Jones v. State of Los Angeles

Brief Fact Summary.

Plaintiffs were arrested for violating a city ordinance that prohibited individuals from sleeping, sitting, or lying on a public street or sidewalk at anytime. The plaintiffs appealed arguing the ordinance violated the Eighth Amendment of the Constitution after they were arrested for violating the ordinance.

Synopsis of Rule of Law.

If a city ordinance effectively punishes homeless individuals based on the fact they are homeless, that ordinance violates the Eighth Amendment’s Cruel and Unusual Punishment Clause.

Facts.

Plaintiffs were arrested for violating a city ordinance that prohibited individuals from sleeping, sitting, or lying on a public street or sidewalk at anytime. Edward Jones and five other plaintiffs were arrested after officers found them living and sleeping in the city’s skid row area, in violation of the ordinance. The skid row area of Los Angeles contains the largest number of homeless persons in the United States. The plaintiffs filed suit in federal district court against the city of Los Angeles and their police department arguing the ordinance violates the Eight Amendment's Cruel and Unusual Punishment Clause and sought injunctive relief against the city from enforcing the ordinance during the nighttime hours or against disabled individuals at anytime. The district court held that the ordinance only punished conduct and not status. The plaintiffs appealed.

Issue.

Whether the Los Angeles city ordinance punishes individuals based on their status rather than their conduct, thus violating the Eight Amendment's Cruel and Unusual Punishment Clause?

Held.

yes, the ordinance effectively punishes individuals for their status as homeless persons and does not punish their conduct.

Dissent.

The cities ordinance only punishes individuals conduct and not heir status as homeless individuals and homeless individuals should not get relief from violations of the law based on their condition of being homeless.

Discussion.

The plaintiffs are in a constant state of homelessness and a great number of those individuals are not homeless by choice. Shelter is not consistently available to these individuals and it follows that often times they have no access to any kind of shelter, except areas such as skid row. The homeless included individuals such as the mentally ill, alcoholics, drug addicts, and domestic violence victims and the amount of homeless individuals has drastically increased over time. Criminally punishing these individuals based on their status as a homeless persons is essentially punishing them based on an involuntary condition. Thus, the city ordinance is a violation of the Eight Amendment of the Constitution and cities can not punish individuals based on their status. However, this is not to say that cities cannot punish things such as panhandling or obstructing public streets, things completely unrelated to homelessness.