Greener Pastures Holisticare could be running afoul of city codes, Portland officials said, if it opens a marijuana-based substance abuse treatment program on March 1 out of a single-family home on outer Washington Avenue.

Greener Pastures owner Roxanne Gullikson failed to disclose – on forms filed with the city in October – that it would be using marijuana. That followed a May 2017 filing in U.S. Bankruptcy Court that also sought to distance Greener Pastures from marijuana, which remains an illegal drug under federal law.

In an October application to the city for a conditional use permit for a residential treatment program, Gullikson did not disclose that cannabis would be part of the treatment protocol. The application made no mention of cannabis or marijuana in detailing Greener Pastures’ “holistic approach,” which included an array of programs and services, such as counseling, yoga, meditation, use of natural supplements and group therapy. The application also didn’t mention kratom, a legal but controversial substance that Gullikson claims helps with opioid withdrawal, an assertion disputed by medical experts.

“Greener Pastures administers a proprietary holistic approach to addiction, recovery and wellness,” the application said. “Drug and/or alcohol use is prohibited and grounds for immediate dismissal from the program.”

However, Gullikson told the Maine Sunday Telegram last week that marijuana would be a central part of the program.

The staff would include a licensed clinical social worker, licensed drug and alcohol counselor, medication aides, yoga instructor and dietitian, according to the application. Greener Pastures would also have a medical director, Dr. Mary Callison.

Greener Pastures is scheduled to open March 1, and charge patients $20,000 a month. The program has been providing similar outpatient treatment for about four years, Gullikson previously told the Press Herald.

City spokeswoman Jessica Grondin said that Gullikson’s conditional use permit could be in jeopardy if marijuana is used to treat a substance use disorder, because it’s not a permitted use under the city code.

“One of the conditions for qualifying as a sheltered care group home – which is the conditional use permit they received – is that the home serves a primary population which is not current illegal drug users. Marijuana is still illegal under federal law, so this arguably would not qualify as a sheltered care group home any longer. If they open and include marijuana in their treatment program, they would be operating without an approved conditional use,” Grondin said.

Gullikson, who had filed for Chapter 13 personal bankruptcy in 2017, has openly promoted her controversial method of using marijuana to treat opioid addiction, advocating for the business through social media and soliciting media coverage by email. Gullikson was featured in a Jan. 28 Telegram story about the controversial treatment methods, and claimed that she has been using cannabis to help treat opioid addiction for about four years.

But Gullikson denied including marijuana for opioid treatment in a signed statement to the bankruptcy court last year.

“Greener Pastures Holisticare does not provide or supply medical cannabis to its clients and never has,” she wrote in a May 16, 2017, statement to the court in response to questions about her plans to emerge from bankruptcy.

Gullikson, who is registered as a medical marijuana caregiver with the state of Maine, said city officials were aware that cannabis would be used for treatment at the home, but in a brief interview Thursday, she couldn’t explain why the application failed to make any mention of cannabis or marijuana.

Substance abuse treatment experts have criticized this method because there is no evidence that marijuana is effective in treating opioid addiction. Gullikson also promoted the use of kratom for withdrawing from opioids, which was also criticized by treatment experts. While a legal product, kratom has no medical uses, according to the Food and Drug Administration.

The business on outer Washington Street that Gullikson co-owns and operates with her husband, Ron Figaratto, would provide a 90-day, 12-bed residential treatment program if it’s allowed to open on March 1.

Gullikson had contacted the Telegram about writing a story on the program highlighting using marijuana and kratom to treat opioid addiction, which would likely be the first of its kind in Maine. In the Jan. 28 article, two patients told their stories to the newspaper and touted how Gullikson provided them with marijuana to help them beat their opioid addictions.

But Greener Pastures may have difficulty obtaining an occupancy permit to begin operating.

Grondin, the city spokeswoman, said the city has not made any decisions yet, but that staffers contacted Gullikson and told her about the potential problem she could have by opening the business.

Gullikson said the city’s application didn’t specifically ask whether her business would be using marijuana for treatment, and that marijuana is legal in Maine, for both recreational and medicinal uses.

Maine voters approved marijuana for recreational use in a 2016 referendum, but the rules for implementing legalization are still being hashed out in the Legislature. Substance use disorder is not a qualifying condition for certification as a medical marijuana patient, although there’s an effort in the Legislature to make it one, despite the lack of evidence that marijuana is effective in treating addiction.

In her bankruptcy filing, Gullikson denied that Greener Pastures uses marijuana for treatment, after trustee William Harrington questioned whether the business gave patients marijuana as a central component of its treatment program.

Harrington wrote that because marijuana is illegal under federal law, proceeds from a marijuana business couldn’t be used to emerge from bankruptcy.

“If it is the debtor’s intent to fund her Chapter 13 plan through revenues generated from the manufacture, distribution or dispensation of a controlled substance; such a plan cannot be confirmed. To do so would necessarily and improperly involve a federal court in administering the fruits and instrumentalities of federal criminal activity,” Harrington wrote. “(Without) the marijuana-based income stream, the debtors cannot fund a plan without breaking the law, and are therefore ineligible for relief under Chapter 13.”

Gullikson’s bankruptcy court statement denies using marijuana, but said the business gives patients “a wide variety of natural plant botanicals,” including “passion flower” “turmeric, St. John’s wort, moraga, borage” and others.

She claimed in the court statement that Greener Pastures could help patients with a number of illnesses, including arthritis, diabetes, Alzheimer’s, cancer and addiction.

The Greener Pastures website promotes cannabis as being effective for opioid treatment, using the acronym CHART to describe its protocol. CHART stands for Cannabis Harm-reduction and Recovery Training.

“We recognize the cannabis plant as a medicinal supplement and essential nutrient that specifically and uniquely benefits the body’s endocannabinoid system,” the website says. “As such the responsible use of cannabis is not a barrier to or threat to sobriety.”

Gullikson said in an interview last week that she couldn’t discuss the bankruptcy case.

“I proceeded in my bankruptcy filing based on legal advice I was given,” she said. “I can’t speak any more about that.”

Gullikson also said Greener Pastures is new, although her 2017 bankruptcy court filing lists Greener Pastures as her business for the previous seven months. On her October 2017 application for a conditional use permit, Gullikson claimed to have operated Greener Pastures as an outpatient recovery service out of the Washington Avenue home since “late 2015.”

Gullikson has also operated the Brickhouse Cannasseurs medical marijuana caregiver business.

“Lots of people have financial difficulties. That has nothing to do with how well they do their job or the goals they have in their life,” Gullikson said.

According to the bankruptcy filing, Gullikson earned $2,500 per month but had $3,192 in monthly expenses. A home she owned at 144 Ocean Ave. in Portland was in foreclosure proceedings, and creditors were demanding that she pay back about $150,000 on the loan. The home was the subject of a separate lawsuit between Gullikson and her mother over ownership and rent. The case was dismissed in October 2017.

The bankruptcy case was dismissed in November 2017 after Gullikson failed to make a $330 monthly payment. The court had approved a 54-month repayment plan, but the issue of whether Gullikson intended to use proceeds from marijuana to help her emerge from bankruptcy appeared to be unresolved prior to the dismissal, according to court records.