Quote Originally Posted by SoCoMMJ
(d) Except for patients applying pursuant to subsection (6) of this section, where the state health agency, within thirty-five days of receipt of an application, fails to issue a registry identification card or fails to issue verbal or written notice of denial of such application, the patient's application for such card will be deemed to have been approved.

Here is the Colorado State DOR interpretation of the 35 day ruling:
DOR 35 day ruling
Read the link you posted. It specifically says that amendment 20 does not address the 35 day rule, look under "discussion". It is when you mix 1284 and amendment 20 that they get the 35 day rule. 1284 says you need a redcard to purchase. a20 says that the cdphe has 35 days to decline you, after that, you are approved. Since there is a possibility to be declined in the first 35 days, their thought is to just deny you your medicine. What if it were insulin?

Anyways, I see where you are coming from. I still think it could be fought in court, but like you said, they are issuing before the 35 days.