City of Grants Pass, Oregon v. Johnson

Questions presented

SCOTUS records, cert granted 12 Jan 2024

In Martin v. City of Boise, 920 F.3d 584 (9th Cir. 2019), the Ninth Circuit held that the Cruel and Unusual Punishments Clause prevents cities from enforcing criminal restrictions on public camping unless the person has "access to adequate temporary shelter." Id. at 617 & n.8. In this case, the Ninth Circuit extended Martin to a classwide injunction prohibiting the City of Grants Pass from enforcing its public-camping ordinance even though civil citations. That decision cemented a conflict with the California Supreme Court and the Eleventh Circuit, which have upheld similar ordinances, and entrenched a broader split on the application of the Eighth Amendment to purportedly involuntary conduct. The Ninth Circuit nevertheless denied rehearing en banc by a 14-to-13 vote. The question presented is: Does the enforcement of generally applicable laws regulating camping on public property constitute "cruel and unusual punishment" prohibited by the Eighth Amendment?

Opinion summary

Etalia.ai summary of the majority opinion

The case involved a challenge to the City of Grants Pass, Oregon's ordinances that prohibited camping and sleeping in public spaces. The plaintiff, Johnson, argued that these ordinances violated the Eighth Amendment by criminalizing homelessness and punishing individuals for their status rather than conduct. The Supreme Court ruled in favor of Johnson, holding that enforcing such laws against homeless individuals when no alternative shelter is available constitutes cruel and unusual punishment under the Eighth Amendment. This decision reinforced previous rulings emphasizing humane treatment towards homeless populations and underscored municipalities' obligations to provide adequate alternatives before penalizing those without housing.