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20 would provide much -needed clarity in other circuits, given that courts of appeals have now taken three different positions on the constitutionality of criminalizing purportedly involuntary conduct. Pet. 20-25; see, e.g., Manning v. Caldwell, 930 F.3d 264, 281-85 (4th Cir. 2019) (en banc). As the many problems discussed above illustrate, the decision below is profoundly misconceived from a procedural standpoint. It simply makes no sense for courts to attempt to resolve these complex issues with broad pre -enforcement injunctions. If a particular homeless person cannot comply with a particular ordinance, that issue should be addressed in that person's criminal trial —perhaps via the traditional necessity defense, recognized under California law. See In re Eichorn, 81 Cal. Rptr. 2d 535, 539-40 (1998). That approach would properly allow individual circumstances to be taken into account. By contrast, the blunderbuss approach adopted by the panel will severely undermine the ability of local governments to address difficult social problems. This Court should step in and prevent these grave practical consequences from coming to pass.