City of Grants Pass, Oregon v. Johnson

The City of Grants Pass, Oregon (the city) (defendant) had three laws that, collectively, made it illegal to sleep or camp, including overnight parking, on city property or in city parks (the anti-camping laws). Direct penalties for violations included civil fines and civil orders excluding violators from city parks. If someone violated a civil exclusion order, the person could face criminal-trespass charges punishable with prison time and criminal fines. The city used these laws and other tools to address homelessness in the area. Gloria Johnson and John Logan (plaintiffs) lived in the city and were homeless. The city had never enforced any of its camping prohibitions against Johnson and Logan. However, Johnson and Logan typically slept in their vehicles and were at risk of having the laws enforced against them. Johnson and Logan sued the city in district court, alleging that the anti-camping laws violated the Eighth Amendment’s prohibition on cruel and unusual punishment. This claim relied heavily on Martin v. Boise, which held that if a person was involuntarily homeless, it was cruel and unusual to punish that person for camping on public property. Applying Martin, the district court certified a class of involuntarily homeless people and enjoined the city from enforcing its anti-camping laws against the class. A divided Ninth Circuit panel affirmed most of the order, and the Ninth Circuit declined to rehear the matter en banc. The United States Supreme Court granted certiorari.