603 U.S. 520
SCOTUS2024Background
- Grants Pass, Oregon (pop. ~38,000) enforces municipal ordinances banning camping and overnight parking on public property; penalties escalate from fines to park-exclusion orders and up to 30 days’ imprisonment for trespass.
- Two long‑term homeless residents sued on behalf of a class of “involuntarily homeless” people, seeking an injunction barring enforcement of the city’s public‑camping laws.
- The district court certified the class and entered a Martin‑style injunction, finding Grants Pass’s homeless population exceeded “practically available” shelter beds and that local shelter rules (e.g., smoking and religious‑service requirements) rendered beds unavailable.
- A divided Ninth Circuit panel affirmed key aspects of the injunction, applying Martin v. Boise and the “practically available” bed test; rehearing en banc was denied over multiple dissents.
- The Supreme Court granted review and reversed: it held the Eighth Amendment’s Cruel and Unusual Punishments Clause does not prohibit enforcement of generally applicable public‑camping laws and refused to extend Robinson beyond its narrow status‑crime holding.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether enforcing public‑camping laws against people who lack shelter violates the Eighth Amendment | Johnson: Criminalizing sleeping outside when no shelter is available punishes the status of homelessness or involuntary acts incident to that status | Grants Pass: Ordinances prohibit conduct (camping), not status; Eighth Amendment governs kinds of punishment, not what may be criminalized | Reversed Ninth Circuit; enforcement of generally applicable camping laws is not per se Eighth Amendment cruel and unusual punishment |
| Whether Robinson v. California requires invalidating laws that effectively punish homelessness | Extend Robinson: Robinson’s status‑rule should bar penalizing acts that are unavoidable consequences of status (i.e., involuntary acts) | Resist extension: Robinson is a narrow, anomalous status decision; Powell controls and limits Robinson’s reach | Court declined to extend Robinson to involuntary conduct; Robinson limited to laws criminalizing mere status |
| Whether Martin’s ‘‘practically available’’ shelter‑bed arithmetic should block enforcement of camping laws | Plaintiffs: If shelter beds are fewer than homeless people, enforcement is unconstitutional | City & amici: Martin usurps local policymaking, is unworkable and ill suited to Eighth Amendment inquiry | Court rejected Martin’s framework as an Eighth Amendment rule and remanded for further proceedings consistent with decision |
| Whether the Eighth Amendment applies to civil fines/exclusion orders tied to camping violations | Plaintiffs: Civil penalties can lead to criminal sanctions later, so Eighth scrutiny applies | City: The Punishments Clause targets criminal punishments after conviction, not antecedent civil regulation or criminalization choices | Court emphasized Clause focuses on method/kind of punishment post‑conviction; did not adopt a new rule extending Robinson to civil penalties and left other constitutional protections available |
Key Cases Cited
- Robinson v. California, 370 U.S. 660 (1962) (Eighth Amendment bars criminalizing the status of narcotic addiction)
- Powell v. Texas, 392 U.S. 514 (1968) (Robinson’s reach is narrow; courts should not extend status‑based rule to involuntary acts)
- Martin v. Boise, 920 F.3d 584 (9th Cir. 2019) (Ninth Circuit held enforcement of camping ordinances against people without shelter can violate the Eighth Amendment)
- Bucklew v. Precythe, 587 U.S. 119 (2019) (historical meaning of “cruel” and “unusual” and focus on methods/kinds of punishment)
- Kahler v. Kansas, 589 U.S. 271 (2020) (questions of moral culpability and criminal‑responsibility rules are typically left to legislatures)
- Timbs v. Indiana, 586 U.S. 146 (2019) (Eighth Amendment principles and historical analysis of punishments)