This is what some fear: Any day now, the federal government will raid several of the medical marijuana dispensaries that have been proliferating lately throughout Western Washington. The crackdown would serve as an edict to our state, which legalized medical marijuana 13 years ago, that we can go only so far in flouting the Controlled Substances Act.

"We believe the possibility exists of an ongoing, large-scale federal investigation coordinated by US Attorney for Western Washington Jenny Durkan," says the blog of Seattle-based Cannabis Defense Coalition (CDC), which held raid preparedness trainings in the spring.

One dispensary operator in Seattle, who serves roughly 800 patients and asked to remain anonymous, says, "We feel a bit like sitting, smoking ducks."

To avoid federal attention, dispensaries in Seattle are shrinking their client bases, changing their business models, and toning down their advertising. Meanwhile, city officials have attempted to provide legal clarity while county prosecutors reassess where they stand in a battle between local and federal authority.

Why the big changes now, after the bazaar of new medical marijuana shops opened over the past year?

A new state law takes effect on July 22, the result of a bill passed by the state legislature in April and then partly vetoed by the governor, creating a tangle of rules. The upshot, lawyers say, is that the new policy eliminates a legal gray area in which dispensaries have thrived. Until this month, the state medical marijuana act passed by voters in 1998 allowed a care provider to provide marijuana to one patient at any given time; a liberal interpretation suggested dispensaries could serve thousands of patients, but only one at a time. The new law explicitly limits a care provider to one patient every 15 days.

This local policy shift matters to federal law enforcement, which has repeated under the Obama administration that it will turn a blind eye to medical marijuana cases that appear to comply with state laws. Now that Washington State is removing legal shelter for pot providers who care for multiple patients, some believe the dispensaries are exposed to greater federal criminal liability. Moreover, US deputy attorney general James Cole announced in a June 29 memo that anyone growing, selling, or distributing medical marijuana is violating federal rules, "regardless of state law."

"In a worst-case scenario, everyone associated with a dispensary could be subject to federal indictment—from the person watering plants to the person working the front desk," says Alison Holcomb, drug policy director of the ACLU of Washington. The severity of the punishment under federal law, which provides no medical defense, "depends on how much marijuana is involved. If you have 100 plants, you're looking at five years minimum out the door."

What are operators of the 50-plus dispensaries in Seattle, which the city estimates serve 25,000 patients, doing to prepare?

"Quietly freaking the fuck out," says the anonymous dispensary proprietor, who is also working with lawyers to establish a collective garden grow model that will be allowed. For all its drawbacks, the new law authorizes 10 patients to collectively grow up to 45 medical marijuana plants. In larger grow facilities, some attorneys posit, each collective garden could be separated by a strip of tape on the floor. The patients associated with each garden could change by the day, week, or year—as long as the dispensary's paperwork reflects that.

"Basically, it's an exercise in mental knot-tying," says Ben Livingston, a spokesman for the CDC. "The bigger the dispensary, the bigger the pain in the ass."

Conversely, smaller dispensaries may have an easier time complying. "With the aid of law enforcement, we've found a way to exist that complies with the new laws," says John Davis, co-owner of the Northwest Patient Resource Center, a dispensary in West Seattle.

But some dispensaries aren't being given the chance. The cities of Edmonds, Federal Way, Issaquah, Poulsbo, Yelm, Port Orchard, Hoquiam, Snohomish, North Bend, and Kent have all passed moratoriums. If dispensaries resist, city authorities may summon the Feds to begin raids, as happened in Spokane this year, says Kurt Boehl, a criminal defense attorney.

Seattle may be the most striking exception. On July 18, the Seattle City Council passed legislation to license dispensaries like other businesses and regulate where they can operate. Next, the council will set zones where the dispensaries can stay open.

That is, they can stay open provided federal authorities believe the interpretation of state and city rules provides a legal shelter. Boehl warns, however, that it's not patients who are at risk, but "the people operating as cooperatives, collectives, and access points who have to be very careful." recommended