Desertrain v. City of Los Angeles

Quick Summary

Cheyenne Desertrain and co-plaintiffs (plaintiffs), homeless individuals, contested the City of Los Angeles’ (defendant) enforcement of a code prohibiting living in vehicles. They were arrested or cited for normal activities like eating or sheltering in their cars.

The dispute centered around whether the code was too vague and resulted in arbitrary enforcement against the homeless. The Ninth Circuit found the law unconstitutional due to its ambiguity and potential for discriminatory application, reversing the lower court’s decision.

Facts of the Case

Cheyenne Desertrain and six other individuals (plaintiffs), who were homeless, faced legal action after the City of Los Angeles (defendant) enforced a municipal code that barred the use of vehicles as living quarters. The plaintiffs engaged in everyday activities like eating, resting, and seeking shelter in their cars due to their homelessness.

Despite these actions not being consistently penalized, they were arrested or cited under the ambiguous law. The plaintiffs sought legal redress, claiming the municipal code was unconstitutionally vague and facilitated arbitrary enforcement, which they argued violated their due process rights under the Fourteenth Amendment.

The enforcement of this code began after a Venice Homelessness Task Force was created, targeting homeless individuals living in vehicles. The plaintiffs, including Jacobs-Elstein, Taylor, Warivonchik, and Cagle, experienced varying encounters with law enforcement that led to citations and arrests despite attempts to comply with the law. They ultimately challenged the constitutionality of the municipal code in federal court, leading to the legal proceedings in question.

Procedural History

The plaintiffs filed suit in federal district court against the City and individual police officers.
The district court denied the plaintiffs’ motion for summary judgment and granted the defendants’ motion for summary judgment.
The plaintiffs appealed to the United States Court of Appeals for the Ninth Circuit.

I.R.A.C. Format

Issue

Whether the Los Angeles Municipal Code Section 85.02, prohibiting the use of vehicles as living quarters, is unconstitutionally vague on its face, failing to provide sufficient notice of prohibited conduct and promoting arbitrary and discriminatory enforcement in violation of the Due Process Clause of the Fourteenth Amendment.

Rule of Law

A law is considered unconstitutionally vague if it does not clearly define prohibited conduct or establish standards for enforcement, potentially leading to arbitrary application and infringing upon individuals’ right to due process.

Reasoning and Analysis

The Ninth Circuit Court found that Los Angeles Municipal Code Section 85.02 was unconstitutionally vague because it did not clearly define what constitutes ‘use’ of a vehicle as ‘living quarters’. The court noted that ordinary people could not reasonably understand what behaviors were prohibited, as activities such as eating or having personal belongings in a vehicle could be interpreted as violations.

Furthermore, the law’s ambiguity had led to inconsistent application by police, primarily impacting homeless individuals and thus raising concerns of discriminatory enforcement. In its analysis, the court referenced precedents where similar vagueness concerns led to statutes being struck down.

They emphasized the importance of clear standards to prevent selective enforcement and ensure citizens have fair notice of illegal actions. The court concluded that Section 85.02 failed both to provide adequate notice and prevent arbitrary enforcement, violating constitutional due process protections.

Conclusion

The Ninth Circuit reversed the district court’s ruling and held that Los Angeles Municipal Code Section 85.02 was unconstitutionally vague, violating the Due Process Clause of the Fourteenth Amendment.

Key Takeaways

The court determined that laws must provide clear definitions and standards to avoid being unconstitutionally vague.
Arbitrary enforcement targeting specific groups, such as the homeless, demonstrates a law’s failure to meet constitutional standards for due process.
The decision underscores how statutes impacting fundamental aspects of daily life must be scrutinized to protect individuals’ rights against ambiguous legislation.

Relevant FAQs of this case

What constitutes a law as being 'unconstitutionally vague'?

A law is ‘unconstitutionally vague’ when it fails to provide a person of ordinary intelligence fair notice of what is prohibited, or when it is so standardless that it authorizes or encourages serious discriminatory enforcement.

For example: A city ordinance prohibits “unreasonably loud noise,” but does not define ‘unreasonably loud,’ leaving it open to arbitrary interpretation and enforcement.

How does vague legislation affect due process rights?

Vague legislation infringes on due process rights as individuals must have clear notice of the behavior that could subject them to criminal penalties, ensuring they can govern their actions accordingly.

For example: A law prohibits “behaving badly” in public with no further guidance on what behavior falls under this category, making it impossible for individuals to adjust their behavior to avoid legal trouble.

What are the implications of a law that leads to arbitrary enforcement against a particular group?

When a law leads to arbitrary enforcement, especially against a specific group, it raises issues of unequal treatment under the law, amounting to discrimination that violates the equal protection clause of the Constitution.

For example: A dress code policy is enforced only against employees of a certain ethnicity, demonstrating discriminatory application even if the policy itself seems neutral on its face.

References

Last updated February 15, 2024

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