Larry P. Cote – DEA Litigation & Compliance Attorney
Larry Cote is one of the nation’s foremost Drug Enforcement Administration (DEA) compliance attorneys. He focuses his practice on counseling clients across the spectrum of regulatory compliance and enforcement issues involving the Controlled Substances Act (CSA). Having spent six and a half years heading up a national law firm’s DEA Compliance and Litigation Practice Group, Larry took the practice to his own firm, Cote Law PLLC, in 2018.
Clients
Larry’s clients span the health care and pharmaceutical industries, from manufacturers and wholesale distributors to pharmacies, hospitals, and individual practitioners. He brings to them a broad and deep expertise in all compliance matters arising under the CSA and DEA regulations. Larry also represents clients in administrative and civil litigation matters, having tried a wide variety of cases before DEA’s Administrative Law Judges.
Innovative
In a series of positions at the United States Department of Justice (DOJ), Larry developed extensive litigation and government investigations experience. Immediately before his law firm tenure, Larry was associate chief counsel for the Diversion and Regulatory Litigation Section at DEA. In this position, he took a prominent role in many of DEA’s most significant enforcement actions and compliance efforts. Larry served as DEA’s legal adviser on matters regarding the diversion of legally-produced controlled substances and listed chemicals into illegitimate channels. He also managed a team of attorneys who represented the agency in administrative hearings regarding the revocation or denial of DEA registrations to handle controlled substances or listed chemicals, the scheduling of controlled substances, and the suspension of international shipments of listed chemicals.
Experience
Larry’s DOJ experience began as an associate general counsel at the Executive Office for Immigration Review. He then served as a trial attorney in the Civil Division. While at DOJ, Larry was detailed as a special assistant U.S. attorney for the U.S. Attorney’s Office for the District of Columbia and as an ethics advisor for the Office of Counsel to the President of the United States.
Larry was a major in the Judge Advocate General’s Corps, United States Army Reserve, and is a veteran of Operation Iraqi Freedom.
In addition to his legal practice, Larry serves on the Board of Directors of the Community Anti-Drug Coalitions of America, the premier membership organization representing those working to make their communities safe, healthy and drug-free.
Education:
- Albany Law School (J.D.)
- Union College (B.A.)
Bar Admissions:
- Maryland
- District of Columbia
Court Admissions:
- U.S. Court of Appeals, 4th Circuit
- U.S. Court of Appeals, 5th Circuit
- U.S. Court of Appeals, 7th Circuit
- U.S. Court of Appeals, 9th Circuit
- U.S. Court of Appeals, D.C. Circuit
Professional and Civic Activities:
- CADCA (Community Anti-Drug Coalition of America) (Board Member)
- American Society for Pharmacy Law (Member)
- Food and Drug Law Institute (Member)
- Health Care Compliance Association (Member)
- American Health Law Association (Member)
Professional Recognition:
2020 Community Anti-Drug Coalitions of America (CADCA), Champion for Drug-Free Kids
2001 American Bar Association, Legal Assistance for Military Personal Award for service on the Joint Services Family Assistance Center Legal Team, which provided legal support to family members of the victims of the 9/11 attack on the Pentagon
Insights:
The DEA is alleging Truepill, Cerebral’s former pharmacy partner, broke the law in filling prescriptions for highly regulated drugs, Business Insider, December 16, 2022
‘Untreated’: Patients with opioid addiction could soon lose access to virtual care, Politico, June 20, 2022
As Overdose Deaths Soar, DEA-Wary Pharmacies Shy From Dispensing Addiction Medication, Kaiser Health News, November 9, 2021
Biden Opioid Plan Puts Pharmacies On Notice, Law360, November 8, 2020
Co-author, DEA Disconnect Leads to Buprenorphine Bottlenecks, Journal of Addiction Medicine, November 11, 2020
How Johnson & Johnson companies used a ‘super poppy’ to make narcotics for America’s most abused opioid pills, Washington Post, March 26, 2020
Cloaked From Public View, DEA Drug Data Bolsters Opioid Suits, Ideastream, August 6, 2018
5 Takeaways As DEA Mulls Slashing Opioid Output, Law360, April 19, 2018
Pharmacists May Be Legally Liable for Opioid Overdoses, Medscape, June 30, 2017
As America’s Opioid Crisis Spirals, Giant Drug Distributor McKesson Is Feeling the Pain, Fortune, June 13, 2017
The DEA warned NFL doctors about drug laws in 2011. It didn’t go well, Washington Post, April 20, 2017
The real history of the DEA and opioids, Washington Post, December 1, 2017
Drug industry hired dozens of officials from the DEA as the agency tried to curb opioid abuse, Washington Post, December 22, 2016
Trump’s attorney general pick is bad news for legal marijuana, Business Insider, November 18, 2016
The Unintended Impact Of DEA’s New Registration Policy, Law360, November 18, 2016
FDA Adds Black-Box Warning To Opioids, Law360, March 22, 2016
Tackling Pot Law A Niche Practice As Some Firms Shy Away, Law360, August 22, 2014
Are Shippers Responsible for Legality of Goods They Transport? U.S. Case Against FedEx Involves Controlled Substances, The Wall Street Journal, July 27, 2014
Presentations
“Peer-Proven Strategies for Managing Controlled Substance Prescriptions”
National Community Pharmacists Association Annual Convention, October 2022
“Everything You Always Wanted to Know (But Were Afraid to Ask): An Open Discussion on Recent Developments in Controlled Substance Compliance”
American Society for Pharmacy Law, Developments in Pharmacy Law Seminar XXXI, November 2020
Controlled Substances Legal Panel
Healthcare Distribution Management, 2020 Distribution Management Webinar Series, April 2020
“Dispensing Controlled Substances: Navigating a Minefield of Contradictions”
American Society for Pharmacy Law, Developments in Pharmacy Law Seminar XXX, November 2019
“DEA Update”
Specialty Pharma Association Regulatory Workshop, August 2019
Controlled Substances Legal Panel
2018 Distribution Management Conference and Expo, March 2018
“Update on State and Federal Enforcement Initiatives”
2018 Summit on Controlled Substances- Regulation, Litigation, and Enforcement, January 2018
“The DEA Is Here to Stay: Recent Enforcement Actions and Using Your Own Data to Protect Against Diversion”
American Society for Pharmacy Law, Developments in Pharmacy Law Seminar XXVIII, November 2017
“Satisfying DEA Standards When Dispensing Controlled Substances”
Online course, LearnSomething, Inc., November 2014
“Controlled Substances: Understanding Pharmacists’ Obligations and Risks”
Educational Webinar Series, April 2014
“Shifting Sands: Preparing for Changes in Diversion, Regulations, and Enforcement”
Buzzeo PDMA’s 17th Annual Controlled Substance & State Regulatory Conference, April 2014
“Suspicious Order Monitoring – What’s Next?”
HDMA Distribution Management Conference and Technology Expo, March 2014