting ranking, methodology, and agency adherence to published scoring procedures.

Alabama • Integrated Facility (Vertically Integrated)

Litigation-driven uncertainty: procedure, scoring framework adherence, and award consistency

Alabama’s licensing has been shaped by rule challenges and litigation risk. In contested settings like this, the practical question is whether the agency applied its scoring framework consistently and whether deviations are material in the final rank order.

Record items that tend to matter

  • • Score packets, evaluator sheets, and category totals
  • • The exact rules/rubrics used (including revisions and emergency rules)
  • • Award list and documentation of how ties/ranks were resolved

What the matter is waiting on

Appellate or judicial guidance on challenged rules and the final disposition of pending disputes that affect award stability and licensing timelines.

Arkansas • Medical Cannabis

Generally stable program; disputes tend to be round-specific and record-driven

In Arkansas, major disputes typically arise around discrete licensing decisions (expansions, scoring rounds, compliance enforcement). When a challenge is viable, it is usually because the record shows inconsistent criterion application or errors in scoring methodology.

Record items that tend to matter

  • • Rubric definitions and published scoring instructions
  • • Score breakdowns and any evaluator notes
  • • Denial notices and deadlines (critical for preservation)

What the matter is waiting on

Any new expansion rounds, revised scoring criteria, or enforcement actions that create a fresh record for administrative review.

California • Municipal Licensing

Local scoring, zoning, and equity criteria: disputes often turn on municipal record and process

California disputes are frequently municipal (not statewide): city/county scoring, zoning prerequisites, equity qualification, and consistency of evaluator application. The viability of a challenge usually depends on what the municipality documented—and what it failed to document.

Record items that tend to matter

  • • Local ordinance + RFP instructions + scoring rubric
  • • Evaluator scorecards and any public meeting minutes
  • • Equity determinations and supporting documentation requirements

What the matter is waiting on

New municipal rounds, litigation outcomes affecting transparency and discretion, and any changes to equity frameworks that alter scoring and eligibility.

Georgia • Limited Licensing / RFP Mechanics

RFP-style record discipline: where the narrative and the math must match

Georgia provides a useful template for record-building even when disputes are less frequent: challenges succeed (or fail) based on whether the evaluation record supports the scores and whether the stated criteria were applied consistently across applicants.

Record items that tend to matter

  • • The rubric, definitions, and evaluator instructions
  • • Score breakdown by criterion and any evaluator rationale
  • • Proof that quantitative totals align with qualitative findings

What the matter is waiting on

Statutory expansion, new competitive rounds, and any changes to scoring criteria that create a new administrative record for review.

Illinois • Equity / Licensing Administration

Equity scoring and administrative compliance: disputes often focus on documentation and rule fidelity

Illinois disputes frequently involve equity qualification, scoring transparency, and administrative handling of applications. Where a challenge is viable, it is typically because the record shows inconsistent treatment of similarly situated applicants or deviation from published scoring/verification rules.

Record items that tend to matter

  • • Equity criteria, verification rules, and evidence submitted
  • • Scoring rubrics and evaluator score sheets
  • • Agency communications and cure/deficiency notices

What the matter is waiting on

Additional licensing phases, further guidance on scoring disclosure, and resolution of round-specific administrative challenges.

Maryland • Licensing Administration

Mature program posture; disputes typically emerge around expansions and compliance actions

Maryland is generally stable compared to capped competitive scoring states. When contested matters arise, they are often tied to discrete expansion rounds, application scoring, or administrative enforcement.

Record items that tend to matter

  • • Round-specific rubrics and scoring packets
  • • Administrative deadlines and preservation steps
  • • Compliance notices and inspection findings (if enforcement-based)

What the matter is waiting on

Any new licensing rounds or market-expansion phases that create competitive scoring outcomes and a new administrative record.

Missouri • Prior Competitive Rounds

Prior scoring disputes remain instructive; watch for capped expansions and discrete contested rounds

Missouri has seen litigation over scoring fairness in earlier competitive licensing rounds. While the market is more mature, any future capped expansion can reintroduce the same record-driven issues: consistent criterion application and defensible scoring mathematics.

Record items that tend to matter

  • • Round rubric, scoring packet, and evaluator variance
  • • Any corrections, re-scoring, or post-award adjustments
  • • Denial letters and administrative timelines

What the matter is waiting on

Any future limited-license rounds or rule changes that create competitive scoring and a new record for administrative review.

Nebraska • Implementation / Initial Rulemaking Risk

Early-stage risk: compressed timelines, transparency, and the design of scoring criteria

Nebraska is a “front-end risk” jurisdiction: when licensing frameworks are being implemented, disputes often turn on the clarity of the rubric, disclosure of scoring mechanics, and strict timelines that can foreclose meaningful review if deadlines are missed.

Record items that tend to matter

  • • Proposed/issued rules and scoring criteria definitions
  • • Published timelines, cure windows, and appeal procedures
  • • Any scoring disclosure obligations (what applicants can access)

What the matter is waiting on

Final rules, initial licensing rounds, and the first wave of administrative challenges that test how scoring and disclosure are handled in practice.

New Jersey • Scoring / Disclosure / Administration

Technical compliance and scoring transparency: disputes often center on what the record shows (and what it withholds)

New Jersey matters often involve application administration, scoring transparency, and access to materials needed to evaluate the rank outcome. Counsel typically focuses on whether similarly situated applicants were treated consistently and whether scoring mechanics can be verified from the record.

Record items that tend to matter

  • • Scoring criteria, point allocations, and score summaries
  • • Access/disclosure correspondence and document production
  • • Deficiency notices and technical compliance determinations

What the matter is waiting on

Further guidance and practice regarding what scoring records must be disclosed and how technical compliance decisions are documented and reviewed.

Ohio • Licensing Administration / Compliance

Administrative review tends to be compliance-driven; watch for rule changes that create new competitive outcomes

Ohio disputes frequently arise from administrative enforcement and compliance determinations rather than wholesale scoring-model challenges. Where competitive outcomes occur, the same principles apply: verify that the rubric, scoring, and rank order can be reconciled from the record.

Record items that tend to matter

  • • Compliance notices, inspection findings, and administrative correspondence
  • • Any round-based scoring packets (if a competitive award is at issue)
  • • Deadlines for administrative appeal and preservation

What the matter is waiting on

Regulatory adjustments that affect licensing availability and any new competitive rounds created by statutory or program changes.

Pennsylvania • Administrative Appeals / Program Administration

Procedural adherence and record sufficiency: disputes often turn on documentation and agency consistency

Pennsylvania maintains structured administrative processes. Disputes typically involve procedural adherence, documentation sufficiency, and consistent application of program requirements. In any competitive decision, counsel’s leverage depends on the completeness and clarity of the record.

Record items that tend to matter

  • • Agency communications, deficiency notices, and timelines
  • • Any scoring packets from competitive phases (if applicable)
  • • Documentation showing unequal treatment or rule deviation

What the matter is waiting on

Any legislative market-expansion actions that create new licensing rounds, and resolution of round-specific administrative challenges.

Utah • Capped / Highly Regulated Program

Structured administration with capped access: disputes tend to be narrow and procedure-specific

Utah’s program design tends to produce fewer broad “scoring model” disputes and more targeted administrative issues tied to compliance, eligibility, and capped licensing decisions. The record still controls: what rules were applied, to whom, and how consistently.

Record items that tend to matter

  • • Applicable statutes/rules and the decision trail
  • • Compliance determinations and administrative correspondence
  • • Any competitive scoring documentation (if a capped award is involved)

What the matter is waiting on

Statutory or regulatory changes expanding license availability and any related administrative challenges that follow expansion.

For counsel and referral partners

Start with the scoring packet—then decide whether it is worth pressing

A preliminary review is designed to answer one question: does the record support an outcome-changing scoring, ranking, or procedural issue? If it does not, you avoid avoidable briefing, cost, and timeline compression.

Submit for Confidential Preliminary Review Return to Watchlist

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This section is informational and does not constitute legal advice. Any engagement is limited to independent analysis of scoring, ranking, and procedural characteristics to assess whether the administrative record supports further expert work.

Why timing and local rules in select states matter

In select states, MMTC and other medical cannabis licenses are often awarded through complex scoring systems and tight batching windows. Once a round is closed, the opportunity to correct scoring errors is limited and time sensitive.

A consultation helps you answer three urgent questions:

  • Is there evidence that the scoring or ranking process may be flawed?
  • Can those issues be articulated in a way that decision-makers will understand?
  • Is there enough time to develop the analysis and support your counsel's strategy?
Share your scoring documents →

Brief video overview

Challenging Medical Marijuana License Rejections

Strategic opportunity for operators and investors

A less-costly route to becoming an MSO

Among the applicants Dr. Cornew has advised and for whom he has presented expert opinions, successful appeals have not only resulted in initial licensure but have, in some cases, led to substantial subsequent transactions — including Nature's Way selling its Florida license for $67,000,000.00.

A smarter path to expansion

Accordingly, a more economical method to become an MSO (or to expand an existing footprint) can be to identify and convert improperly rejected applicants into successful licensees, and then selectively acquire those entities. Rather than competing in every initial round at full cost, you focus resources on contests where scoring and ranking processes are most vulnerable to challenge.

For operators and investors in select states, this can mean building a multi-state presence by strategically appealing and acquiring licenses, instead of relying solely on expensive, highly competitive initial application cycles.

Discuss Appeal Strategy

Why appeals can be more efficient than reapplying

Reduced Costs

The legal costs of an appeal are often substantially less than mounting a brand-new application effort from scratch, especially when the administrative record and scoring already exist.

Focused Effort

Instead of rebuilding an entire application, you concentrate resources on the specific scoring and ranking issues that may have driven the rejection.

Expert guidance for decision-makers

An advisor with deep experience in contesting medical marijuana license scoring can help identify which cases are most promising, explain the statistical issues clearly to decision-makers, and support counsel in building a focused, data-driven challenge.

Whether you are a single-location operator in select states or part of a larger group seeking to expand, a carefully targeted, evidence-based appeal can unlock significant value.

Dr. Ron Cornew

Meet the Expert

About Dr. Ron Cornew

Dr. Cornew is a consultant and expert witness in medical marijuana licensing cases involving numerical and other mathematical issues, and in cases involving securities and investments.

His background is in statistics and investment consulting, having received both a Bachelor of Science degree and a Doctor of Science degree from the Massachusetts Institute of Technology, where he also served on the teaching and research staff. He has published papers comparing trading advisors using various statistical methods — a problem not unlike selecting applicants to receive medical marijuana licenses.

Dr. Cornew co-founded a Boston-based fund management company and has consulted with banks, the New York Stock Exchange, the Options Clearing Corporation, and other major clients.

His litigation work has included consulting in the preparation for court cases and hearings, often in matters where customers have lost significant sums. He has served as a member of the board of arbitrators of the National Association of Securities Dealers (now FINRA), the New York Stock Exchange, the American Arbitration Association, and the National Futures Association.

Why law firms and license applicants in select states engage Dr. Cornew

  • Deep experience with MMTC scoring, ranking, and tie-breaking procedures.
  • Ability to identify arbitrary or capricious scoring patterns using statistical methods.
  • Clear, courtroom-ready explanations for judges, hearing officers, and regulators.
Talk to Dr. Cornew's Office

Use the contact form below to outline the matter, relevant deadlines, and any available scoring or ranking documents.

Next step: confidential review

Request a Confidential Consultation

If you or your client have received a medical marijuana license rejection in select states, and you believe the scoring or ranking process may have been flawed, please use the form to request a confidential, data-driven review.

Your submission is reviewed by Market Consulting Corporation for the limited purpose of assessing whether the contest's scoring and ranking structure appears to support an appeal. You will receive a response indicating whether additional analysis is recommended before critical deadlines.

What to include in your message

  • Jurisdiction and type of license applied for (MMTC or equivalent).
  • Date of denial and any applicable filing or appeal deadlines.
  • Any score sheets, ranking tables, or evaluator notes you have received.

Please do not include highly sensitive personal information beyond what is necessary to describe the matter.

Tell us about your license rejection in select states

Provide your contact details and a brief summary of the matter. We will follow up to let you know whether a deeper analysis is recommended.

Submission of this form does not create an attorney-client relationship and does not obligate Market Consulting Corporation to accept an engagement. Any follow-up will be for consulting purposes only.

Denied Your Medical Marijuana License in select states?

Independent expert analysis to challenge arbitrary MMTC scoring and give your application a second chance.

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