CFR
Cullen/Frost Bankers Inc.
stock NYSE

From chatgpt:
**My hypothetical Julius ruling**
If I actually had to write the bottom line after this record, mine would probably look approximately like this:
**FINDINGS**
The record establishes that marijuana presents meaningful risks of abuse and adverse health consequences. The evidence further demonstrates substantial variation among marijuana products with respect to potency, formulation, route of administration and dosage.
The opponents have presented credible evidence concerning cannabis-use disorder, psychiatric effects, impaired driving, high-potency products and limitations in portions of the medical literature.
However, the evidence does not establish that marijuana lacks a currently accepted medical use.
HHS’s scientific and medical evaluation concluded otherwise, and the Government presented evidence supporting that determination. The opposing parties identified limitations in that analysis but did not sufficiently undermine its central conclusion.
Moreover, evidence concerning the risks associated with marijuana does not, without more, establish that Schedule I remains the appropriate classification.
**CONCLUSION**
After consideration of the administrative record and the applicable statutory factors, I would recommend that the marijuana presently subject to this proceeding be **transferred from Schedule I to Schedule III of the Controlled Substances Act**, subject to the regulatory controls applicable under federal law.
**But I would attach significant caveats**
This is where I think Julius could surprise cannabis investors.
A **Schedule III recommendation doesn’t require him to endorse the cannabis industry**.
He could write a fairly harsh 100+ page decision cataloguing high-potency THC, psychiatric risks, impaired driving, dependence, questionable medical claims and deficiencies in state regulatory systems…
…and still conclude:
**Schedule III.**
Those two things aren’t contradictory.
In fact, after reviewing the testimony, I think that’s one of the more plausible outcomes: **a reluctant, tightly reasoned Schedule III recommendation with extensive findings about marijuana’s risks.**
**What could change my 70–80% assessment?**
The **post-hearing briefs**.
That’s important because Julius’s preliminary order specifically said there would be no oral closing arguments; instead, parties would submit post-hearing briefs under 21 CFR §1316.64.
And right now DEA’s public 2026 NPRM page lists all 11 transcripts plus the transcript/post-hearing briefing order, but **does not presently list the parties’ post-hearing briefs themselves**.
Those briefs matter because a witness can give persuasive scientific testimony but still lose on the **law**. The briefs are where each side connects the testimony to the CSA and explains why Julius legally can—or cannot—reach Schedule III.
So I wouldn’t move my probability substantially higher than \~80% until seeing those arguments.
**One more important point**
Even if my hypothetical Julius issues:
**RECOMMENDATION: Schedule III**
that **doesn’t itself reschedule marijuana**.
Julius is the ALJ developing the administrative record and recommended findings. The ultimate agency rulemaking still has subsequent steps. DEA describes the process as formal rulemaking involving administrative review after the evidentiary proceeding.

From chatgpt:
**My hypothetical Julius ruling**
If I actually had to write the bottom line after this record, mine would probably look approximately like this:
**FINDINGS**
The record establishes that marijuana presents meaningful risks of abuse and adverse health consequences. The evidence further demonstrates substantial variation among marijuana products with respect to potency, formulation, route of administration and dosage.
The opponents have presented credible evidence concerning cannabis-use disorder, psychiatric effects, impaired driving, high-potency products and limitations in portions of the medical literature.
However, the evidence does not establish that marijuana lacks a currently accepted medical use.
HHS’s scientific and medical evaluation concluded otherwise, and the Government presented evidence supporting that determination. The opposing parties identified limitations in that analysis but did not sufficiently undermine its central conclusion.
Moreover, evidence concerning the risks associated with marijuana does not, without more, establish that Schedule I remains the appropriate classification.
**CONCLUSION**
After consideration of the administrative record and the applicable statutory factors, I would recommend that the marijuana presently subject to this proceeding be **transferred from Schedule I to Schedule III of the Controlled Substances Act**, subject to the regulatory controls applicable under federal law.
**But I would attach significant caveats**
This is where I think Julius could surprise cannabis investors.
A **Schedule III recommendation doesn’t require him to endorse the cannabis industry**.
He could write a fairly harsh 100+ page decision cataloguing high-potency THC, psychiatric risks, impaired driving, dependence, questionable medical claims and deficiencies in state regulatory systems…
…and still conclude:
**Schedule III.**
Those two things aren’t contradictory.
In fact, after reviewing the testimony, I think that’s one of the more plausible outcomes: **a reluctant, tightly reasoned Schedule III recommendation with extensive findings about marijuana’s risks.**
**What could change my 70–80% assessment?**
The **post-hearing briefs**.
That’s important because Julius’s preliminary order specifically said there would be no oral closing arguments; instead, parties would submit post-hearing briefs under 21 CFR §1316.64.
And right now DEA’s public 2026 NPRM page lists all 11 transcripts plus the transcript/post-hearing briefing order, but **does not presently list the parties’ post-hearing briefs themselves**.
Those briefs matter because a witness can give persuasive scientific testimony but still lose on the **law**. The briefs are where each side connects the testimony to the CSA and explains why Julius legally can—or cannot—reach Schedule III.
So I wouldn’t move my probability substantially higher than \~80% until seeing those arguments.
**One more important point**
Even if my hypothetical Julius issues:
**RECOMMENDATION: Schedule III**
that **doesn’t itself reschedule marijuana**.
Julius is the ALJ developing the administrative record and recommended findings. The ultimate agency rulemaking still has subsequent steps. DEA describes the process as formal rulemaking involving administrative review after the evidentiary proceeding.