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At various times since 1978, 36 states and the District of Columbia have had favorable medicinal marijuana laws. Laws in six states have either expired or been repealed, but 30 states and D.C. now have laws on the books, according to the Marijuana Policy Project. Only 12 states have what the MPP calls 'effective laws,' which allow the cultivation of medicinal marijuana and protect patients who possess it with their doctors' recommendations or certifications from criminal penalties: Alaska, California, Colorado, Hawaii, Maine, Montana, Nevada, New Mexico, Oregon, Rhode Island, Vermont, and Washington. Maryland has what the MPP deems a 'workable law' because it protects patients from jail time for possession of marijuana, but it does not specifically address cultivation. For patients who can prove in court that their use of marijuana was a medical necessity, the maximum penalty is a $100 fine. Seventeen additional states and D.C. have laws that recognize marijuana's medical value, but these laws are ineffective, according to the MPP, because they rely on federal cooperation.