People v. Hartwick, 303 Mich. App. 247

Defendant, a MMMA registry holder, was charged with manufacturing and possessing marijuana for delivery.
He claimed immunity under § 4 and an affirmative § 8 defense based on his registry cards.
The trial court denied § 4 immunity and rejected the § 8 defense at trial.
The appellate court affirmed, rejecting both his § 4 immunity and § 8 defense arguments.
The court held that mere possession of registry cards does not prove § 8(bona fide physician-patient relationship) or satisfy § 4(d) immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendant is entitled to §4 immunity	Kolenek supports card-based immunity	Card possession automatically immunizes under §4	Not entitled to §4 immunity
Whether §8(a)(1) requires a bona fide physician-patient relationship	Card alone proves §8(a)(1)	Ongoing doctor-patient relationship is not required	Card possession insufficient; §8(a)(1) requires ongoing relationship
Whether §8(a)(2) requires knowledge of “reasonably necessary” amount	Amount limits from §4 apply to §8(a)(2)	Defendant knew patient needs; enough to satisfy §8(a)(2)	Defendant failed to show knowledge of required quantities; §8(a)(2) not satisfied
Whether §8(a)(3) could rescue §8 defense if §8(a)(1)-(2) failed	Evidence could show actual medical use under §8(a)(3)	Card evidence supports §8(a)(3) regardless of §8(a)(1)-(2)	Court did not reach §8(a)(3) because §8(a)(1)-(2) were not satisfied; defense failed as a matter of law

Kolanek v. Michigan, 491 Mich 382 (2012) (MMMA protections limited to those with serious medical conditions; analysis centers on medical purpose)
Bylsma v. Michigan, 493 Mich 17 (2012) (§4 immunity and §8 defense are independent; court reviews 4 and 8 separately)
Redden v. Michigan, 290 Mich App 65 (2010) (Defines bona fide physician-patient relationship; prior to amendments)
Hartwick v. Michigan, 493 Mich 950 (2013) (Authority on MMMA interpretation and procedural posture)