Michigan's Cannabis Regulatory Agency has filed a formal complaint against Trap Stars Outlet, an adult-use retailer in New Buffalo, alleging the licensee recorded hundreds of vape cartridge sales in the state's seed-to-sale tracking system that surveillance footage, point-of-sale receipts, and basic inventory logic couldn't support. The complaint, which targets the dispensary's adult-use license, centers on 76 Metrc transactions logged in a 44-minute window - 528 units, priced at six or seven cents each - that investigators say don't hold up under scrutiny.
What the Metrc Records Actually Showed
On the morning of September 30, 2025, Trap Stars' Metrc entries recorded 76 separate sales of MuhaMeds disposable vape cartridges between 9:56 a.m. and 10:40 a.m. Combined, those transactions accounted for 528 cartridges containing a total of 1,056 grams of marijuana concentrate. Each receipt reflected a transaction cost of $0.06 or $0.07.
That pattern should raise flags for any compliance professional familiar with Michigan's adult-use rules. At the unit level, those prices don't reflect a conventional retail transaction - they look more like what the industry sometimes calls "zeroing out" or "pennying out" inventory: a way of moving product off the books at nominal cost. Trap Stars' own internal SOP on discounting and promotional giveaways explicitly instructs staff never to do exactly that without a corresponding legitimate sale. The agent determined the dispensary wasn't following its own written procedure.
When a CRA agent visited on October 8, the general manager could produce only one POS receipt matching those 76 Metrc entries - a receipt showing seven cartridges sold, totaling 14 grams. Surveillance video of the same time window showed customers on the sales floor buying primarily deli-style flower. The vape cartridge volume recorded in Metrc wasn't visible anywhere on camera.
The Paper Trail Gets Messier
Over the following weeks, the picture didn't get cleaner. Trap Stars provided 37 of the 76 requested POS receipts in early October. Of those, 34 shared the same customer ID and the same budtender ID - a detail that, in a dispensary processing dozens of individual customer transactions, would be unusual under normal retail conditions. Those receipts reflected 237 cartridges and 474 grams of concentrate, and several contained line items coded as "(FREE) 100% DISCOUNT" and "(FREE) 100% DISCOUNT open prot."
The remaining 41 receipts didn't arrive until November 13 - more than six weeks after the original complaint was filed. They showed an additional 284 cartridges sold, again under the same customer and budtender IDs as the earlier batch. The one numeric difference between the Metrc records and the POS records was a $0.01 discrepancy on each receipt, which the agent traced to a line item for excise tax.
The manager's explanation, offered in November, was that the cartridges were given away as promotional items - specifically, that a customer who purchased a qualifying amount of product received a promotional item for $0.01. He also indicated the relevant transactions occurred on camera between September 29 and September 30. What he didn't provide: video evidence, corroborating transaction records, or any documentation that tied the promotional structure to the volume of product that left the facility.
Where the Compliance Failures Actually Sit
The CRA cited two specific rule violations. The first is Rule 420.104(3)(b), which requires marijuana retailers to accurately enter all transactions, current inventory, and related information into Metrc - Michigan's statewide monitoring system. The second is Rule 420.206a(3), which mandates that licensed businesses maintain current, on-site standard operating procedures that cover the activities necessary for compliance.
Here's the catch with the SOP issue: Trap Stars eventually produced an SOP for discounting and promotional giveaways that the agent found structurally acceptable. The problem wasn't the document - it was the gap between what the document required and what actually happened. The SOP said every promotional transaction must clearly show the original item, the discount applied, and the total paid. It explicitly prohibited zeroing out product without a corresponding sale. The receipts in evidence didn't meet that standard. Writing a compliant SOP and then operating outside it can, from a regulatory standpoint, actually compound the problem - it establishes that the licensee knew what proper procedure looked like.
For dispensary operators broadly, this case illustrates why POS and Metrc alignment matters as a live operational discipline, not just a periodic audit function. When the two systems diverge - and in this case they diverged significantly - the discrepancy becomes the record. Regulators reviewing Metrc data can flag anomalies without stepping foot in a store. A cluster of 76 transactions in 44 minutes at sub-ten-cent price points is exactly the kind of pattern that automated compliance review or a routine complaint can surface quickly.
The CRA can impose fines, restrict the license, suspend or revoke it, or decline renewal. The formal complaint is an allegation; no final determination has been issued. Trap Stars did not respond to a request for comment.
