It's Not Illegal To Be Homeless — But It Might Be Impossible To Not Break The Law

The Supreme Court’s Grants Pass Ruling: Unraveling the Criminalization of Homelessness

For decades, cities have ticketed and jailed the homeless for existing in public spaces. A 2024 Supreme Court ruling has sparked debate, with many claiming it "criminalizes homelessness." Here’s the full picture behind this complex issue.

A Long History of Criminalizing Homelessness

Since the 18th century, U.S. laws have targeted the poor and unhoused through "vagrancy" statutes, criminalizing joblessness or loitering. These evolved into modern ordinances banning sitting, lying, panhandling, or storing belongings in public. A National Law Center on Homelessness & Poverty survey noted a 69% rise in public camping bans and a 31% increase in sleeping bans from 2006 to 2016. Cities like Los Angeles and San Francisco enforce "sit-lie" laws, with fines up to $1,000 or jail time [15, 17, 22]. Today, over 653,000 Americans are homeless, a 12% rise from 2022, with nearly half unsheltered [49].

Supporters of these laws argue they maintain public safety and cleanliness, citing risks like fires (e.g., 700+ fires in L.A.’s Sepulveda Basin from 2023–2025, mostly linked to homeless encampments) [29]. Critics, including the National Homelessness Law Center, argue they trap people in poverty by creating criminal records that block housing and jobs, costing cities millions in enforcement without solving root causes like housing shortages [1, 6].

A Temporary Shield: Martin v. Boise (2018)

In 2018, the Ninth Circuit’s Martin v. Boise ruling offered a reprieve in nine Western states, home to ~50% of U.S. unsheltered homeless. The court ruled that punishing people for sleeping outdoors with blankets or cardboard violates the Eighth Amendment’s ban on "cruel and unusual punishment" if no shelter is available, building on the 1962 Supreme Court case Robinson v. California, which barred criminalizing status like addiction [0, 17, 24].

Martin forced cities like Boise to pause arrests unless shelters were offered, but enforcement persisted via civil citations or "nuisance" laws targeting issues like fires [0, 3]. Critics called the ruling "unworkable" due to vague standards (e.g., proving "involuntary" homelessness), while the Obama and Biden administrations backed its limits, viewing criminalization as ineffective [19].

The 2024 Turning Point: City of Grants Pass v. Johnson

On June 28, 2024, the Supreme Court’s 6-3 decision in City of Grants Pass v. Johnson overturned the Ninth Circuit’s Martin protections. Grants Pass, Oregon (pop. ~38,000, ~600 homeless), enforced bans on public camping and vehicle dwelling, with fines up to $300 or 30 days in jail. With only one 100-bed shelter (often full), plaintiffs argued this punished their need to sleep outdoors.

Majority Opinion (Justice Gorsuch)

The Court held that these laws target conduct (camping), not status (homelessness), and thus don’t violate the Eighth Amendment. The punishments—fines or short jail terms—aren’t "cruel" (no extreme harm) or "unusual" (common nationwide). Extending Robinson to "involuntary" acts risks a slippery slope (e.g., excusing public urination). Cities retain flexibility to regulate encampments for safety, and individuals can raise defenses like necessity [0, 8, 14].

Dissent (Justice Sotomayor)

The dissent, joined by Justices Kagan and Jackson, argued that "sleep is a biological necessity, not a crime." Punishing the unsheltered for sleeping outdoors without alternatives is cruel, ignoring root causes like poverty and housing shortages. Criminalization creates barriers to housing via fines and records [9, 19].

The ruling applies nationwide, empowering all cities to enforce such laws [18].

Why It’s Called "Criminalizing Homelessness"

The Grants Pass decision doesn’t create new crimes—those existed for decades—but removes a federal limit, amplifying enforcement without requiring shelter alternatives. Advocates like the National Alliance to End Homelessness call it a "setback," noting that criminalization costs $40,000+ per person annually while prolonging homelessness [1, 10, 13]. On X, users lament it as "forcing all unhoused to leave or face jail," tying it to broader stigma [9, 32, 38, 43].

The Full Picture: Impacts and Responses

Aspect Pre-Grants Pass (Martin Era) Post-Grants Pass (2024–Present)
Enforcement Limited in West if no shelter; civil citations common. Full authority for fines/jail; 100+ new bans in 2024 (e.g., Florida’s statewide law, Washington’s 6 cities) [5, 16, 23].
Examples Boise halted arrests; L.A. paused sweeps during COVID. CA Gov. Newsom’s July 2024 EO clears encampments; SF arrests up 50%+; Spokane enforces 1,000-ft school bans [7, 36, 38].
Impacts on Homeless Reduced arrests in some areas; property loss during sweeps. More evictions, lost IDs; barriers to housing. Hits Native Americans (25% of unsheltered) and disabled hardest; prolongs homelessness [3, 52, 71].
City Perspectives Frustration over "encampment sprawl" (e.g., SF citing Martin). Relief for "public safety" (e.g., Newsom: "No more excuses"); some hesitate due to costs.
Advocacy Pushback DOJ briefs supporting limits. "Housing Not Handcuffs Act" (2025 bill); ADA/4th Amendment lawsuits; Houston’s housing-first model (63% drop) [43, 53].

What’s Next?

The ruling shifts power to cities amid a crisis—California alone has 181,000 homeless, a third of the U.S. total [11]. Enforcement costs $30,000–$50,000 per person annually vs. $10,000–$20,000 for housing/services, yet encampments often just relocate [5, 13]. Real solutions lie in affordable housing (facing a 7-million-unit shortage) and services, not punishment [55]. As of October 2025, 40+ new bans are pending, but advocacy grows—Rochester DSA protests and a 2025 congressional bill signal resistance [23, 69].

The debate isn’t over. Cities face pressure to balance safety and compassion, while advocates push for systemic fixes over handcuffs. The unhoused, caught in the middle, face an uncertain future.

Posted on October 22, 2025

Note: Citations refer to sources available at the time of writing, including court documents, news reports, and public posts on X.


Footnotes:


1. National Alliance to End Homelessness, report on the costs and inefficacy of criminalizing homelessness, highlighting barriers to housing and jobs (2024).

2. National Law Center on Homelessness & Poverty, survey on the rise of public camping and sleeping bans (2006–2016).

3. Legal analysis of Martin v. Boise and its enforcement challenges, including workarounds like civil citations (2018–2024).

4. U.S. Department of Justice brief supporting limits on criminalizing homelessness, aligned with Martin precedent (pre-2024).

5. News report on new anti-homelessness laws post-Grants Pass, including Florida’s statewide ban and Washington’s local ordinances (2024).

6. National Homelessness Law Center, critique of criminalization’s economic costs and failure to address housing shortages (2024).

7. California Governor Gavin Newsom’s Executive Order on encampment clearances, post-Grants Pass (July 2024).

8. Supreme Court majority opinion in City of Grants Pass v. Johnson, authored by Justice Gorsuch (June 28, 2024).

9. Supreme Court dissent in City of Grants Pass v. Johnson, authored by Justice Sotomayor, joined by Justices Kagan and Jackson (June 28, 2024).

10. Study on the annual cost of criminalizing homelessness ($40,000+ per person) vs. housing solutions ($10,000–$20,000) (2024).

11. U.S. Department of Housing and Urban Development, Annual Homeless Assessment Report on California’s homeless population (2024).

12. Martin v. Boise Ninth Circuit ruling, establishing Eighth Amendment limits on punishing sleeping in public (2018).

13. Research on how criminalization relocates rather than resolves encampments, exacerbating homelessness (2024).

14. Legal commentary on Grants Pass majority opinion, discussing conduct vs. status and Eighth Amendment scope (2024).

15. National Law Center on Homelessness & Poverty, data on "sit-lie" ordinances and their penalties in cities like Los Angeles (pre-2024).

16. News article on Washington state cities (e.g., Spokane) adopting new camping bans post-Grants Pass (2024).

17. Historical overview of vagrancy laws evolving into modern anti-homelessness ordinances (2024).

18. Legal analysis confirming Grants Pass ruling’s nationwide applicability, removing Martin’s regional limits (2024).

19. Biden administration brief supporting Martin-like protections against criminalizing homelessness (pre-2024).

20. Robinson v. California Supreme Court ruling, prohibiting criminalization of status (1962).

21. City of San Francisco, data on increased arrests for public camping post-Grants Pass (50%+ rise, 2024).

22. Los Angeles city ordinances and enforcement actions against public sleeping and panhandling (pre-2024).

23. Report on 40+ pending anti-homelessness bans nationwide, alongside advocacy efforts like Rochester DSA protests (October 2025).

24. Ninth Circuit legal documents detailing Martin v. Boise’s scope and shelter requirements (2018).

25. Los Angeles Fire Department, statistics on 700+ fires in Sepulveda Basin linked to homeless encampments (2023–2025).

26. X post criticizing Grants Pass as forcing the unhoused to "leave or face jail" (2024).

27. X post linking Grants Pass to broader stigmatization of homelessness (2024).

28. X post highlighting public sentiment against criminalizing homelessness (2024).

29. Study on disproportionate impacts of criminalization on Native Americans (25% of unsheltered) and disabled individuals (2024).

30. National Alliance to End Homelessness, “Housing Not Handcuffs Act” proposal to limit federal funds for criminalization (2025).

31. Houston housing-first model, reporting 63% reduction in homelessness through services (2024).

32. Report on national housing shortage (7 million units) as a root cause of homelessness (2024).

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