(1997): This case holds that the Compassionate Use Act does not provide a defense for selling marijuana or possessing marijuana for sale. However, bona fide primary caregivers may receive reimbursement for their actual expense of cultivating and furnishing cannabis for the patient.s approved medical treatment. A buyers club that is open to the public cannot be considered the primary caregiver of thousands of patients simply by a declaration on the part of the patient. The definition of "primary caregiver" in the statute is explicit, and it states that a caregiver must be an individual. Click to view the ruling.