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Martin v. City of Boise

902 F.3d 1031 (2018)

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Martin v. City of Boise

United States Court of Appeals for the Ninth Circuit

902 F.3d 1031 (2018)

Facts

The City of Boise (defendant) had two city ordinances related to homeless persons. The camping ordinance prohibited camping on public property. The disorderly conduct ordinance banned sleeping in any public or private place without permission. The state conducted a count of homeless individuals in the county in which Boise sits, Ada County. The results indicated that there were about 867 homeless persons in the county. At the time of the count, 125 individuals were unsheltered. Ada County had three homeless shelters, all located in Boise. The three shelters had 354 beds and 92 overflow mats combined. Two of the shelters had restrictions on who may stay. The City of Boise enforced the ordinances against six homeless or recently homeless persons (plaintiffs), including Robert Anderson and Robert Martin. These six individuals sought relief for citations under the ordinance, arguing it violated the Eighth Amendment to the United States Constitution. Martin and Anderson also sought declaratory and injunctive relief against future prosecution, alleging they expected to be cited under the ordinances in the future. The district court upheld the ordinances. The six individuals appealed to the United States Court of Appeals for the Ninth Circuit.

Rule of Law

Issue

Holding and Reasoning (Berzon, J.)

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