The reference to "certain studies" is to the then-forthcoming National Commission on Marijuana and Drug Abuse. In 1972, the Commission released a report favoring decriminalization of marijuana. The Richard Nixon administration took no action to implement the recommendation, however. In 1972, the National Organization for the Reform of Marijuana Laws filed a rescheduling petition under provisions of the Act. The government declined to initiate proceedings on the basis of their interpretation of U.S. treaty commitments. A federal Court ruled against the government and ordered them to process the petition ("NORML v. Ingersoll 497 F.2d 654 (1974)"). The government continued to rely on treaty commitments in their interpretation of scheduling related issues concerning the NORML petition, leading to another lawsuit ("NORML v. DEA 559 F.2d 735 (1977)"). In this decision, the Court made clear that the Act requires a full scientific and medical evaluation and the fulfillment of the rescheduling process before treaty commitments can be evaluated. "See Removal of cannabis from Schedule I of the Controlled Substances Act".