Letters from the Law Center

A collection of letters sent or signed onto by the Law Center to support our advocacy and legal work.

Letter to the Members of the Texas House of Representatives (2021)

This letter expresses the Law Center’s opposition to Texas House Bill 1925. HB 1925 would prohibit sheltering in public statewide regardless of access to indoor shelter alternatives, disability status, or inclement weather conditions. This bill is inhumane, harmful to communities, and may expose the State of Texas to expensive and divisive litigation. It is also incorrectly aimed at punishing unhoused people for lacking shelter when unsheltered homelessness can more affordably and sustainably be solved with proven housing and service solutions. The Law Center urges Texas House Representatives to vote no on HB 1925.

Letter to the Mayor and City Commissioners of Adrian, MI (2021)

This letter, submitted in coordination with the ACLU of Michigan, expresses our concerns regarding Section 62-44 (“Camping Ban”) of the Adrian, Michigan Code of Ordinances. Adrian’s Camping Ban makes it a civil infraction and a public nuisance for any person to “camp or establish shelter upon a public park” regardless of the availability of indoor shelter and/or any alternative place to sleep and safely store one’s belongings. In this letter, we inform the City that the ordinance falls afoul of the 9th Circuit’s ruling in Martin v. Boise by criminalizing involuntary homelessness, and poses a risk to housed and unhoused residents of Adrian alike during the COVID-19 pandemic. We urge the city to repeal the camping ban and to instead pursue evidence-based strategies to end and prevent homelessness in Adrian.

Letter to the Mayor and City Council of Fort Myers, Florida and to the Lee County, Florida Board of County Commissioners (2021)

This letter, submitted in coordination with the Southern Legal Counsel and the ACLU of Florida, expresses our concerns regarding Fort Myers’ and Lee County’s intended city-wide sweeps of homeless encampments including at Lions Park, Schandler Hall, and the Fort Myers Regional Library starting on March 19, 2021, as well as the intended enforcement of ordinances that would criminalize people experiencing homelessness found camping on public property. People found in violation of the ordinance in Fort Myers would be subject to fines up to $250, criminal citations, and are likely to lose significant personal property during the sweep. We write to inform Fort Myers and Lee County of guidance issued by the Centers for Disease Control and Prevention stating that that homeless encampments should not be evicted during the COVID-19 pandemic unless the city can offer individual housing units to people experiencing homelessness. In this letter, we urge Fort Myers and Lee County to cease conducting sweeps. Instead, we encourage the City to rely on funding available from the Federal Emergency Management Agency to safely house its homeless population rather than continuing to displace them with no safe alternative. Unfortunately, Fort Myers and Lee County conducted the planned sweeps.

Letter to the Mayor, Deputy Mayor, and City Council of Everett, Washington (2021)

This letter expresses the Law Center’s concern with Council Bill # 2102-06, which would prohibit certain conduct within designated rights of way. This ordinance would make it a criminal misdemeanor subject to a $500 fine to “sit or lie down upon, or place a blanket, sleeping bag, back pack, chair, mattress, couch, stool, or any similar equipment, item, or furniture upon” in any public sidewalk or right of way within the designated area. In this letter, we recognize the disproportionate effect this ordinance would have on people experiencing homelessness and encourage the Everett City Council to vote against this ordinance. Unfortunately, this ordinance passed with a 5-1 vote.

Letter to the Mayor and City Council of Española, New Mexico (2021)

This letter expresses the Law Center’s concern with the City of Española’s clearance of an encampment at Ranchitos Park despite guidance issued by the Centers for Disease Control and Prevention stating that that homeless encampments should not be evicted during the COVID-19 pandemic unless the city can offer individual housing units to people experiencing homelessness. In this letter, we urge the City to cease conducting sweeps. Instead, we encourage the City to rely on funding available from the Federal Emergency Management Agency to safely house its homeless population rather than continuing to displace them with no safe alternative.

Letter to the Mayor and City Council of Merriam, KS (2021)

This letter, submitted in coordination with the ACLU of Kansas, expresses concerns regarding an ordinance approved by the Merriam City Council which amends Chapter 68 of the Merriam Code of Ordinances to pedestrians from standing on certain medians. In this letter, we recognize the effect this ordinance would have on people experiencing homelessness, and that it is counterproductive to issue fines to people panhandling on these medians. We encourage Merriam to reconsider this ordinance because it unconstitutionally regulates the content of speech and, instead of promoting traffic safety, disproportionately punishes people experiencing homelessness.

Letter to the Mayor, Deputy Mayor, and Common Council of Madison, WI (2021)

This letter expresses the Law Center’s concern with the City of Madison’s clearance of an encampment at McPike Park despite guidance issued by the Centers for Disease Control and Prevention stating that that homeless encampments should not be evicted during the COVID-19 pandemic unless the city can offer individual housing units to people experiencing homelessness. In this letter, we urge the City to cease conducting sweeps. Instead, we encourage the City to rely on funding available from the Federal Emergency Management Agency to safely house its homeless population rather than continuing to displace them with no safe alternative. We inform the City that FEMA has changed its non-congregate shelter reimbursement policies since Wisconsin had previously applied, so that the City should reapply.

Letter to Mayor, City Council, and Principal Planner of Medford, OR (2021)

This letter expresses concerns with the City of Medford’s Proposed Ordinance, which seeks to prohibit sleeping or lying on public property for over 24 hours, camping on public property, and camping, lying, sleeping, or using bedding material at various locations in the City. In this letter, we inform the City that the Proposed Ordinance falls afoul of the 9th Circuit’s ruling in Martin v. Boise by criminalizing involuntary homelessness, and poses a risk to housed and unhoused residents of Medford alike during the COVID-19 pandemic. We urge the City to vote against the ordinance and to rely on funding available from the Federal Emergency Management Agency to safely house its homeless population rather than further criminalization.

Letter to City Council of San Antonio, TX (2021)

This letter expresses the Law Center’s concerns with the City of San Antonio’s aggressive abatements of various encampments despite guidance issued by the Centers for Disease Control and Prevention stating that that homeless encampments should not be evicted during the COVID-19 pandemic unless the city can offer individual housing units to people experiencing homelessness. In this letter, we urge the City to cease conducting sweeps and to rely on funding available from the Federal Emergency Management Agency to safely house its homeless population rather than continuing to displace them with no safe alternative.

Letter to Mayor and City Council of Porterdale, GA (2021)

This letter expresses the Law Center’s concerns with the City of Porterdale’s plan to stop operating its temporary warming center serving people experiencing homelessness. In this letter, we urge the City to rely on funding available from the Federal Emergency Management Agency to safely house its homeless population rather than move forward with its plan to close the temporary warming center at Rainbow Covenant Ministries.

Letter to City Council of Dallas, TX (2021)

This letter expresses the Law Center’s concerns with the City of Dallas’s clearance of various encampments despite guidance issued by the Centers for Disease Control and Prevention stating that that homeless encampments should not be evicted during the COVID-19 pandemic unless the city can offer individual housing units to people experiencing homelessness. In this letter, we urge the City to cease conducting sweeps and to rely on funding available from the Federal Emergency Management Agency to safely house its homeless population rather than continuing to displace them with no safe alternative.

Letter to Mayor and City Council of Sweet Home, OR (2021)

This letter expresses the Law Center’s concerns with the City of Sweet Home’s plan to close the homeless encampment at the Church of Nazarene despite guidance issued by the Centers for Disease Control and Prevention stating that that homeless encampments should not be evicted during the COVID-19 pandemic unless the city can offer individual housing units to people experiencing homelessness. In this letter, we urge the City to rely on funding available from the Federal Emergency Management Agency to safely house its homeless population rather than move forward with its plan to close the encampment at the Church of Nazarene and just disperse its homeless population.

Letter to Mayor and City Council of Napa, CA (2021)

This letter expresses the Law Center’s concerns with the City of Napa’s clearance of various encampments despite guidance issued by the Centers for Disease Control and Prevention stating that that homeless encampments should not be evicted during the COVID-19 pandemic unless the city can offer individual housing units to people experiencing homelessness. In this letter, we urge the City to cease conducting sweeps and to rely on funding available from the Federal Emergency Management Agency to safely house its homeless population rather than continuing to displace them with no safe alternative.

Letter to the Mayor and City Commissioners of Gainesville, FL (2021)

This letter, submitted in coordination with the Southern Legal Counsel and the ACLU of Florida, expresses the Law Center’s concerns with the City of Gainesville’s Proposed Ordinance that would prohibit pedestrians from traffic medians. Comments made during public debates made it clear a primary purpose of the ordinance is to disproportionately deter people panhandling on traffic medians. In this letter, we urge the City to vote against the ordinance because it unconstitutionally regulates the content of speech and because instead of promoting traffic safety it punishes people experiencing homelessness.

Letter to the Mayor and Aldermen of Manchester, NH (2021)

This letter expresses the Law Center’s concerns with the City of Manchester’s Proposed Ordinance, which seeks to prohibit camping in public places without permission and authorizes police to issue a fine up to $1,000 to anyone camping on public property if there is “available overnight shelter.” In this letter, we inform the City that the Proposed Ordinance falls afoul of the 9th Circuit’s ruling in Martin v. Boise by criminalizing involuntary homelessness, and poses a risk to housed and unhoused residents of Manchester alike during the COVID-19 pandemic, and urge the City to vote against the ordinance.

Joint letter to the Mayor and Councilmembers of Knoxville, TN (2021)

This letter, submitted in coordination with the ACLU of Tennessee, expresses the Law Center’s concerns about Knoxville’s clearance of encampments during the COVID-19 pandemic, which goes against CDC guidelines. In this letter, we urge the City Council to take advantage of funding from FEMA to provide individual housing options to all individuals and families experiencing homelessness.

Letter to the Mayor and Councilmembers of Delray Beach, FL (2021)

This letter, submitted in coordination with the ACLU of Florida, Southern Legal Counsel, and the Palm Beach County Chapter of the ACLU of Florida, expresses the Law Center’s concerns about Delray Beach’s Proposed Ordinance, which seeks to criminalize the innocent act of requesting charity. In this letter, we urge the City Council to vote against this unconstitutional ordinance and develop constructive approaches that will lead to the best outcomes for all the residents of Delray Beach, housed and unhoused alike.

Letter to the Mayor and Councilmembers of Medford, OR (2020)

This letter expresses the Law Center’s concerns regarding the city of Medford’s clearance of the homeless encampments in Hawthorne Park and the Greenway. This approach is contrary to CDC guidance and likely unconstitutional according to the precedent set in Martin v. Boise, and recently reaffirmed in Blake v. Grants Pass. We call on the city to immediately cease evictions of homeless encampments and instead put its resources to getting people into housing.

Letter to the Mayor of Salt Lake City, UT (2020)

This letter addresses the Law Center’s concerns about Salt Lake City’s continued encampment sweeps during the COVID-19 pandemic. We urge the city to adhere to CDC guidance and immediately stop conducting sweeps of homeless encampments until the city can offer individual housing units to people experiencing homelessness. The Law Center also encourages Salt Lake City to place an immediate moratorium on enforcement of laws or policies criminalizing homelessness, such as laws against camping, sleeping, panhandling, or sleeping in one’s vehicle.

Letter to the Mayor and Councilmembers of Auburn, WA (2020)

This letter addresses the Law Center’s concerns about the City of Auburn’s Proposed Ordinance which prohibits erecting or maintaining a tent in any city park and subjects a person to “arrest and prosecution for criminal trespass” for simply “entering or remaining in a park when it is closed.” We urge the Council to vote against these amendments which criminalize involuntary homelessness and instead to repeal the ordinance.

Joint Letter to the Mayor and Councilmembers of Boulder, CO (2020)

This letter, written jointly with the National Association for the Advancement of Colored People Boulder County Branch, expresses the Law Center’s concerns about Boulder’s camping ban and prohibition on using vehicles as dwelling places during COVID-19. We urge the city to adhere to CDC guidance and consider repealing or placing a moratorium on encampment clearings until the city can offer individual housing units to people experiencing homelessness.

Letter to the Mayor and Councilmembers of Austin, TX (2020)

This letter expresses the Law Center’s support for the Fair Chance Housing Resolution and urges the City of Austin to approve this important step toward ending and preventing homelessness. The Fair Chance Housing Resolution will not only remove unnecessary barriers to housing access, but it will also help to promote racial equity and reduce homelessness in Austin.

Joint Letter to the Mayor, City Councilmembers, and Public Health Departments of Detroit, MI (2020)

This letter, written jointly with the American Civil Liberties Union of Michigan (ACLU), Street Democracy, and our partner signatories, expresses the Law Center’s concerns about Detroit’s harmful sweeps during COVID-19. The letter was initiated by local medical students doing street medicine who observed the sweeps. We urged the City to cease all homeless encampment evictions during the COVID-19 pandemic immediately and asked that they adopt a policy that protects unsheltered people and their property.

Joint Letter to the City Council of Honolulu, HI (2020)

This letter, written and signed by 35 legal scholars, is in response to the latest proposed expansion of Honolulu’s criminal prohibition on sleeping or lying in public places. For years now, the city has effectively chased people with new and wider bans, and it is doing so again with the latest proposal. Enforcing such bans against people without access to shelter is cruel and unusual punishment, and the Constitution forbids it.

Joint Letter to the Mayor of San Francisco, CA (2020)

This letter, written jointly with Lawyers’ Committee for Civil Rights of the San Francisco Bay Area, ACLU-Northern California, and the Public Interest Law Project, is on behalf of the Coalition on Homelessness San Francisco to demand the City and County of San Francisco’s compliance with recent local legislation requiring the procurement of hotel and motel rooms for unhoused people as a critical public health response to the COVID-19 pandemic and with Welfare and Institutions Code section 17000.

Joint Letter to the Board of Supervisors of Sacramento County, CA (2020)

This letter, written jointly with Disability Rights California and ACLU-Northern California, expresses the Law Center’s concerns about the refusal of the City of Sacramento and the County of Sacramento to provide emergency services to, and refrain from the criminalization of, people experiencing homelessness. We urge the City and the County to adhere to CDC guidance—and its own Plan—which includes a variety of measures that will serve the needs of people experiencing homelessness and reduce the further spread of coronavirus.

Joint Letter to the Mayor, Vice Mayor, and City Council of Sacramento, CA (2020)

This letter, written jointly with Disability Rights California, Legal Services of Northern California, and ACLU-Northern California, expresses the Law Center’s concerns about the refusal of the City of Sacramento to provide emergency services to, and refrain from the criminalization of, people experiencing homelessness. We urge the City to adhere to CDC guidance—and its own Plan—which includes a variety of measures that will serve the needs of people experiencing homelessness and reduce the further spread of coronavirus.

Letter to the Mayor and Councilmembers of Denver, CO (2020)

The Law Center urges Mayor Hancock and Councilmembers not to displace people living outside in the City of Denver unless the people living in those locations are offered accessible individual housing units, such as hotel rooms, consistent with CDC Guidance. We also urge the City of Denver to issue a formal policy to leave intact homeless encampments that do not pose immediate public health or safety risks throughout the COVID-19 State of Emergency because such a policy can protect the lives and safety of all Denver residents.

Letter to the Mayor and City Councillors of Topeka, KS (2019)

This letter expresses the Law Center’s concerns with the city’s  proposed camping ordinance, and suggests more constructive policies to implement in its place. The Law Center has offered assistance in seeing these alternatives put forward.

Joint Letter to the Mayor and City Council of Santa Cruz, CA (2019)

This letter, written jointly with Disability Rights California and the ACLU of California, expresses the Law Center’s concerns with the city’s  proposed camping ordinance, and suggests more constructive policies to implement in its place. Rather than the proposed policy of amending ordinances to justify the citation and arrest of homeless individuals, the letter urge the Council to undertake a considered, thoughtful analysis of homelessness and the barriers that people experiencing homelessness face when attempting to access services.

Letter to the Mayor and City Councillors of Marysville, CA (2019)

This letter expresses the Law Center’s concerns with the city’s  proposed camping ordinance. It urges the addressed officials to vote no on the proposed ordinance. The Law Center has offered assistance in implementing constructive policies in its place.

Letter to the City of Wausau, WI (2019)

The Law Center submitted a letter opposing a proposed ordinance in Wausau, WI that would make it illegal to be in a parking lot or garage for any longer than necessary to park a car. Based on comments from the Office of the City Attorney, the ordinance seems motivated in part by complaints about people sleeping in ramp stairwells. As with other ordinances that criminalize the lives of people experiencing homelessness in one way or another, the ordinance  fails to address where these people will be able to seek shelter if not in the targeted parking lots and vehicles. The lack of plan or requirement to house or adequately shelter the displaced persons means they are merely dispersed to different public spaces. Given this, the Law Center has urged city officials to oppose or amend the ordinance to better serve the needs of all members of the Wausau community.

Letter to the Mayor and City Council of Las Vegas, NV (2019)

In this letter, the Law Center raises concerns with a proposed bill to prohibit camping and similar activities on public property. The bill, were it to pass, would greatly limit the ability of people experiencing homelessness to rest in light of a lack of alternatives. The letter references our reports and past litigation to point out the inefficiency and cruelty of criminalizing homelessness as with a camping ban. It also provides suggestions to pursue for constructive, non-criminalizing alternatives.

Letter to the Mayor and City Council of Austin, TX (2019)

This letter from the Law Center urges the City of Austin to continue their course in decriminalizing homelessness, and not to bow to outside pressure to revise their ordinances to add the criminalization of homelessness into the city’s laws. The letter reminds the city of the non-punitive measures available to them, and the other law enforcement tools available to address legitimate public safety and health concerns. Further, it encourages the city to pursue the constructive alternative of the Homelessness Action Plan already being developed locally as of the time of the letter’s writing.

Public Comment to HUD, re: Mixed Status Rulemaking (2019)

This comment voices our strong opposition to changes regarding the eligibility of families for financial assistance. This comment raises concerns not addressed by HUD that the proposed rule will increase homelessness and inflict the costs of housing instability on eligible families and on society as a whole.  The proposed rule would result in many eligible individuals losing their housing and being exposed to housing instability and potential homeless. The rule will also exacerbate the existing crisis of a lack of affordable housing and result in fewer families being able to receive assistance, and would reduce the quantity and quality of assistance available for others. The effects would stretch beyond just immigrant families, as the resulting increase in housing instability and homelessness will result in greater costs to U.S. citizen families and their communities than it currently costs HUD to keep families stably housed and work toward self-sufficiency through these programs.

Letter to Montgomery, AL Mayor re: Panhandling Ordinance (2019)

The Law Center wrote this letter to urge the Mayor of Montgomery, AL to not sign an ordinance which prohibits panhandling in the City of Montgomery.  Since the landmark Reed v. Gilbert case in 2015, every panhandling ordinance challenged in federal court—at 25 of 25 to date—including many with features similar to the ones in Montgomery, has been found constitutionally deficient.  At least 31 additional cities have repealed their panhandling ordinances when informed of the likely infringement on First Amendment rights.  The City’s ordinance not only almost certainly violates the constitutional right to free speech protected by the First Amendment to the United States Constitution, it is also bad policy, and numerous examples of better alternatives now exist which the City could draw on. We recommend the mayor and the city council to reconsider the ordinance and instead consider more constructive alternatives or risk potential litigation.

Letter to the Volusia County, FL Council re: First Step Shelter (2017)

This letter to the Volusia County Council opposes the proposal recommended by Dr. Robert Marbut to construct a low-barrier shelter for the purposes of forcing homeless persons to “choose” between a shelter with an outdated approach to homelessness or going to jail. We commend the county on its willingness to commit funds to ending homelessness, but they could be much better expended following federal policy and national best practices which emphasize a Housing First approach in conjunction with not promoting the criminalization of homelessness. Following the letter, the county postponed its vote on the proposal.
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