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was called into question by Leary v. United States. 10 The following year the Act wasrepealed and replaced with the 1970 Controlled Substance Act (CSA)States’ approval of marijuana use is going to run into the buzz saw of the federalgovernment’s disapproval of marijuana use. The feds will argue that, under the doctrineof preemption, in a battle with the states, the federal government wins because a statemay not pass a law in direct opposition to a federal law if the federal legislature intendedto regulate that area. Based on this doctrine of preemption, no state law may require afederal contractor or grantee to accommodate state-legal medical marijuana use.In 2005, this conflict came to a head in Gonzales v. Raich. 11There, the Supreme Courtheld that the Commerce Clause of the Constitution includes the power to prohibitmarijuana from being cultivated and used even though it was in compliance withCalifornia law. In Gonzales, the petitioners argued that the “CSA's categoricalprohibition of the manufacture and possession of marijuana as applied to the intrastatemanufacture and possession of marijuana for medical purposes pursuant to Californialaw” exceeded Congressional authority under the Commerce Clause. 12The Courtdisagreed and stated,[L]imiting the activity to marijuana possession and cultivation “inaccordance with state law” cannot serve to place respondents' activitiesbeyond congressional reach. The Supremacy Clause unambiguously10 Leary v. United States, 395 U.S. 6, 89 S.CT. 1532 (1969). The Court found that compliance with the1937 Marijuana Tax Act would have a substantial risk of self-incrimination11 Gonzales v. Raich, 545 U.S. 1, 125 S.Ct. 2195, 2196 (2005).12 Id. at 15.