The Court of Appeal recently determined that persons are required to obtain registry cards, under the Michigan Medical Marihuana Act (MMMA), before they begin to grow marihuana for medical purposes.  Here, Defendant Reed suffers from chronic back pain, related to a surgery over a decade ago, and began to inquire about the medical use of marihuana.  On August 25, 2009, an undercover narcotics team, while doing aerial surveillance, spotted six marijuana plants at Reed's residence.  On September 16, 2009, Reed obtained a certification from a doctor to use marihuana for medical purposes.  Reed received his registry identification card from the State of Michigan on October 6, 2009.  On October 16, 2009, Reed was arrested and charged with the manufacture of marijuana.  Reed filed a motion to dismiss the charges claiming that he met all the elements of the affirmative defenses in Section 8 of the MMMA.  Section 8 of the MMMA indicates that a patient may assert the medical purpose for using marihuana as a defense to any prosecution and it shall be presumed valid, if, among other things, a physician has stated the patient is likely to receive benefit from the medical use of marihuana.  Reed also argued that he should have been immune from arrest under the MMMA, which states that a qualifying patient who has been issued and possesses a registry card shall not be subject to arrest, provided the patient doesn't have more than the permitted amount of marihuana.  The trial court denied Reed's motion and the Court of Appeals granted leave to hear the appeal.  The Court of Appeals determined that Reed's arguments fail because at the time of the offense, he did not possess a registry card; and in order for the Section 8 defenses to apply, the physician's statement must be procured before the purportedly illegal conduct occurs.  People v Reed, Published No. 296686, at 4 (2011).