Washington, D.C. Office
Tel: (202) 372-9524
Fax: (202) 372-9593

Larry P. Cote

Partner

Larry Cote is one of the most preeminent and highly regarded Drug Enforcement Administration (DEA) compliance attorneys in the country, counseling clients on a broad range of regulatory compliance and enforcement issues involving the Controlled Substances Act (CSA). He leads Quarles & Brady’s nationally recognized DEA Compliance & Litigation Practice Group.
Larry represents and advises manufacturers, wholesale distributors, pharmacies, hospitals, and individual practitioners on the full array of compliance matters relating to their obligations under CSA and DEA's regulations. He also represents registrants in administrative and civil litigation matters in actions brought under the CSA and has extensive experience trying cases before DEA's Administrative Law Judges.
Larry has significant experience navigating government investigations and litigation, having served in a variety of positions at the United States Department of Justice (DOJ). Prior to joining Quarles & Brady, Larry served as the associate chief counsel for the DEA's Diversion and Regulatory Litigation Section, where he worked at the forefront of the largest enforcement actions and compliance initiatives undertaken by DEA. In that capacity, he was DEA’s legal advisor on issues related to the diversion of legally produced controlled substances and listed chemicals into illegitimate channels. Larry managed a team of attorneys responsible for representing the agency in administrative hearings regarding the revocation or denial of DEA registrations for physicians, pharmacies, manufacturers, distributors, importers, and exporters to handle controlled substances or listed chemicals, the suspension of international shipments of listed chemicals, and the scheduling of controlled substances.
Prior to joining DEA, Larry was a trial attorney in the DOJ Civil Division and an associate general counsel at the agency's Executive Office for Immigration Review. During his time at the DOJ, Larry was also detailed to serve as special assistant U.S. attorney for the U.S. Attorney's Office for the District of Columbia and as ethics advisor for the Office of Counsel to the President of the United States.
Larry is a major in the Judge Advocate General’s Corps, United States Army Reserve, and is a veteran of Operation Iraqi Freedom.

Legal Services

  • Health & Life Sciences
  • DEA Compliance & Litigation
  • Pharmacy
  • Higher Education

Education and Honors

  • Albany Law School (J.D., 1997)
  • Union College (B.A., 1994)

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

Professional and Civic Activities

  • American Society for Pharmacy Law (Member)
  • St. Jude Children's Research Hospital, The St. Jude Open, Washington, D.C. (Committee Member)
  • CADCA (Community Anti-Drug Coalition of America) (Board Member)
  • Sports Lawyers Association (Member)

Professional Recognition

  • 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

Publications and Presentations

08/16/18
"DEA Slashes Opioid Manufacturing Quotas for 2019"
DEA Chronicles

04/18/18
"DEA Proposes Changes to Quota Regulations"
DEA Chronicles

02/15/18
"DEA Gives Wholesalers Access to Some ARCOS Data, but Not Quantities Purchased"
DEA Chronicles

01/23/18
"Enforcement Initiatives Just One of the Topics at the Summit on Controlled Substances"
DEA Chronicles

12/17/17
"Are DEA Administrative Hearings Fundamentally Unfair to Registrants?"
DEA Chronicles

12/15/17
"Be Careful What You Wish For: DEA to Update Suspicious Order Reporting Regulations"
DEA Chronicles

12/13/17
"Bipartisan Agreement that News Reports Regarding the Ensuring Patient Access and Effective Drug Enforcement Act are Light on Facts"
DEA Chronicles

12/01/17
"The real history of the DEA and opioids"
The Washington Post

11/02/17
"An “Open Letter” to President Trump Regarding the Prescription Drug Abuse Epidemic"
DEA Chronicles

10/18/17
"The Other Side of the Story: DEA Enforcement in the Opioid Crisis"
DEA Chronicles

10/10/17
"West Virginia Imposes New Suspicious Order Reporting Requirements"
DEA Chronicles

07/05/17
Taxing Opioids to Address Prescription Drug Abuse
Tax Law Alert

07/05/17
"Taxing Opioids to Address Prescription Drug Abuse"
DEA Chronicles

07/02/17
"DEA Prevails Over Masters Pharmaceutical, Inc."
DEA Chronicles

06/20/17
"Oregon Adds Suspicious Order Reporting to Wholesale Distributor Requirements"
DEA Chronicles

06/19/17
Oregon Adds Suspicious Order Reporting to Wholesale Distributor Requirements
Health Law Alert

03/14/17
"Washington Post Article Highlights Alleged Improper Drug Practices By NFL Teams"
DEA Chronicles

12/20/16
"DEA Reverses Decision to Change Registration Policy"
DEA Chronicles

11/18/16
"The Unintended Impact Of DEA's New Registration Policy"
Law360

11/03/16
"DEA Changes Longstanding Registration Policy"
DEA Chronicles

07/21/16
"DEA: Regulatory Update and Recent Trends in Enforcement"
Quarles & Brady Pharmacy Law Symposium

07/29/15
"GAO Issues Another Report Involving DEA"
DEA Chronicles

07/23/15
"DEA: Recent Trends in Enforcement"
Quarles & Brady Pharmacy Law Symposium

07/20/15
"DEA to Continue Take Back Programs"
DEA Chronicles

05/21/15
"DEA Announces Major Enforcement Action"
DEA Chronicles

05/06/15
"Senate Committee Questions DEA on Quota Process"
DEA Chronicles

03/08/15
"GAO Report Criticizes DEA Quota Process"
DEA Chronicles

02/16/15
"Second Bill Introduced in the Senate to Amend the Controlled Substances Act"
DEA Chronicles

02/12/15
"Legislation Introduced in Senate Seeking to Amend CSA"
DEA Chronicles

11/24/14
"Satisfying DEA Standards When Dispensing Controlled Substances"
Online course for LearnSomething, Inc.

07/29/14
"FedEx Pleads Not Guilty"
DEA Chronicles

05/27/14
"NABP Releases 'Red Flags'"
DEA Chronicles

04/11/14
“Shifting Sands: Preparing for Changes in Diversion, Regulations, and Enforcement”
BuzzeoPDMA’s 17th Annual Controlled Substance & State Regulatory Conference

04/08/14
“Controlled Substances: Understanding Pharmacists' Obligations and Risks”
Educational Webinar Series

03/11/14
“Suspicious Order Monitoring - What's Next?”
HDMA Distribution Management Conference and Technology Expo

03/05/14
"Suspicious Order Monitoring – What’s Next?"
DEA Chronicles

02/27/14
"DEA Takes the First Step Towards Rescheduling Hydrocodone Combination Products"
DEA Chronicles

01/16/14
“American Conference Institute’s Legal, Regulatory & Compliance Forum on Controlled Substances”
American Conference Institute (January 16- 17, 2014)

12/02/13
“Developments in Controlled Substances Regulation”
Ohio-Kentucky Academy of Managed Care Pharmacy at Sullivan University College of Pharmacy

11/21/13
"Upcoming Conference: Controlled Substances Forum"
DEA Chronicles

11/17/13
“The Evolving Concept of Corresponding Responsibility”
American Society for Pharmacy Law Seminar

10/21/13
"DEA Holds Drug Take-Back Event"
DEA Chronicles

10/09/13
"Veterans’ Affairs Hearing on VA Prescribing Practices"
DEA Chronicles

09/24/13
"DEA Finalizes 2014 Quota"
DEA Chronicles

08/21/13
"Eisai Inc. Sues DEA"
DEA Chronicles

08/11/13
"A Pharmacist’s Obligation: Corresponding Responsibility and Red Flags of Diversion"
DEA Chronicles

06/12/13
"DEA and Walgreens Settlement"
DEA Chronicles

05/07/13
"Upcoming DEA Conferences"
DEA Chronicles

05/06/13
"Obtaining DEA Quota to Manufacture Controlled Substances"
DEA Chronicles

04/10/13
"Suspicious Order Monitoring and More: DEA's Expectation of the Supply Chain"
BuzzeoPDMA's 16th Annual Controlled Substances, PDMA and State Conference (April 10-12, 2013)

03/28/13
"DEA Litigation and Enforcement Update"
The Food and Drug Law Institute, Controlled Substances Regulation

03/21/13
"Oral Argument: Walgreen Co. v. DEA"
DEA Chronicles

03/12/13
"Significant Shift in Drug Diversion"
DEA Chronicles

03/05/13
"The Key to Suspicious Order Monitoring Is DEA: Design, Execute, Assess"
HDMA Distribution Management Conference and Technology Expo

02/27/13
"Suspicious Order Monitoring"
DEA Chronicles

02/26/13
"A Controlled Substances Act Primer: Understanding DEA's Other War on Drugs"
St. Mary's University School of Law

02/26/13
"The Last Line of Defense: A Pharmacist's Corresponding Responsibility and Identifying Red Flags"
University of the Incarnate Word, Feik School of Pharmacy

02/20/13
"DEA Compliance Programs"
DEA Chronicles

02/13/13
"2012 DEA Enforcement Actions: A Year in Review"
DEA Chronicles

01/24/13
DEA Enforcement Actions: A Year in Review
Health Law Update

01/02/13
DEA Notice of Proposed Rulemaking on the Disposal of Controlled Substances
Health Law Update

12/07/12
U.S. v. Caronia: Second Circuit Holds that the First Amendment Protects Speech Promoting Off-Label Drug Use
Health Law Update

11/12/12
"Developments in Controlled Substances Regulation and a Foggy Crystal Ball"
American Society for Pharmacy Law Seminar

09/20/12
"State & Local Government Relations Seminar"
Public Affairs Council

06/19/12
DEA Revokes Doctor's Registration for Misconduct and Lack of State Authority
Health Law Alert

06/18/12
DEA Issues Six Final Orders
Health Law Alert

06/12/12
DEA Denies Application Based on Past Misconduct of Pharmacist in Charge
Health Law Alert

01/01/10
"The HIPAA Issue/Excuse: Obtaining Medical Information within HIPAA's Medical Privacy Rules"
National Methamphetamine and Pharmaceutical Initiative Conference

01/01/10
"Administrative Sanctions and Strategies: Assistance in State Cases"
National Methamphetamine and Pharmaceutical Initiative Conference