Sales, cultivation and possession were illegal under state law prior to Proposition 215.
Were; past tense; not any longer. Prior; before now; formerly. Is it sinking in yet?
You've claimed that there must have been such an intent, but when called on your error have been utterly incapable of providing the slightest support for your claim from any source whatsoever.
Ping me if you ever find any support for your "implied sales".
Here, have some more:
“The court further held that Proposition 215 does exempt seriously ill patients and their caregivers from California Health and Safety Code sections 11357 and 11358, which prohibit possession and cultivation of marijuana. However, the court disagreed with Trippet in further holding that Proposition 215 does not, under any circumstances, exempt such patients from sections 11359 and 11360, which prohibit the sale or giving away of marijuana. The Supreme Court of California denied review of the Peron decision on February 25, 1998.”
http://goliath.ecnext.com/coms2/gi_0199-2956201/United-States-v-Oakland-Cannabis.html