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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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12 <br />enforcement, a homeless individual could be cited for <br />camping in public at 7:30 PM, but not at 8:30 PM (even <br />though it would still be true at 8:30 PM that she had <br />been free to go to the shelter at 7:30 PM). <br />The Boise shelters described in the opinion below <br />also do not allow individuals who voluntarily leave the <br />shelters to return immediately. Pet.App. 48a. It <br />would be odd to treat a shelter as unavailable to <br />someone who is excluded from it only because he made <br />a choice to leave; yet that is what the opinion below <br />suggests. Pet.App.48a-49a. <br />Another version of the same difficulty arises with <br />respect to homeless individuals who travel from one <br />location to another. Suppose there is adequate shelter <br />in City A, but a homeless individual makes a voluntary <br />decision to relocate to City B. Should shelter in City A <br />be viewed as available to that individual? May City B, <br />at least, impose a durational residency requirement <br />such that its shelters are available only to persons who <br />have lived in City B for some prescribed period? <br />Prohibiting such requirements would be untenable as <br />a practical matter; a desirable city could be forced to <br />provide more and more shelter, ad infinitum, as more <br />homeless individuals arrived from all over the country. <br />And yet, again, that is arguably what the decision <br />below would require. <br />In all of these examples, the conceptual problem is <br />traceable to the difficulty of assessing when an action <br />should be considered "voluntary." The decision below <br />completely fails to grapple with this question. Jones v. <br />City of Los Angeles —an earlier Ninth Circuit opinion <br />which reached the same conclusion but was vacated <br />due to settlement —analyzed the matter a bit more <br />
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