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CORRESPONDENCE - CS -1A
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CORRESPONDENCE - CS -1A
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City Clerk
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Agenda Packet
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12/18/2019
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11 <br />prohibition on assaulting other residents. Should such <br />a shelter still be viewed as available to an individual <br />who does not wish to abide by those rules? The answer <br />must surely be yes. <br />But now imagine that the same individual checks <br />in to the shelter, violates the rule against assaulting <br />other residents, and is evicted as a result. Should the <br />shelter now be regarded as available? If the question <br />is considered at the time of enforcement, the answer <br />would appear to be no. See Pet.App. 48a-49a <br />(suggesting that its rule would apply to individuals <br />who were "denied entry" to a shelter "for reasons other <br />than shelter capacity"). This cannot be right. There <br />is no justification for allowing homeless individuals to <br />exempt themselves from public sleeping ordinances <br />simply by violating rules that, ex ante, all would agree <br />they should be expected to follow. <br />This is no mere theoretical construct. The Orange <br />County Sheriffs Department —which is the contract <br />law -enforcement agency for many cities within its <br />borders —has advised amicus San Clemente that its <br />officers would not enforce the City's public camping <br />ordinance against individuals who have been evicted <br />from the San Clemente campsite, claiming that such <br />enforcement is barred by the decision below. This <br />regime —which rewards willful violations of even the <br />most uncontroversial shelter rules —is perverse and <br />dangerous. <br />And the same sort of temporal paradox reappears <br />in any number of contexts. For example, the opinion <br />below notes that two shelters in Boise deny admission <br />to anyone arriving after 8 PM. Pet.App. 48a. If <br />availability must be measured at the moment of <br />
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