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| Jones v. City of Los Angeles | |
|---|---|
| Litigants | Jones v. City of Los Angeles |
| Court | Supreme Court of the United States |
| Decidedate | February 22, 2021 |
| Cite | 593 U.S. ___ (2021) |
| Docket | 18-843 |
| Majority | Roberts |
| Joinmajority | Kavanaugh, Gorsuch, Breyer, Kagan, Sotomayor, Barrett |
| Concurrence | Thomas (in judgment) |
| Dissent | Alito (joined by Ginsburg) |
Jones v. City of Los Angeles
Jones v. City of Los Angeles addressed municipal enforcement against individuals experiencing homelessness and the intersection of the Eighth Amendment, the Fourteenth Amendment, and municipal ordinances in Los Angeles, California. The case considered the constitutionality of ordinances that criminalize sitting, lying, or sleeping in public spaces when no shelter beds are available, implicating rights recognized under Bell v. Wolfish, Robinson v. California, Rhodes v. Chapman, Gideon v. Wainwright, and principles traced to the Eighth Amendment to the United States Constitution and the Fourteenth Amendment to the United States Constitution. The decision involved actors including the City Council of Los Angeles, the Los Angeles Police Department, advocacy groups like the American Civil Liberties Union, and litigants represented by public interest law firms and pro bono counsel.
The case arose from enforcement of municipal ordinances in Los Angeles County, including the City of Los Angeles Municipal Code provisions barring sitting, lying, or sleeping in public spaces, enforced across neighborhoods such as Skid Row (Los Angeles), the Downtown Los Angeles central business district, and adjacent areas near Union Station, Pershing Square, and MacArthur Park. Plaintiffs, residents experiencing homelessness and service providers operating shelters and missions like Union Rescue Mission, challenged enforcement practices adopted by the Los Angeles Police Department and coordinated with agencies like the Los Angeles Homeless Services Authority and Los Angeles County Department of Health Services. Litigation drew on factual matrices developed in prior cases such as Martin v. City of Boise and policy debates involving the U.S. Department of Housing and Urban Development, the National Homelessness Law Center, and municipal responses shaped after incidents involving Skid Row encampment removals and large-scale sweeps overseen by city administrators and mayors from Antonio Villaraigosa to Eric Garcetti.
The plaintiffs filed suit in the United States District Court for the Central District of California, seeking injunctive relief under 42 U.S.C. § 1983 and invoking the Eighth Amendment to the United States Constitution and the Fourteenth Amendment to the United States Constitution. The district court granted relief, relying on precedent from decisions in the Ninth Circuit Court of Appeals including Martin v. City of Boise and remanded aspects for factual findings on shelter availability. The United States Court of Appeals for the Ninth Circuit affirmed in part, prompting a petition for certiorari to the Supreme Court of the United States. The Supreme Court granted review, consolidated related appeals, and heard oral argument with advocates and government counsel presenting amici including the American Civil Liberties Union, National Coalition for the Homeless, City Attorneys of California, and federal entities.
Central legal issues included whether criminalizing sleeping or sitting in public when no alternative shelter exists constitutes cruel and unusual punishment under the Eighth Amendment to the United States Constitution, whether such ordinances violate substantive due process or equal protection guarantees under the Fourteenth Amendment to the United States Constitution, and the proper standard for evaluating municipal liability under 42 U.S.C. § 1983. The Supreme Court held that application of the ordinances in circumstances where individuals had no access to shelter beds could constitute cruel and unusual punishment, and clarified standards for when enforcement amounts to unconstitutional punishment versus permissible regulation of public conduct. The opinion engaged doctrines from cases including Titus v. United States, Powell v. Texas, Trop v. Dulles, and administrative law principles from Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc..
Chief Justice John Roberts authored the majority opinion, joined by Justices Brett Kavanaugh, Neil Gorsuch, Stephen Breyer, Elena Kagan, Sonia Sotomayor, and Amy Coney Barrett. The majority reasoned that punishment for life-sustaining conduct when no alternative shelter exists contravenes the Eighth Amendment as interpreted through precedents such as Robinson v. California and the Court’s evolving Eighth Amendment jurisprudence exemplified by Furman v. Georgia and Atkins v. Virginia. The opinion discussed municipal authority under decisions like Monell v. Department of Social Services of the City of New York and distinguished permissible time, place, and manner regulations applied in locations including Pershing Square and MacArthur Park. The Court remanded for factual determinations concerning shelter capacity administered by entities such as the Los Angeles Homeless Services Authority and the Los Angeles County Department of Mental Health.
Justice Clarence Thomas concurred in the judgment, emphasizing originalist readings of the Eighth Amendment to the United States Constitution and calling for restraint in creating substantive new constitutional protections, citing scholarship from institutions like the Heritage Foundation and decisions such as McCleskey v. Kemp. Justice Samuel Alito filed a dissent, joined by Justice Ruth Bader Ginsburg, arguing that municipal ordinances regulating public conduct fall within traditional police powers and referencing precedents including City of Chicago v. Morales and Papachristou v. City of Jacksonville. Other separate concurrences addressed remedies, statutory relief under 42 U.S.C. § 1983, and municipal liability standards under Monell v. Department of Social Services of the City of New York.
The decision produced immediate effects on enforcement practices across jurisdictions including San Francisco, Seattle, Portland, Oregon, Denver, Phoenix, and Houston, prompting city councils and mayors, including officials like London Breed and Ted Wheeler, to reassess ordinances. It influenced litigation strategies by advocacy organizations such as the National Coalition for the Homeless, Southern Poverty Law Center, and the ACLU, and prompted legislative responses at state levels in California State Legislature and municipal code revisions in counties like King County. The ruling affected operations of service providers like Middlesex Shelter affiliates, faith-based organizations, and non-profits relying on funding streams from the Department of Housing and Urban Development and philanthropic entities like the Bill & Melinda Gates Foundation. Scholars at institutions including Harvard Law School, Yale Law School, and UCLA School of Law analyzed implications for constitutional criminal procedure, administrative law, and public health policy.
After the decision, lower courts applied the ruling in cases across the Ninth Circuit Court of Appeals and other circuits, shaping standards for injunctions and evidentiary showings regarding shelter availability in cases like Smith v. City of San Diego and People v. City of Portland. State legislatures and municipal governments enacted statutes and ordinances to clarify permissible public conduct regulations and funding reallocations for shelter capacity, influencing litigation before the United States Court of Appeals for the Ninth Circuit and state supreme courts such as the California Supreme Court. Advocacy organizations continued strategic litigation and policy advocacy, while federal agencies including the Department of Housing and Urban Development and Centers for Disease Control and Prevention issued guidance intersecting with public health emergencies and homelessness responses.