Civil Lawsuit Filed In Hawaii

https://docs.google.com/document/d/1xkbMU6B25LOJ2ugAhf5e4O9yrYI3TqsABzFO4PcJ_5g/mobilebasic?

Reverend Heidi Grossman-Lepp, 

Reverend and Founder of Sugarleaf Church 2014

Qualified Expert Witness on Sacramental Use of Entheogenic Medicine

Former Founding Member of the Psychedelic Bar Association, 

Former Member of the Religious Use Committee

Www.SugarleafChurch.com 

SugarleafChurch@Gmail.com 1-530-301-0587

OPEN LETTER TO THE STATE OF HAWAII LEGISLATURE, GOVERNOR JOSH GREEN, HAWAII DEPARTMENT OF HEALTH, ATTORNEY GENERAL ANNE LOPEZ, PAM BONDI, AND DOGE

To:

Governor Josh Green, M.D., Executive Chambers, State Capitol, 415 South Beretania St., Honolulu, Hawai‘i 96813, Phone: (808) 586-0034, Fax: (808) 586-0006, Email: Contact the Governor

Attorney General Anne E. Lopez, Department of the Attorney General, 425 Queen Street, Honolulu, HI 96813, Phone: (808) 586-1500, Fax: (808) 586-1239, Email: Email the Attorney General

Hawaii Department of Health, 1250 Punchbowl Street, Honolulu, HI 96813, Phone: (808) 586-4400, Email: Contact the Department of Health

Hawaii State Legislature, State Capitol, 415 South Beretania Street, Honolulu, HI 96813-2407, Phone: (808) 587-0478 (Public Access Room), Email: par@capitol.hawaii.gov, Website: Hawaiʻi State Legislature

Attorney General Pam Bondi & Pastor Paula White, 601 13th St NW Ste 450N, Washington, DC 20005-3816, Office: (202) 800-5620, Fax: (202) 800-5623

Department of Government Efficiency (DOGE), Email: doge@mail.house.gov, Website

Date: April 17, 2025

Subject: Formal Notice of Violations, Religious Discrimination and Persecution, Demand for Immediate Accountability and Return of Sacred Church Property

Notice: Reverend Jason Hanley, leader and caregiver of Care Waialua Church, is now a member and an official branch—of Sugarleaf Church. You are formally on notice: “Notice to the agent is notice to the principal.” 

1. Introduction: A Call from the Silenced

To the officials who claim to serve the people:

I, Reverend Heidi Grossman-Lepp, speak on behalf of the silenced—the medical and spiritual cannabis users you have persecuted, abandoned, and tortured through ignorance, fraud, waste, greed and abuse. I stand for the Divine Plant and for my people that you have demonized and caged for corporate greed, only to turn around and poison us with the products of those very corporations that kill.  

Cannabis is not a commodity—it is a Sacrament, a Sacred Medicine, a gift from God. Your continued assault on it, and on those who revere it, is a spiritual, legal, and moral crime to humanity. We, the good people of America, will hold you accountable.

As Mahatma Gandhi prophesied, “First they ignore you, then they laugh at you, then they fight you, then you win.”

2. My Personal Stake and Mission: Reverend Heidi Lepp and Sugarleaf Church

I founded Sugarleaf Church in 2014, and I have dedicated my life to protecting the Sacramental use of Entheogenic Natural Medicine, including Cannabis, as a Divine and Sacred right. As a qualified expert witness and Cannabis criminal case investigator, the Church and our members now have 29 criminal Religious Freedom Restoration Act of 1993 case (RFRA) victories. I have witnessed and documented over 17 years the systemic corruption you perpetuate and in progress of literary works on the subject. 

My late husband, Reverend Charles Edward “Eddy” Lepp, was a trailblazer in the Cannabis Ministry, and his persecution—along with my own—fuels my resolve. I have endured 20+ raids including the FBI, DEA, a privately funded blackwater military operation TRIDENT raid, destruction of property, hate crimes, Yolo County Sheriffs burnt one of our churches down, theft, several death threats, bricks through my window, and a narrative that painted me as bad as a cartel. 

The judges in these cases signed the warrants with their eyes wide open, the press spun propaganda, and the same agencies I sued in federal court for religious discrimination raided me to destroy my evidence against them. This ended the theft of 30,000 pounds of Sacraments worth $90 million and a $2 billion lien on my bank accounts. Patrick McGrath, the DA of Yuba County, CA unlawfully arrested and charged me with 28 felony counts of conspiracy to commit a misdemeanor to cultivate and distribute Cannabis (yes I was).  They never found a crime or any evidence of one. I was not guilty. Sgt. Brandon Spears said on the stand at my trial, he knew I was operating legally, but raided me because I started calling my Cannabis collectives “churches”. Yet, I remain steadfast to shine the light on truth and transparency. Sugarleaf Church is not just a community; it is a sanctuary for healing, a bulwark against tyranny, and a testament to our unyielding faith in Divine justice. This is not justice. This is racketeering with a badge, and the blueprint that started in California is now swallowing communities like Reverend Jason Hanly’s in Hawaii.

3. The Persecution and Discrimination of Religious Leaders, Healers and Patients

3.1. Landmark Ruling: United States v. Marin Alliance for Medical Marijuana

In 2015, U.S. District Judge Charles R. Breyer ruled in United States v. Marin Alliance for Medical Marijuana that the federal government cannot prosecute medical cannabis providers compliant with state law, enforcing the December 16, 2014, Rohrabacher–Farr Amendment. This amendment PROHIBITS the Department of Justice from using funds to interfere with state medical Cannabis programs, setting a clear federal precedent that such prosecutions are illegal.

Yet, this law has been ignored along with many others, targeting medical patients, spiritual users, churches, sanctuaries, and spiritual centers like mine and Reverend Hanly with relentless raids, violations of human rights, and HATE CRIMES AGAINST HUMANITY AND GOD.

3.2. Personal and Cultural Tragedies Against Spiritual and Religious Leaders: My Late Husband Reverend Eddy Lepp, Reverends Roger and Sherryanne Christie, and Reverend Jason Hanley

Reverend Charles Edward “Eddy” Lepp, Ratafarian: 

After winning his state criminal case in 1998 with 182 plants in Lake County, California, Lepp prevailed under The Compassionate Use Act of 1996 legalizing medical marijuana. In 2004, federal agents raided his 30-acre Rastafarian Ministry, seizing his Sacred Plants and prosecuting him under federal drug conspiracy laws. In 2009, Judge Marilyn Hall Patel, whom I describe as one of the most corrupt and disgusting judicial actors, sentenced him to a mandatory minimum of 10 years in federal prison. She said the sentence was “excessive” and lied that her hands were tied, while redacting all references to California’s Proposition 215 (CUA) for the jury, denying his lawful medical and religious defense. 

Reverends Roger and Sherryanne Christie of THC Ministries: 

In 2010, they were raided, arrested, federally charged, and detained without bail for over four years. Roger served 50 months, and Sherryanne served 27 months from 2016 to 2018. Their sanctuary was desecrated, their divine mission silenced, and their lives dismantled—all to shield corporate profits and pharmaceutical monopolies. 

Reverend Jason Hanley and Waialua Care: 

​Jason Hanley’s cultivation at Care Waialua was fully legal under Hawaii’s medical cannabis law, established by Act 228 (2000), which allows qualified patients and caregivers to grow cannabis for medical use. Jason was acting within the protections of HRS § 329-122, which grants immunity from arrest or prosecution for registered patients and their designated growers. 

Reverend Hanley had been transparent about his operations, previously inviting lawmakers and media to tour the facility. He stated that Care Waialua served nearly 1,000 patients, many of whom were elderly, veterans, or in hospice care. Despite his openness and efforts to comply with state medical cannabis laws. He obviously put a target on his back.

Jason Hanley’s Care Waialua medical cannabis farm was raided on October 25, 2023 by Homeland Security (federally funded), in a coordinated operation involving federal agents, state narcotics officers, and Honolulu police. During the early morning raid, authorities seized thousands of cannabis plants from the farm’s greenhouses, as well as financial records, medical records, property, Sacred plants and cash from both the farm and Hanley’s residence. 

The Withdrawal of Claim and Consent to Forfeiture (FP&F Case No. 2024-3201-000037-01) attached and was forcefully signed by Reverend Jason Hanley. This is constitutionally and procedurally defective if obtained under coercion, duress, or threat of indictment. Under the Fifth and Sixth Amendments, and consistent with Brady v. United States, 397 U.S. 742 (1970), and Federal Rule of Criminal Procedure 11(b)(2), any waiver of rights—including property rights through forfeiture—must be knowing, voluntary, and intelligent. Reverend Hanly had initially invoked his right to judicial forfeiture under 18 U.S.C. § 983(a)(2), which requires the government to file a judicial complaint within 90 days. Instead, he was pressured to withdraw his claim and consent to forfeiture without judicial review, bypassing the statutory process. This withdrawal was induced through threats of criminal charges, promises of leniency, or withholding of due process, it constitutes a clear violation of federal law. Shameful. 

Furthermore, while Reverend Jason Hanley had not yet formally established Care Waialua as a religious entity at the time of the raid, he has since declared and documented his status as a federally protected religious organization under the Religious Freedom Restoration Act (RFRA), 42 U.S.C. § 2000bb and United with Sugarleaf Church. The property seized—rosin presses, distillers, freeze dryers, and other Sacrament-processing equipment—was directly tied to his spiritual practice and religious transformation. The government’s continued retention of sacred materials following that transformation, without affording judicial review or RFRA consideration, constitutes a substantial burden on religious exercise. Courts have long held that once religious status is asserted—even post hoc—RFRA still applies unless the government can show a compelling interest using the least restrictive means. 

The failure to appoint a special master to review seized MEDICAL, spiritual and potentially privileged materials, as authorized under Federal Rule of Civil Procedure 53, further violates Jason’s due process, HIPAA confidentiality, and First Amendment rights, especially given the risk of improper law enforcement access to sacred, spiritual, or medical data. 

Cutter v. Wilkinson, 544 U.S. 709, 714 (2005)
“The Religious Land Use and Institutionalized Persons Act (RLUIPA), like RFRA, protects individuals and institutions from substantial burdens on religious exercise whether such exercise is longstanding or newly adopted.”

Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 546 U.S. 418 (2006)
The Court ruled that the government must demonstrate a compelling interest and least restrictive means even if the religious claim was asserted only after enforcement action had begun.

42 U.S.C. § 2000bb-1(c) (RFRA Statute)
“A person whose religious exercise has been burdened in violation of this section may assert that violation as a claim or defense in a judicial proceeding and obtain appropriate relief…” The statute contains no time restriction for asserting RFRA protection.

The raid on Care Waialua was not a fluke, nor was it the result of one rogue agency overstepping. It followed a pattern—one I know all too well. What happened in Hawaii is the direct exportation of a model perfected in California with Kamala Toe Harris at the helm. Let me show you what that looks like:

Since the late 1990s, California has served as the blueprint for a decades-long war against Natural Medicine and Spiritual Freedom, launching a model of state-sanctioned terrorism that metastasized across the nation. Under the guise of “public safety,” rogue bureaucrats weaponized militarized narcotics task forces —like YONET and NET-5—built on unholy alliances between local sheriffs and their associations that funded the California Harris regime, state agents, and the DEA, and fueled by the Equitable Sharing Program, a perverse financial pipeline where federal asset forfeiture kickbacks flowed directly into the budgets of the same officers conducting the raids. 

These weren’t just busts—they were public executions of liberty: pre-dawn raids with AR-15s, helicopters, and armored vehicles aimed not at criminals but grandmothers, pastors, caregivers, and patients growing plants for spiritual healing. With each raid came theft masquerading as law, as millions in Sacrament, property, and cash were seized without charges, and funneled back to law enforcement who then bought more toys and raided again. It was a self-replicating parasite, a bureaucratic cartel cloaked in badges and funded by federal dollars. 

3.3 Transition to Hawaii:

And now, with chilling precision, that blueprint arrived in Hawaii. Reverend Jason Hanley, a peaceful spiritual cultivator and founder of Care Waialua, found himself caught in the crosshairs of the same militarized, profit-driven machine. His spiritual center was stormed, sacred Sacraments were seized, and his reputation was dragged through the mud. Why? Because Care Waialua operated outside the state’s pay-to-play licensing scheme. Reverend Hanly, a man of God, could not be sold.

4. HIPAA Violations and Human Rights Abuses: Jason Hanley and Care Waialua

4.1. Judicial Overreach Without a Special Master

This unlawful nefarious case presented the most disturbing of civil rights violations.  Judge Kenneth J. Mansfield, should be removed from the bench! He signed an unlawful warrant, without an affidavit of probable cause (to our knowledge). The judge’s authorization and request to access the HIPAA-protected medical records of over 925 patients at Waialua Care without appointing a special master to safeguard their privacy is exposing a massive line of corruption. 

Federal Rule of Civil Procedure 53 mandates federal courts appoint a special master in complex or sensitive matters—especially where the integrity of constitutional rights or privileged materials is at stake. In cases involving the seizure of medical or patient records, the court’s failure to appoint a special master to oversee the handling of protected documents constitutes a grave violation of due process, HIPAA confidentiality, and First Amendment religious freedom. This omission not only exposes sacred and confidential information to unlawful review by law enforcement but also erodes judicial impartiality and public trust. Courts across jurisdictions have affirmed that where constitutionally protected or privileged records are involved, Rule 53 oversight is essential to guard against abuse, ensure transparency, and uphold the fundamental rights enshrined by the Bill of Rights.

Relevant citations:

  • Fed. R. Civ. P. 53(a)(1)(C)
  • United States v. Zolin, 491 U.S. 554 (1989) – reinforcing court’s duty to protect privileged material
  • United States v. Comprehensive Drug Testing, Inc., 621 F.3d 1162 (9th Cir. 2010) – requiring special procedures (including judicial oversight) when executing broad government searches to avoid improper exposure of protected information

This judicial overreach not only disregarded federal privacy laws but also trampled the rights of each patient, exposing their sensitive health information to unwarranted scrutiny and potential public disclosure. This created over 925 victims with the swipe of a pen. No legal justification or HIPAA-compliant process was followed, making this a blatant and egregious violation of:

  • HIPAA Privacy Rule (45 CFR §§ 160, 164)
  • Fourth Amendment protections against unreasonable searches
  • Due Process and Equal Protection under the Constitution
  • Religious Freedom Restoration Act (RFRA, 42 U.S.C. § 2000bb)

This action compounded the raid’s aggression, turning a medical & spiritual healing center into a target for systemic abuse, with no regard for patient confidentiality, judicial ethics, or the sacred trust between healer and patient. It is a direct assault on the rights of over 925 individuals who sought healing, not persecution, and it mirrors the broader pattern of targeting I have witnessed and fought against for decades.

4.2. Legal Violations: HIPAA, RFRA, Constitutional, and International Law

This single act of judicial overreach violates not only HIPAA but also fundamental constitutional and international protections, including:

  • First and Fifth Amendments
  • Universal Declaration of Human Rights (Articles 12, 18)

You cannot justify stripping patients of their sacraments, denying their confidentiality, and exposing their private health data as “criminal evidence.” This is not enforcement—it is a calculated violation of civil, constitutional, and international law, and it demands immediate accountability.

5. Systemic RICO and Fraud Upon the Court: A Corrupt Network

5.1. The Collapse of the Defense Bar and My Observations Over 17 Years

Over the last 17 years, I have documented countless cases where government officials concealed exculpatory evidence, fabricated charges, and abused prosecutorial discretion to maliciously prosecute Cannabis users, religious leaders and healers. Public defenders, court-appointed counsel, and even civil rights attorneys have consistently refused to challenge these abuses, whether due to incompetence, fear, or allegiance to the system. This collapse of the defense bar is not accidental—it is complicity, and I have borne witness to its devastating impact on our community.

RICO Violations, Corporate Collusion, and Legislative Corruption

This is a RICO operation disguised as cannabis enforcement. Under 18 U.S.C. §§ 1961–1964, your pattern of racketeering continues and your actions protect corporate dispensaries, low-IQ lobbyists waging lawfare, activist judges, and prosecutors who have abandoned their oaths—all while public defenders serve the state instead of the people. This is corruption at its most grotesque, and I will expose it.

6. Our Unwavering Position: No Permission Needed for Sacred Practice

6.1 Protection Under RFRA, First Amendment, and Constitutional Law

We do not need a permit, judge or DA to worship or a prosecutor’s blessing to heal. Our sacraments are protected by the United States Constitution. You should read it. 

We are not rogue actors; we are federally protected spiritual communities, and I will defend this right with every breath until my dying day.

6.2 Legal Precedents: Gonzales v. O Centro, Church of Lukumi Babalu Aye, and More

Landmark decisions like Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal (546 U.S. 418, 2006), Church of the Lukumi Babalu Aye v. City of Hialeah (508 U.S. 520, 1993), and People v. Lepp affirm our rights. 

In a landmark ruling in March 2025, U.S. District Judge Jill N. Parrish, in the case of Jensen v. Utah County, granted a preliminary injunction protecting the religious use of psilocybin by the Singularism religious group in Utah. This decision underscores that religious freedom must extend to “unpopular or unfamiliar religious groups” as well as mainstream ones, a principle directly applicable to our sacramental use of cannabis. Judge Parrish ordered local officials to return seized psilocybin and refrain from interfering with the group’s sincere religious practices, citing both Utah’s and the federal RFRA. She emphasized that governments cannot deploy coercive power to harass new religions without evidence of harm, stating, “For that guarantee of religious liberty to mean anything, the laws must protect unfamiliar religions equally with familiar ones, both in design and in practice.” This ruling, detailed in multiple reports, reinforces our position that your actions against Sugarleaf Church and Waialua Care violate the same protections under RFRA and the First Amendment.

6.3 The War on Drugs: A Fraudulent War Against the People, Natural Healing and Divinity, The Greatest Fraud Ever Perpetrated by Government

The War on Drugs is the most fraudulent and destructive policy operation in modern American history—a multibillion-dollar scam that disguised racial, spiritual, and political repression as public safety. It was never about stopping harm—it was about manufacturing criminals, militarizing local police, and funneling Sacred Medicine into the hands of corporations while stripping it from the hands of the People. Former Nixon aide John Ehrlichman admitted the true motive: to target Black Americans and antiwar activists by associating their communities with heroin and cannabis. This admission alone exposes the foundation of the War on Drugs as unconstitutional, immoral, and un-American. Every raid, every arrest, and every forfeiture stemming from this false war is tainted by its racist, deceitful roots. It was never about protecting the public—it was about suppressing natural medicine, dismantling Indigenous and spiritual healing, and enriching state coffers through asset forfeiture and mass incarceration.

The War on Drugs was never about public safety. It was a weaponized policy to dismantle communities, strip native ancestral ways from Indigenous peoples, silence spiritual practice, and empower law enforcement with unchecked authority. As Michelle Alexander argues in The New Jim Crow (2010), it is a fraudulent enterprise cloaked in public policy, disproportionately targeting communities of color and spiritual minorities. I have documented case after case of concealed evidence, fabricated charges, and prosecutorial abuse, aligning with United States v. Throckmorton (98 U.S. 61, 1878) and Hazel-Atlas Glass Co. v. Hartford-Empire Co. (322 U.S. 238, 1944), which define fraud upon the court as corruption of judicial machinery. 

6.4 Constitutional, Civil, and Human Rights Violations

Your raids, false pretenses, and manipulated records violate the Constitution, RFRA, and the trust of the people. You label God’s medicine as “illegal,” “dangerous,” and “public enemy number one,” while licensing corporations to profit from it, killing people in the process. This is fraud upon the people, and divine intervention has arrived through our resistance.

7. Legislative RICO and Corporate Greed: Protecting Profits Over People

Your unconstitutional legislation suppresses people and competition while favoring select corporations, constituting racketeering under 18 U.S.C. § 1962(c) and color of law violations under 18 U.S.C. § 242. You protect pharmaceutical boardrooms and low-IQ lobbyists, using taxpayers’ money to line your pockets while denying individuals their Creator-given right to heal. This is not governance—it is greed, and I will not let it stand.

On April 9, 2025, President Donald J. Trump issued a groundbreaking Executive Order aimed at dismantling unconstitutional regulations and curbing government overreach across federal agencies. This order mandates that all federal rules and enforcement actions must align with the Constitution, and it empowers individuals and businesses to challenge unlawful regulations that lack clear statutory authority. It specifically prohibits federal agencies from engaging in backdoor lawmaking through guidance documents or informal threats, a practice that has plagued religious institutions, caregivers, and natural medicine practitioners for years. This Executive Order reinforces that no agency has the right to criminalize behavior or seize property without clear, lawful authority—and due process. It further demands that any regulatory action affecting constitutional rights—especially under the First Amendment and Religious Freedom Restoration Act (42 U.S.C. § 2000bb)—must meet strict scrutiny. In essence, President Trump’s directive echoes what we have long declared: enforcement without lawful basis is not governance—it is tyranny.

8. Final Warnings and Resolutions: A Call to Action and Divine Resolve

8.1. Planned Legal Actions: RICO Claims, Public Records Requests, and Investigations

Jason Hanley is one of many whose constitutional and spiritual rights were violated. Despite asserting his status under the Religious Freedom Restoration Act (42 U.S.C. § 2000bb), Homeland Security continues to hold his sacred Sacrament-processing tools without due process or judicial review, in violation of Federal Rule of Civil Procedure 53. No special master was appointed. No hearing was granted. No restitution has been offered.

The government cannot simply hit delete on its abuses. If Hawaii wants true healing, it must recognize these individuals as victims, not former criminals. It must provide restitution, not just relief. And it must hold itself accountable, not just rewrite history.

We are now preparing to:

  • File RICO claims against local and state agencies participating in these coordinated violations
  • Launch public records requests into every HIPAA breach connected to religious cannabis enforcement
  • Call for disciplinary investigations into every attorney, defense attorney, lobbyist, judge, and prosecutor who aided and abetted these crimes through omission or collaboration

The law, the people, and the truth are on our side, and we will use AI transparency systems to log every raid, abuse, and deal, immortalizing your actions as case studies of corruption, not heroism. This history will not go unnoticed or accounted for. 

8.2. Our Unyielding Commitment to Justice, Truth, and the Sacred Plant

You can raid us again, mock our churches in the press, and call us “fake,” “illegal”, “legal”, “criminal,” or “dangerous.” But we will not back down. We are reclaiming what was stolen, restoring the Sacred, and walking with the law, the truth, and the Spirit. At the Aloha Cup, we will distribute this letter, ensuring every person knows: Hawaii is run by bureaucrats who’d rather arrest a healer than a pharmaceutical backdoor blood sucking executive. We do not surrender God’s medicine to your regulatory tyranny. The plant is holy—your fraud is not.

9. Expungement without acknowledgment is not justice—it’s concealment.

On April 14, 2025, Governor Josh Green signed HB 1595 into law, expediting the automatic expungement of over 2,200 low-level cannabis convictions in Hawaii. While framed as progress, this gesture is hollow without truth and accountability. The very people whose records are now being erased were unlawfully targeted, over-charged, raided, and defamed. They are not just names in a database—they are victims of systemic abuse.

Under Hawaii Revised Statutes § 801D-4, victims are guaranteed the right to be heard, to restitution, and to be treated with dignity. 18 U.S.C. § 3771, the federal Crime Victims’ Rights Act, further guarantees the right to full and timely restitution, to proceedings free from unreasonable delay, and to be protected from the accused. These rights have not been honored. There has been no restitution. No apology. No hearings. Just a silent swipe of the state’s slate, hoping no one asks questions.

Now, as undocumented labor is being driven out, Governor Green suddenly calls for “clean, legal hires.” But where was that energy when local caregivers and spiritual healers were being raided, robbed, and jailed? Many of them now face economic ruin while the same state that persecuted them courts sanitized headlines and new labor policies.

Jason Hanley is one of many whose constitutional and spiritual rights were violated. He is now publicly asserting his status under the Religious Freedom Restoration Act (42 U.S.C. § 2000bb), Homeland Security continues to hold his sacred Sacrament-processing tools without due process or judicial review.

The government cannot simply hit delete on its abuses. If Hawaii wants true healing, it must recognize these individuals as victims, not former criminals. It must provide restitution, not just relief. And it must hold itself accountable, not just rewrite history.

10. Conclusion

We will fight you in every court, every arena, and every public square. We walk with God, the Constitution, and the undefeated truth. This is our final warning: stop digging your grave deeper, or face the consequences of divine intervention and legal justice.

In firm resolve,

Reverend Heidi Grossman-Lepp

Cc: Michael Plumehoff, Law Clerk for Sugareleaf Church 

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