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Home My WebLink About8/15/2023 Item PC, Jorgeson - Handouts at the meetingSpeaker Time - 3 Minutes CITY OF SHIZ LUIS OBISPO SPEAKER CARD The City Council and staff appreciate your participation at this public meeting. Meeting Date: Y —' � — �; 3 Phone (optional): Print Name: Provide name the wi Item No. ddress (optional): it sounds (phonetically): Subject: /Aoryl , Jg44 Note: Completion of this card is voluntary. All citizens may attend meetings and address the City Council. However, this form will assist the Mayor in facilitating public comments, the City Clerk's office in ensuring the correct spelling of names in the minutes (addresses are not included in the minutes), and enable staff to follow up with speakers, as appropriate. Municipal Advocate/Lobbying: If you are paid by any other person or organization to communicate with any officer, employee, or commission of the City of San Luis Obispo for the purpose of influencing local legislative or discretionary action, you may qualify as a municipal advocate or lobbyist. If you are not already registered, please fill out a Municipal Advocate registration form (available in the foyer). (SLOMC Section 2.64) PLEASE GIVE THIS CARD TO THE CITY CLERK, seated at the center staff table below the City Council QUESTIONS AND CONCERNS FOR SLO CITY Why does the City of SLO? Continue to violate the Martin v Boise federal law if there are new processes in place? Continue to waste taxpayers' money on a federal lawsuit against the City when other cities understand the law and are in compliance? We could use that money for housing just as we could use the money spent on twomexicans.com to help our homeless instead of hurting them; Continue to criminalize homelessness? Continue citing people for illegal lodging during daylight hours when Ordinance 12.23.030 states no illegal camping at night? Continue to confiscate peoples' personal property and not give receipts or notice before they come? Talk about trash when the trash cans we put along the BJT were removed "because we didn't have a permit?" Close public loos at night causing people to urinate and defecate outside... Why don't we have anything but Prado when they are full most of the time and there are at least 5-10 folks every single night who can't get in? Is anything in store for people until the proposed Welcome Home project may or may not be approved for building? 125 people were counted along the BJT by a top county official and the "Welcome Home" project will only have 80 beds ... do the rest stay along the BJT? The more folks are forced up into the hills, the more fires we will have this summer and fall; We need permanent mobile home parks or campgrounds (not safe parking sites) that our homeless neighbors can afford... and a sanctioned encampment or campground until truly affordable housing is built up; but some will always fall through the cracks in service; Out of the city's $30mil budget for 23-24, can't homelessness receive more than .026% of the funding? 87 communities in the US have ended homelessness and we could too (proof attached). SLO could be a beacon of hope in America by building affordable tiny house villages that involve entire communities - and we could help. Thank you for listening. Becky Jorgeson HOPE'S VILLAGE s iv+vjiv >e.sv' e a ox-o i 805-234-5478 About Us Take Action Resources News and Events Contact Us Q HOMELESSNESS Supreme Court Lots Martin v. Boise Stand: Homeless Persons Cannot Be Punished for Steeping in Absence of Alternatives FOR IMMEDIATE RELEASE Contact, Crys Letona Communications Associate Share- cletona0hometesslaw.org > (December 16, 20% Washington, DO - This morning, the U.S. Supreme Court denied a petition by the city of l3olse to review the case Martin xRaise (formerly Beg v Boise). This Leaves In place earlier rulings by the 90 Circuit that homeless persons cannot be punished for slmpl rig outside on public property In the absence of adequate aiternativtn. People experiencing unsheltered homelessness ---at Least In the Oh Circuit --can steep more safety without facing criminal punishment for simply trying to survive on the streets. inepup. o.m.,.,wisciedswmissued wmrt=comment. i;,,,�iV�r the Apr12019 I - . z. ruling Is binding In the gM Circuit covering nine states Including most of the western states, and carries national. influence. The ruling also means that homeless Individuals who have reaelved criminal, citations under Boise's policy can now proceed with their constitutional claims against the City. The I t io i r, I (The Low CoerrtaA which flied the case In and ; :-n :-P, halLs this decision as being essential to encouraging cities to propose constructive allematives to homelessness. NEED;] I 141liq Wwr.101_11111 1 P11 1_1� ILIALI R1r.+**-xq_ MqK61141 INKINA L91ffftR111L;4r-*:VJFr4 ikyj I 11= a I ](RITA ra r } 'r 1United States • Interagency a: Counci*1 on Homelessness i Gi *', Communities That Have Ended Homelessness These communities have a system in place to ensure that homelessness is rare, brief, and one-time. To be recognized as having achieved the goal, communities must meet the requirements laid out in the federal ,criteria and benchmarks for ending homelessness. *83 communities and 3 states have ended Veteran homelessness * 4 communities have ended Chronic & Veteran homelessness States that have at least one community that has ended homelessness Communities and states that have ended Veteran homelessness (in order of announcement): New Orleans, LA 2. Houston, TX 3. Mobile, AL 4. Troy, NY 5. Saratoga Springs, NY 6. Flagler County, FL 7. Lancaster City & County, PA 8. Cumberland County/Fayetteville, NC 9. Winston-Salem, NC 10. Las Cruces, NM 11. Syracuse, NY 12. Las Vegas, NV 13. Commonwealth of Virginia 14. Schenectady, NY 15. Rochester, NY 16. Albany, NY 17. Rockford, IL 18. Philadelphia, PA 19. Mississippi Gulfport/Gulf Coast Regional Continuum of Care 20. Montgomery County, MD 21. Volusia County/Daytona Beach, FL 22. Connecticut 23. Reading/Berks County, PA 24. Lynn, MA 25. Des Moines, IA 26. San Antonio, TX 27. Terrebonne Parish, LA 28. Hattiesburg, MS 29. Long Island, NY 30. Bergen County, NJ 31. Austin, TX 32. Middlesex County, NJ 33. Buffalo/Western New York 34. State of Delaware 35. Dayton/Montgomery County, OH 36. DeKalb County, GA 37. Portland/Gresham/Multnomah County Continuum of Care 38. Shreveport, LA 39. Riverside, CA 40. Santa Fe, NM 41. Chattanooga, TN 42. Fort Myers/Lee County, FL 43. Southwest Minnesota Continuum of Care 44. Nashua, NH 45. Punta Gorda/Charlotte County, FL 46. Akron/Barberton/Summit County, OH 47. LaCrosse, WI 48. Scranton/Lackawanna County, PA 49. Lehigh Valley, PA 50. Massachusetts Balance of State Continuum of Care 51. Will County, IL 52. Lowell, MA 53. Northwest Minnesota Continuum of Care 54. Moorhead/West Central Minnesota Continuum of Care 55. Kent County, MI 56. Dutchess County, NY 57. Atlanta, GA 58. Kansas City, KS/Kansas City, MO, and Independence/Lee's Summit/Jackson, Wyandotte Counties Continuum of Care 59. Pittsburgh/McKeesport/Penn Hills/Allegheny County CoC 60. Nebraska Balance of State Continuum of Care 61. Delaware County, PA 62. Beckley, WV/Beckley VAMC Catchment Area, including City of Beckley and Raleigh, Fayette, Nicholas, Summers, Greenbrier, Monroe, Pocahontas, Wyoming, Mercer, McDowell and Clay counties 63. Norman/Cleveland County, OK 64. Kittitas County, WA 65. Miami -Dade County, FL 66. Lincoln, NE 67. Jackson/West Tennessee Continuum of Care 68. Little Rock, AR 69. Northeast Minnesota Continuum of Care 70. Central Illinois Continuum of Care 71. Saint Joseph/Andrew, Buchanan, DeKalb Counties, MO, Continuum of Care 72. Lexington, KY 73. Lansing, East Lansing, Ingham County, MI, Continuum of Care 74. Wexford, Missaukee, and Manistee Counties, MI 75. Mississippi Balance of State Continuum of Care 76. Waukegan, North Chicago/Lake County, IL, Continuum of Care 77. Coles, Edgar, Douglas, Moultrie, Shelby, and Christian Counties, IL 78. Abilene, TX 79. Rochester/Southeast Minnesota Continuum of Care 80. Poplar Bluff, MO 81. Western Pennsylvania Continuum of Care 82. Chittenden County, VT 83. Quad Cities Bi-State Region IA/IL 84. Dakota, Anoka, Washington, Scott, Carver Counties, MN, Continuum of Care 85. Indiana Region 5 Planning Council (part of the Indiana Balance of State Continuum of Care - IN-502) 86. Central Minnesota Continuum of Care Communities that have ended chronic homelessness: Lancaster City & County, PA 2. Rockford, IL 3. Bergen County, NJ 4. Southwest Minnesota Continuum of Care TOM Yes, I'll Give HOUSING POLICY The little -noticed court decision that changed homelessness in America Is there a right to sleep outside? By Rachel M. Cohen I @rrnc031 I rac(ieLcohen@voxmedia.com I Jun 12, 2023, 7:30am EDT person experiencing homelessness walks to their tent in the Skid Row neighborhood of Los Angeles, California, on February 24, 2022 ! r),,Vid viri aelty Irna -a criminal justice, and abortion rights, and has been reporting on these issuesfor more than a decade. t Five years ago, a federal court issued a crucial ruling. People experiencing homelessness, the Ninth Circuit Court of Appeals said, can't be punished for sleeping outside on public property if there are no adequate alternatives available. The 2018 decision in Martin v. Boise did not create the homelessness crisis, which researchers attribute primarily to the lack of affordable housing. The number of people experiencing unsheltered homelessness — meaning those sleeping on the streets, in parks, in abandoned buildings or train stations, or anywhere not meant for humans to live — was rising before the decision. But as the number of unsheltered homeless people continued to grow over the past half - decade, the Martin decision has become a pivotal factor in shaping how cities respond to the very visible problem of tent encampments, particularly on the West Coast. While the case never gained huge name recognition, it undergirds the policy and politics of homelessness in 2023. So much of the fight about how to address homelessness today is, at this point, a fight about Martin. The case dates back to 2009, when Robert Martin and a group of fellow homeless residents in Boise, Idaho, sued, arguing that police citations they received for breaking local camping bans violated their constitutional rights. In 2018, the Ninth Circuit agreed that prosecuting people for sleeping or camping on public property when they have no home or shelter to go to violated the Eighth Amendment's prohibition on cruel and unusual punishment. "The government cannot criminalize indigent, homeless people for sleeping outdoors, on public property, on the false premise they had a choice in the matter;" the court declared. States, cities, and counties urged the US Supreme Court to take up the case, arguing the Ninth Circuit had created "a de facto" right to live on sidewalks and in parks that would "cripple" local leaders' ability to safely govern their communities. But in 2019, the court declined, baffling some experts, though others suspect it's because there were no conflicting circuit decisions at the time. Since then, Martin has shaped cities' response — or lack thereof — to the growing challenge of homeless tent encampments. While the decision only formally applies in areas under the Ninth Circuit's jurisdiction, the ruling has reverberated nationally, as local governments consider how to address unsheltered homelessness in ways that could avoid costly constitutional legal battles. There have already L/CCII LIVLVII.7 VI V,%PUI L 1-001=7 %iILII 1r' IVIQI L1I I, II I"UUII lb' II I LI M IFLOUF LII VII Li UIL III WIN V,IIIIQ, QI IL.1 federal lower courts in Ohio, Missouri, Florida, Texas, New York, and Hawaii. For now, though, Martin's impact can be seen most clearly out West. Just before Christmas 2022, for example, a district judge cited Martin when she ruled that San Francisco can no longer enforce encampment sweeps — meaning clear out homeless individuals and their property from an outdoor area — since the city lacks enough shelter beds for those experiencing homelessness to move into. San Francisco appealed the decision, arguing it's "unnecessarily broad and has put the City in an impossible situation:' In Phoenix, Arizona, residents and business owners filed a lawsuit last summer against the city for allowing a downtown homeless encampment to grow with nearly 1,000 people, but a federal judge — echoing Martin — barred Phoenix in December from conducting sweeps if there are more homeless people than shelter beds available. A competing decision issued in March by a state judge ordered Phoenix officials to clean up the "public nuisance" at the encampment by July 10, arguing the city has "erroneously" applied Martin to date. Desi Hurd, 62, uses her wheelchair in the Phoenix, Arizona, homeless encampment known as "The Zone:' I Caitlin O'Hara/Washington Post via Getty Images II I FUI LIQI IU, VI VrIUI I, IIICQI IVVI IIIG, UI I IL.IQIA IIO VC.7L4IAI I IIJIWU LV ICV1:lC U1C11 IVVgI U011 11'JII Is ordinance,to be a "daytime" camping ban from 8 am to 8 pm instead, in recognition that any total camping ban is likely illegal under Martin. Supporters of a more "get tough" approach to encampments say the social and political costs of allowing tent cities to proliferate are too high, and that waiting for cities to build enough new housing before acting is untenable, both morally and politically. Some think officials are getting complacent in relying on Martin as an excuse to maintain the status quo. Advocates for those experiencing homelessness say politicians are squandering an important opportunity by fighting for the right to conduct encampment sweeps — which can be both cruel and counterproductive to the larger goal of ending homelessness. Instead of looking for legal loopholes to Martin like daytime camping bans and sanctioned encampment sites, advocates say leaders should be investing more in solutions like affordable housing and shelter options that afford people more privacy. "Our end goal is not to create a right for people to sleep on the streets. That's the limited remedy we've been given under our Constitution;" said Eric Tars, the legal director for the National Homelessness Law Center. "They're missing the point of Martin if they're just trying to continue a criminalization approach in a more constitutional way." Cities are scrambling to comply with — and find loopholes In — Martin v. Boise Unsheltered homelessness has risen sharply over the last seven years, and at a faster rate than homelessness overall. Unsheltered homeless people now account for 40 percent of all homeless people in the country, up from 31 percent in 2015. Political pressure has mounted to respond to this growing problem of people sleeping in alleys, parks, and train stations. While it's not clear this would be legal under Martin, a number of cities have turned to the idea of so-called sanctioned encampments, or legalized campsites. These are effectively designated areas where unhoused individuals can live outside, and some come with varying degrees of public services, like bathrooms, power outlets, medical care, and on -site case management. In Portland, Oregon, lawmakers voted in November to create several large sanctioned campsites for homeless individuals, and ban the more than 700 other encampments spread across the city. Austin, Texas, has operated one sanctioned encampment of so-called "tiny homes" since 2019, on a seven -acre plot of asphalt near the airport. Denver, Colorado, is also moving to make its so-called "managed campsites" from the pandemic a permanent homelessness response tool. I I IC LI QUC V11 I VI IC601141=U L'CII I II./.l. ILC.71 I IVVVCVCI I IA LI IQL AICCVII IS VUL.JIUC QI IYVVI ICI C CIZIC III Q UILy would then be illegal. This helps alleviate leaders' political problem of having tents pitched all over a city, but activists worry it's just a way to steer the sight of homelessness out of public view, and criminalize people who refuse to go. Some cities are considering sanctioned encampments with a six-month residency limit, even if there's no permanent affordable housing option for those experiencing homelessness to go to after that point. Some advocates have taken a firm stance against the idea; they see sanctioned encampments as a means to segregate and criminalize unhoused people and effectively kick the can down the road by not finding them permanent housing. They're not wrong that sanctioned encampments can require a great deal of money, staff time, and effort. In 2018, the United States Interagency Council on Homelessness warned that "creating these environments may make it look and feel like the community is taking action to end homelessness on the surface — but, by themselves, they have little impact on reducing homelessness:' For these reasons, some cities — like Houston — have rejected the idea. "We can do better as a society. We shouldn't tolerate it and say that's okay," Marc Eichenbaum, the special assistant to Houston's mayor on homeless initiatives, told NPR. But other cities with fewer available housing options say sanctioned encampments represent a decent interim solution, and maybe even better for unhoused residents compared to scattered campsites if cities can more effectively target social services to those corralled together. Legalized campsites can also have a lower barrier to entry than many existing shelters, so supporters are framing them as a harm -reduction approach to homelessness. Groups like the National Homelessness Law Center, which used to firmly oppose sanctioned encampments, have recently softened their stance to say they should be considered on a case -by -case basis. "The only time that we would see a role for that approach is if you had an exit plan;" said Tars, who pointed to some models in Seattle and Gainesville, Florida, that he thought were more positive. "Otherwise you are just creating a permanent shanty town:' Meanwhile, Republican -governed states are exploring more punitive models. In at least half a dozen states, lawmakers have pushed sanctioned encampment bills based on templates from the Cicero Institute, an Austin -based conservative think tank. The bills propose to penalize cities that permit tent encampments, to put time limits on sanctioned encampment sites, and to divert funding from permanent supportive housing into things like mandatory drug treatment. 11 1 GULL, I CI II ICA.JCC LJCL+QI I IC U IC 111 C-L .ILCILC LU PQJ.J Q LJI11 LI IQL VV VUIU I I ICIMV UCH I IP11 16 U1 11Ut C31 FJULJIIL, land a felony. Missouri's version will allow the state's attorney general to sue local governments that don't enforce encampment bans. Activists say Cicero's aggressive opposition to housing -first will lead invariably to more homeless people in jail. Looming ultimately above all these various sanctioned encampment models is the Martin decision, which says a city-wide camping ban would be unconstitutional if the city lacks sufficient shelter options. Leaders recognize they probably can't ban camping everywhere under Martin, but they want to see if they can ban it in most places instead. Yet whether any bans could exist if a city lacks enough shelter beds remains an open Eighth Amendment question. Tars, of the National Homelessness Law Center, thinks the answer is no. "Martin is very clear when it's talking about 'adequate' [housing] alternatives it's talking about indoor shelter beds, and legalized encampments are not shelter beds;' he said, pointing to a 2021 federal court decision that found a sanctioned encampment site in Chico, California, was inadequate "shelter" under Martin. A federal judge described Chico's encampment as "open space with what amounts to a large umbrella for some shade" that "affords no real cover or protection to anyone:' Tars acknowledged, though, there's a "legal gray area" in the Martin decision, as one footnote suggests cities could create some "time/manner/place" restrictions for camping. Earlier this year, when a Maricopa County Superior Court judge ordered Phoenix officials to clear its notoriously large downtown encampment, he urged the city to consider "the creation of controlled, outdoor camping spaces on vacant City property" if there were not enough shelter beds to move people into. As in Houston, Phoenix officials have rejected the sanctioned encampment approach to date, saying resources should be invested into housing solutions with air conditioning: Over 80 percent of Maricopa County's 425 heat -related deaths in 2022 occurred outside. Local officials estimate unsheltered homeless people are at "200 to 300 times higher risk" of heat - related deaths than the rest of the population. Still, even if Phoenix leaders embraced sanctioned encampments, it's not clear the idea would hold up under Martin. Resolving some of these questions will realistically require the Supreme Court, but that's unlikely to happen until there's competing circuit court decisions to pressure it to take the issue up. Homelessness policy is at a crossroads I I ICI C CII C I.UUI L I U111 Ir'J, QI,U LI IC11 LI ICI C O CI 11 U1 t C1I ICI IL U1 LI IVJC 1 UI111r.O.. I IVI I ICICJJ CIUVUL.QLVO aCly it seems as though too many cities are failing to comply with rulings that bar unconstitutional sweeps For example, lawyers say little has changed in San Francisco since a federal judge ruled against sweeps six months ago, and that homeless residents continue to be displaced under the guise of street cleaning. "What we've seen has been a really aggressive media campaign led by the city to suggest we are pro -open-air drug markets and anti -accessibility for sidewalks;" said Zal Shroff, an attorney with Lawyer's Committee For Civil Rights representing the homeless plaintiffs. "You're allowed to clear genuine public safety hazards, but when you do that and throw their laptops and cellphones into dumpsters, that's not a cleaning — that's a seizure of someone's belongings without due process;" he added. In late May, Shroff's team filed a court motion, calling for increased monitoring. Jen Kwart, a spokesperson for San Francisco's city attorney, told Vox they're "complying with the preliminary injunction while simultaneously expending hundreds of millions of dollars annually to provide shelter and services to unhoused people." In Phoenix, while the city is working to clear out its large homeless encampment by July 10, per the Maricopa County Superior Court, the ACLU has been arguing the city's clearings have violated the rights of unhoused people. "Even if you're unsheltered, you have due process rights to your belongings under the Fourth and 14th Amendments;" said Benjamin Rundall, an attorney with ACLU of Arizona. "You can't violate someone's constitutional rights in order to vindicate someone's private property rights:' It's not clear at all where the estimated 700 unhoused people living in the downtown Phoenix encampment are supposed to go. There are not enough available shelter beds in the city; the four largest ones were at 97 percent capacity as of April. A spokesperson for Phoenix's Mayor Kate Gallego did not return requests for comment, but an April city press release said they were exploring hotel options and expected 800 new shelter beds to come online before the end of 2024. Some conservative legal advocates see the Maricopa County Superior Court ruling as offering a blueprint for other cities and states to clear out their tent encampments. "For too long, liberal leaders have used the Martin ruling as an excuse to allow rampant crime and homelessness to LCIMC VVCI I ICISI IL/VI I IVVUA, pESUWU MU01.11I VQI IUCI 1 IVYUCI 17 Q IIOI.JVI I QL LI IC UUIUWVQLCI 11I LILULC, II 1 the Orange County Register. "But no longer." "Our lawsuit was never about solving homelessness;" wrote Ilan Wurman, who represented the Phoenix business and property owners. "It was about solving the humanitarian crisis that these encampments create." Meanwhile, as pandemic eviction aid dries up, homeless advocates are bracing for more people to lose their housing in the coming months. Washington, DC, recently reported an 11.6 percent increase in homelessness from 2022. While the nation has been increasing its shelter bed capacity over the last few years, fewer people are choosing to stay in them. Many have decided sleeping outdoors is preferable to the rules and conditions of congregate shelters. Figuring out where cities go next will be shaped in no small part by how leaders and courts land on interpreting Martin. "It really feels like we're at a tipping point;" said Tars. "Things could either get much better or much worse:' You've read 1 article in the last 30 days. We have a request... Millions of people rely on Vox to understand how policy decisions impact their lives, the lives of their loved ones, and their communities. Gifts from readers help us keep this work free. Join tens of thousands of others who believe information that provides clarity is a public service. Make a gift to Vox today. One -Time Q $95/year Monthly ?ti nwv,--� 0 $120/year 0 $250/year 0 $350/year 0 Other Yes, I'll give $120/year We accept credit card, Apple Pay, and Google Pay. You can also contribute via r pa,.P"I Ninth Circuit Revisits and Clarifies the Reach of Martin v. City of Boise E1 Send. <h CnLcd ■ BEST BEST &'KRIEGER 3 WRITTEN BY: N,:'-1 li• LLP \ I I l l II ♦ t \ ti \ I t \ N Court Invalidates City's Attempts to "Evade" Harlin Over the last fete Years, courts have significantly narrowed the permissible scope of local tj Scott South _ 1 regulation of public c:uuping. The catalyst for this shift was marou o. QjItLo - lur.v (',lfnrtin"), a Ninth Circuit Court of Appeals decision that prohibits criminalizing sitting, sleeping or lying on r ) public properly, Le., "sL•uhrs crimes" when applied to homeless or unsheltered Slayerered individuals. — — Morhn struck down Boise's city -aide public camping prohibition because it lacked adequate emergency public shelter beds. The court left open the question of whether am• regulation of the ma' Why Suhramanian — location or scope of public camping can be constitutional. After years of silence, the Ninth Circuit partially answered this question m.jA- n•ou r, t lur•_I 0-onr. V'a ("Johnson'). which is discussed in further detail below. PUBLISHED IN: Recap: Marlin o. City ofHoise Cruel & Unusual Punishment — Cnpackingdohnson i equires a hrief overview of Martin. In that case, homeless individuals sued the City of Boise. Idaho, after being criminal!}' proseeuled under cilyordinances banning public Eihhlh Amendment (• • •. camping. As relevant here, the Ninth Circuit in Martin held that the Cruel and Unusual Punishment Clause of the Eighth Amendment "prohibits the imposition of criminal penalties for Homeless Issues silting, sleeping or lying outside on public properly for homeless individuals who cannot obtain shelter."'11tese laws could stand. bill not where Boise lacked public shehers.'I'he court explained Local Oidodoce r that "as long as there is no option of sleeping indoors, the government cannot criminalize indigenl, homeless people for sleeping outdoors, on public property, on the false premise they Public Property had n choice in the matter." The court characterized its decision in Martin as `narrow." cautioning that it "in no way CunSIRLRIOrldl dictate[s] to the City that it must provide sufficient shelter for the homeless, or allow anyone who wishes to sit, lie, or sleep on the streets ... nt any time and at any place," The court further allowed that "an ordinance rohibitin sittin lying, or sleeping outside al articular times or in BEST BEST & KRIEGER LLP ON: P K• K, Y K, P I; P particular locations might well he constitutionally permissible," as well as -an ordinance barring the obstruction of public rights of way or the erection of certain s1nuclures."'1 he Johnson decision relates to this last idea, i.e., the permissible physical scope —not location --of public camping. JOURNALISTS FLtd} gttllllSd!9ir4419ry9lrr-CWq Grants Pass's Regulations and the Court's Decision c,..wA-h Inasnn.,F.,, y, q,nk tKrr.gmx,a in -reran t,wy�,ec,.,� Grants ['ass, Oregon's municipal code regulates camping on public property.'rhe Ninth Circuit's decision in.lollursnn focused on —and uitimale1v struck down —two camping -related provisions regarding penalties for violations and prohibitions on the use of bedding, sleeping bags and related items- Both provisions and the court's analysis are summarized below,