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on California's scheme of governance. Cf. Columbus v. <br />Ours Garage & Wrecker Serv., Inc., 536 U.S. 424, 437 <br />(2002) ("Whether and how to use th[e] discretion [to <br />delegate governmental powers to local government <br />units] is a question central to state self-government.")3 <br />The Ninth Circuit's rule also raises an additional <br />puzzle. Suppose that, in an attempt to comply with <br />the decision below, a city purchased a building in a <br />neighboring city in order to operate it as a shelter. Are <br />those beds "available" to homeless individuals in the <br />city that owns and operates the shelter, or would that <br />city violate the Eighth Amendment by enforcing its <br />anti -camping ordinance in reliance on that shelter? <br />Would the answer change if the city offered to provide <br />free transportation to the shelter? How convenient <br />would that transportation have to be? The decision <br />below provides no answers —and no certainty. <br />Furthermore, some homeless individuals may <br />assert that they have a legal or practical obligation to <br />remain in a limited geographical area (for example, to <br />receive treatment for addiction). For such individuals, <br />must shelter be "available" within that limited area? <br />Again, the opinion below is silent. <br />3 The confusion as to the relevant jurisdictional level is <br />reflected in a settlement that Orange County entered in order to <br />resolve claims resembling those addressed by the decision below. <br />Notice of Filing Settlement of Class Action, Orange Cty. Catholic <br />Worker o. Orange Cty., et al., No. 8:18-cv-00155, Dkt. 318 (C.D. <br />Cal., July 23, 2019). Orange County agreed that, in attempting <br />to place homeless individuals in shelters, it would not transport <br />those individuals across "Service Planning Areas." Id. at 10. <br />These "Service Planning Areas" are arbitrary units with no <br />preexisting jurisdictional significance or relevance under state <br />law or otherwise. See id. at 9. <br />