The Michigan Court of Appeals has recently determined that the Michigan Medical Marihuana Act affirmative defenses were not applicable in a case where Ted Allen Anderson was charged with unlawfully manufacturing marihuana.  Anderson possessed 15 marihuana plants in a closet in the house and an additional 11 marihuana plants growing in a garden behind the garage.  Anderson claimed the marihuana was for medical use, and the amount he possessed was a reasonable amount.  After being charged with manufacturing marihuana in violation of MCL 333.7401(2)(d)(iii), Anderson filed a motion to dismiss; however, the trial court determined that Anderson failed to establish the elements of the defense under MCL 333.26428, since Anderson failed to present adequate testimony regarding the amount of marihuana that was reasonably necessary to maintain an uninterrupted supply for his treatment.  The Court of Appeals affirmed the trial court's decision.  See People of the State of Michigan v Ted Allen Anderson, No. 300641 (2011).