When the 1937 Marihuana Tax Act was ruled unconstitutional by the Supreme Court, it was replaced with Nixon’s Controlled Substances Act. Congress temporarily placed cannabis in Schedule I, the most restrictive classification, and the National Commission on Marihuana and Drug Abuse or Shafer Commission was appointed to make a recommendation for its permanent placement. The commission recommended decriminalization of cannabis in 1972, but the recommendation was opposed by a 1974 congressional subcommittee.

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