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Just as the Eighth Amendment prohibits the infliction of criminal punishment on an individual for being a drug addict, or for involuntary public drunkenness that is an unavoidable consequence of being a chronic alcoholic without a home, the Eighth Amendment prohibits a city from punishing involuntary sitting, lying, or sleeping on public sidewalks that is an unavoidable consequence of being human and homeless without shelter in the city.
Appellant homeless individuals lived on the streets of Los Angeles's Skid Row district. Appellants filed a 42 U.S.C.S. § 1983 action alleging that enforcement of L.A., Cal., Mun. Code § 41.18(d) (2005) violated their Eighth Amendment rights. Specifically, they alleged that enforcement of the city ordinance, which criminalized sitting, lying, or sleeping on public streets and sidewalks, violated their constitutional rights because they were unable to obtain shelter on the nights in question. The district court held that the only relevant inquiry is whether the ordinance at issue punishes status as opposed to conduct, and that homelessness is not a constitutionally cognizable status. The district court granted summary judgment to appellees, who were the City of Law Angeles and its police department. Appellants sought review.
Did the enforcement of Los Angeles Mun. Code § 41.18(d) (2005) violate the Eighth Amendment rights of the homeless individuals by criminalizing the unavoidable act of sitting, lying, or sleeping at night while being involuntarily homeless?
Reversing, the United States Court of Appeals held that appellant homeless individuals had standing to challenge the City of Los Angeles ordinance because they sought only prospective injunctive relief, sought only to have its enforcement enjoined and did not ask for it to be declared unconstitutional, and they demonstrated both past injuries and a real and immediate threat that they were likely to be fined, arrested, incarcerated, prosecuted, and/or convicted for violating the ordinance; two of the six appellants were convicted and sentenced for violating the ordinance. The Court held that because there was substantial and undisputed evidence that the number of homeless persons in the city far exceeded the number of available shelter beds at all times, including on the nights of appellants' arrest or citation, the city encroached on appellants' Eighth Amendment rights by criminalizing the unavoidable act of sitting, lying, or sleeping at night while being involuntarily homeless.
As for the applicable standards of review, the Court (1) reviews de novo a district court's legal determination that a statute is constitutional; (2) reviews for clear error a district court's findings of fact; and (3) reviews de novo a district court's decision to grant or deny summary judgment.