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DOJ shifts marijuana policy: What employers need to know

Advocacy News – April 30, 2026 

The big picture: On April 23, 2026, the U.S. Department of Justice reclassified certain marijuana products to Schedule III under the Controlled Substances Act – a major federal shift after decades of Schedule I treatment.

Why it matters: This move recognizes medical use and lowers perceived risk – bringing new implications for workplace policies, especially under the Americans with Disabilities Act (ADA).

What changed:

  • Covers FDA-approved marijuana drugs and state-regulated medical marijuana
  • Does not legalize recreational use federally
  • DOT-regulated safety roles (e.g., pilots, truck drivers) are unchanged under U.S. Department of Transportation rules

Bottom line: Employers may need to treat medical marijuana like other prescribed medications.

  • Past: Marijuana use = “illegal drug use” → no accommodation required
  • Now: Lawful medical use is no longer categorically illegal
  • Result: Employers should engage in the ADA interactive process for qualified employees
  • However, employers can still prohibit on-the-job impairment and safety-sensitive restrictions remain valid
  • THC testing isn’t off the table — but it’s more regulated

Go deeper: This isn’t full legalization – but it’s a meaningful legal shift. Employers who treat it as business-as-usual risk falling out of compliance. Check out the full legal analysis from our friends at Miller Canfield.