I ran across this which is interesting...

In general, the courts have held that cannabis clubs cannot serve as legal "primary caregivers" for large numbers of patients. Some persons have claimed caregiver status while growing for multiple numbers of patients on the theory that they are providing for their patients' health or safety. This defense has been successful in court for caregivers growing for small numbers of patients. However, it was rejected by a state court of appeals in the Peron decision, where the court held that Peron's San Francisco Cannabis Buyers' Club could not reasonably claim to function as a "primary caregiver" for its 8000 clients.