Amicus Curiae Brief — City of Grants Pass, Oregon, Petitioner v. Gloria Johnson, et al., on Behalf of Themselves and All Others Similarly Situated

No. 23-175

In The

Supreme Court of the United States

____________________

CITY OF GRANTS PASS,

Petitioner,

v.

GLORIA JOHNSON AND JOHN LOGAN,

ON BEHALF OF THEMSELVES AND

ALL OTHERS SIMILARLY SITUATED,

Respondents.

____________________

On Petition for Writ of Certiorari to the United

States Court of Appeals for the Ninth Circuit

____________________

BRIEF AMICUS CURIAE OF

PACIFIC LEGAL FOUNDATION and

CALIFORNIA BUSINESS PROPERTIES

ASSOCIATION IN SUPPORT OF PETITIONER

____________________

MARK MILLER

Counsel of Record

Pacific Legal Foundation

4440 PGA Blvd., Ste. 307

Palm Beach Gardens, FL 33410

(561) 691-5000

Mark@pacificlegal.org

Counsel for Amici Curiae

Pacific Legal Foundation and

California Business Properties

Association

i

QUESTION PRESENTED

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 through 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?

ii

TABLE OF CONTENTS

QUESTION PRESENTED .......................................... i

TABLE OF AUTHORITIES ..................................... iii

IDENTITY AND INTEREST OF

AMICI CURIAE ....................................................... 1

INTRODUCTION AND SUMMARY ......................... 3

ARGUMENT ............................................................... 4

I. THE COURT SHOULD GRANT

CERTIORARI BECAUSE THE DECISION

BELOW LEAVES LOCAL OFFICIALS

WITHOUT WORKABLE OR CLEAR

GUIDELINES FOR ADDRESSING THE

HOMELESSNESS CRISIS .............................. 4

II. THE COURT SHOULD GRANT

CERTIORARI BECAUSE THE DECISION

BELOW EXACERBATES THE DAMAGE TO

PRIVATE PROPERTY THAT IS

OCCURRING BECAUSE OF THE

HOMELESSNESS CRISIS .............................. 8

CONCLUSION.......................................................... 12

iii

TABLE OF AUTHORITIES

Page(s)

Cases

Cedar Point Nursery v. Hassid,

141 S.Ct. 2063 (2021) ............................................ 1

Jackson v. City of Joliet,

715 F.2d 1200 (7th Cir. 1983) ............................... 5

Johnson v. City of Grants Pass,

50 F.4th 787 (9th Cir. 2022),

amended on denial of reh’g,

72 F.4th 868 (9th Cir. 2023) .............. 3, 5–7, 11–12

Knick v. Township of Scott,

139 S.Ct. 2162 (2019) ............................................ 1

Martin v. City of Boise,

920 F.3d 584 (9th Cir. 2019) ............ i, 3, 5–6, 9, 11

Murr v. Wisconsin,

582 U.S. 383 (2017) ............................................... 1

Pakdel v. City and Cnty. of San Francisco,

141 S.Ct. 2226 (2021) ............................................ 1

Palazzolo v. Rhode Island,

533 U.S. 606 (2001) ............................................... 1

Suitum v. Tahoe Reg’l Planning Agency,

520 U.S. 725 (1997) ............................................... 1

Wilkins v. United States,

143 S.Ct. 870 (2023) .............................................. 1

iv

United States Constitution

U.S. Const. amend. VIII ...................................... i, 4–5

U.S. Const. amend. XIV .............................................. 5

Rules

Supreme Court Rule 37.2 ........................................... 1

Supreme Court Rule 37.6 ........................................... 1

Other Authorities

Associated Press, Phoenix faces dueling

lawsuits over homeless crisis as

advocates scramble for more shelter,

AZPM News (May 27, 2023),

https://news.azpm.org/p/newsc/2023/

5/27/216199-phoenix-faces-duelinglawsuits-over-homeless-crisis-asadvocates-scramble-for-more-shelter/................. 10

Burgos, Annalisa, Businesses plead for

long-term solutions as they ‘play

police’ with aggressive patrons,

Hawaii News Now (Jan. 19, 2023),

https://www.hawaiinewsnow.com/20

23/01/20/hawaiis-homeless-crisistakes-toll-local-restaurants/ ................................ 10

Carlton, Jim, A Montana Town Faces a

Homelessness Problem Similar to

San Francisco and L.A., The Wall

Street Journal (Sept. 2, 2023),

https://www.wsj.com/business/hospit

ality/a-montana-town-faces-ahomelessness-problem-similar-tosan-francisco-and-l-a-eba26824 ............................ 9

v

Granda, Carlos, Business owners

struggle to deal with homeless

encampments they say bring crime,

hurt bottom line, ABC 7 News Los

Angeles (Mar. 22, 2023),

https://abc7.com/lincoln-heightshomeless-encampment-los-angelescity-council/12988239 ............................................ 8

Green, Sara Jean, Citing ‘dire

conditions,’ 33 King County Superior

Court judges urge immediate

shutdown of Seattle’s City Hall

[Homeless] Park,

The Seattle Times (June 25, 2021),

https://www.seattletimes.com/seattle

-news/law-justice/citing-direconditions-33-king-county-superiorcourt-judges-urge-immediateshutdown-of-seattles-city-hallpark/?utm_source=marketingcloud&

utm_medium=email&utm_campaign

=BNA_062621032006+33+judges+ur

ge+immediate+shutdown+of+City+H

all+Park_6_25_2021&utm_term=Act

ive%20subscriber ................................................. 10

KCAL-News Staff, Northridge business

owner says homelessness hurting

sales, CBS Los Angeles

(July 29, 2022),

https://www.cbsnews.com/losangeles/

news/northridge-business-ownersays-homelessness-hurting-sales/ ......................... 9

vi

Lillis, Ryan, ‘A better life.’ How a

Facebook community helps

thousands fleeing California

for other states,

The Sacramento Bee (July 13, 2022),

https://www.sacbee.com/news/califor

nia/article263363228.html#storylink

=cpy ...................................................................... 11

Nazaryan, Alexander, San Francisco is

in trouble, battered by remote work

and the homeless crisis,

Yahoo! News (June 16, 2023),

https://news.yahoo.com/sanfrancisco-is-in-trouble-battered-byremote-work-and-the-homelesscrisis-160203782.html ......................................... 10

Saslow, Rachel, Fleeing Portland? We

have bad news about home prices in

surrounding bedroom towns,

Willamette Week (Apr. 13, 2022),

https://www.wweek.com/news/2022/0

4/13/fleeing-portland-we-have-badnews-about-home-prices-insurrounding-bedroom-towns ............................... 11

Schauer, Frederick, Playing by the

Rules: A Philosophical Examination

of Rule-Based Decision-Making in

Law and in Life (Clarendon Press

paperback ed. 1992) ............................................... 6

vii

Shapiro, Ilya, State Police Powers and

the Constitution, Cato Institute

Pandemics and Policy

(Sept. 15, 2020),

https://www.cato.org/pandemicspolicy/state-police-powersconstitution ........................................................ 4–5

Sunstein, Cass R., Justice Scalia’s

Democratic Formalism,

107 Yale L.J. 529 (1997) ........................................ 7

Tweet of Governor Gavin Newsom

of California, X (Aug. 29, 2023),

https://x.com/gavinnewsom/status/16

96600790188822690?s=46&t=KKw0

PCXg7R0gudKVowDDt ......................................... 7

1

Pursuant to Rule 37.2 of the Rules of this Court,

Amici Curiae, Pacific Legal Foundation (PLF) and the

California Business Properties Association (C.B.P.A.),

submit this brief in support of Petitioner City of

Grants Pass. 1

IDENTITY AND INTEREST

OF AMICI CURIAE

Pacific Legal Foundation (PLF) is a nonprofit

corporation organized for the purpose of litigating

matters affecting the public interest in private

property rights, individual liberty, and economic

freedom; all of those interests are at issue in the

instant case. PLF attorneys have participated as lead

counsel in several cases before the U.S. Supreme

Court in defense of these rights. See, e.g., Wilkins v.

United States, 143 S.Ct. 870 (2023); Cedar Point

Nursery v. Hassid, 141 S.Ct. 2063 (2021); Pakdel v.

City and Cnty. of San Francisco, 141 S.Ct. 2226

(2021); Knick v. Township of Scott, 139 S.Ct. 2162

(2019); Murr v. Wisconsin, 582 U.S. 383 (2017);

Palazzolo v. Rhode Island, 533 U.S. 606 (2001);

Suitum v. Tahoe Reg’l Planning Agency, 520 U.S. 725

(1997). PLF’s arguments based on this experience will

assist the Court in understanding and deciding the

Pursuant to Rule 37.2, Amici provided timely notice to all

parties. Pursuant to Rule 37.6, Amici affirm that no counsel for

any party authored this brief in whole or in part, and no counsel

or party made a monetary contribution intended to find the

preparation or submission of this brief. No person other than

Amici, their members, or their counsel made a monetary

contribution to its preparation or submission.

1

2

important issues presented by the petition in this

case.

C.B.P.A. is a commercial real estate trade

association that serves as the legislative and

regulatory advocate for property owners, tenants,

developers, retailers, contractors, land use attorneys,

brokers, and other professionals in the commercial

real estate industry. With over 10,000 members,

C.B.P.A. is the largest consortium of commercial real

estate professionals in California.

C.B.P.A. is the designated legislative advocate for

the International Council of Shopping Centers (ICSC),

NAIOP of California, the Commercial Real Estate

Developers Association (NAIOP), the Building

Owners and Managers Association of California

(BOMA), the Retail Industry Leaders Association

(RILA), the Institute of Real Estate Management

(IREM), the Association of Commercial Real Estate –

Northern and Southern California (ACRE), the

National Association of Real Estate Investment

Trusts (NAREIT), AIR Commercial Real Estate

Association, and the California Association for Local

Economic Development (CALED).

C.B.P.A. is the recognized voice of all aspects of the

commercial, industrial, and retail real estate industry

in California. Its members range from some of

America’s largest retailers and commercial property

owners and tenants to individual and family-run

commercial real estate interests. C.B.P.A. supports

the granting of this petition because the homeless

crisis in California is negatively impacting its

members; business properties and the lower court’s

decision is making the problem worse.

3

INTRODUCTION AND SUMMARY

“Homelessness is presently the defining public

health and safety crisis in the western United States.”

Johnson v. City of Grants Pass, 50 F.4th 787 (9th Cir.

2022), amended on denial of reh’g, 72 F.4th 868, 934

(9th Cir. 2023) (Smith, J., dissenting from den’l of

reh’g en banc). The homelessness crisis inordinately

and negatively impacts private property and private

business across the western states that comprise the

Ninth Circuit’s jurisdiction. Government exists to

protect individual rights, including their personal

safety and private property rights. But the Ninth

Circuit’s murky rule issued here makes it difficult for

cities to protect individual safety and public or private

property in cities with large homeless populations.

In the instant case, the City of Grants Pass,

Oregon, passed a number of ordinances to address the

crisis, and those ordinances in part prohibited

individuals who sought to sleep or camp on public

property from doing so. Id. at 876. This exercise of the

city’s police powers fell well within the ambit of how

cities have addressed trespassing on public property

for time immemorial. Id. at 944–45 (Bress, J.,

dissenting from denial of rehearing en banc)

(explaining that before the Ninth Circuit injected

itself into the question, the question of how to address

a homeless crisis was a question left to local and state

governments, and that it was best left that way).

Unfortunately, the Ninth Circuit’s decision in the

instant case, when combined with an earlier

precedent from the same court, Martin v. City of Boise,

920 F.3d 584 (9th Cir. 2019), tied the hands of elected

city leaders in the West who sought to address the

homeless crisis. It did so premised on a reading of the

4

Eighth Amendment’s cruel and unusual punishment

prohibition that this Court has never endorsed.

Certainly, the police powers exercised by Grants

Pass in this case are constrained by individual

constitutional rights. But by taking public policy

options off the table for policy makers premised on a

constitutional right that this Court has heretofore not

recognized, the Ninth Circuit has exceeded its

authority.

That being the case, this Court should grant

certiorari.

ARGUMENT

I.

THE

COURT

SHOULD

GRANT

CERTIORARI BECAUSE THE DECISION

BELOW LEAVES LOCAL OFFICIALS

WITHOUT WORKABLE OR CLEAR

GUIDELINES FOR ADDRESSING THE

HOMELESSNESS CRISIS

The western states’ homeless crisis calls for health

and safety legislative policy decisions to address it,

and these police powers are within the ambit of state

and local legislative authority when properly

exercised. See Ilya Shapiro, State Police Powers and

the Constitution, Cato Institute Pandemics and Policy

(Sept. 15, 2020) (“State police powers have long been

recognized to include the authority to make laws for

public health and safety”). 2 In exercising their police

powers, the elected leaders of Grants Pass set out

tailored ordinances designed to protect the public

from the dangers that inevitably follow homeless

https://www.cato.org/pandemics-policy/state-police-powersconstitution.

2

5

encampments. The city’s ordinances prohibited

individuals who sought to sleep or camp on public

property from doing so. Johnson, 72 F.4th at 876. If an

individual refused to abide by the prohibition, they

could be fined. Id. If violations of the ordinances

continued, then they could face criminal discipline. Id.

To be sure, the Fourteenth Amendment limits how

far cities may go in exercising their police powers. See

Shapiro, State Police Powers and the Constitution

(“Exercises of the state police power must respect the

individual rights guaranteed in the Constitution”).

But the Ninth Circuit created an unworkable and

opaque rule, enjoining enforcement of a number of

those Grants Pass ordinances purportedly because the

ordinances violated the Eighth Amendment. The

court held that “involuntarily homeless persons must

have ‘somewhere’ to sleep and take rudimentary

precautions (bedding) against the elements.” Johnson,

72 F. 4th at 915 (quoting Martin, 920 F.3d at 590

(Berzon, J., concurring in denial of rehearing en

banc)). It announced from that conclusion that the

homeless had a novel, positive constitutional right 3 to

sleep in public spaces, such as public parks or

As Judge Richard Posner once observed, the Constitution

protects negative rights (what the government cannot do to you),

not positive rights (what the government purportedly owes you).

See Jackson v. City of Joliet, 715 F.2d 1200, 1203 (7th Cir. 1983)

(“[T]he Constitution is a charter of negative rather than positive

liberties . . . [t]he men who wrote the Bill of Rights were not

concerned that government might do too little for the people, but

that it might do too much to them. The Fourteenth Amendment,

adopted in 1868 at the height of laissez-faire thinking, sought to

protect Americans from oppression by state government, not to

secure them basic governmental services.”).

3

6

sidewalks, even when doing so interferes with others’

ability to safely use or enjoy them.

Further, because Grants Pass does not have

enough beds for all homeless people, it could not even

enforce the camping ban against particular

individuals who are offered a bed but choose to

illegally camp instead. See Johnson, 72 F.4th at 938

(Smith, J., dissenting from denial of reh’g en banc). To

be sure, the majority deleted this “bed formula” from

the revised opinion, since the formula had come in for

so much criticism after the original opinion was

released. Id. But as Judge Smith explains, removing

the bed formula did not change the implications of the

decision since “the approach that [deleted] language

forthrightly described remains embedded in the

opinion.” Id. The bed formula makes it virtually

impossible for cities to act—thus it is unworkable.

The Ninth Circuit’s rule also leaves cities without

clear options to protect public property from

trespassing and becoming public nuisances. Rules are

supposed “to foster the interrelated virtues of reliance,

predictability, and certainty.” Frederick Schauer,

Playing by the Rules: A Philosophical Examination of

Rule-Based Decision-Making in Law and in Life, at

137 (Clarendon Press paperback ed. 1992). The “rule”

of Martin and now Johnson has failed to deliver on

any of those virtues. Instead, cities are tied up in the

federal courts because their good faith efforts to

ameliorate the homeless crisis are faced with lawsuits

premised on the Martin rule, see Johnson, 72 F.4th at

940–43 (Smith, J., dissenting from denial of rehearing

en banc) (describing the lawsuits in San Francisco,

7

Phoenix, Santa Barbara, Sacramento, and Chicago),

as now revised by Johnson.

When a rule is unpredictable, no one can rely upon

it—least of all, as we see here, legislators who have

every reason to want to act legally because otherwise

they end up in court. Compare Cass R. Sunstein,

Justice Scalia’s Democratic Formalism, 107 Yale L.J.

529, 531 (1997) (explaining that Justice Scalia favored

clear rules in part because they provide the

background upon which legislators write, they make

the law more readily predictable, and they better

ensure “that Congress [or in this case, local and state

legislators] will legislate in the constitutionally

preferred fashion”).

Governor Gavin Newsom of California threw his

hands up in response to these two Ninth Circuit

decisions. In addressing the crisis on X (formerly

known as Twitter), he stated in pertinent part: “On

homelessness . . . California has made record

investments—$15.3 bil. But federal courts block local

efforts to clean street encampments—even when

housing and services are offered. Courts must also be

held accountable. Enough is enough.” 4 Governor

Newsom’s point and the Amici’s point is the same: the

Ninth Circuit has gone too far.

To be sure, “[t]he challenges faced by individuals

experiencing homelessness are severe. And the

challenges that face municipalities are daunting.”

Johnson, 72 F.4th at 934 (Graber, J., dissenting from

denial of rehearing en banc). The Ninth Circuit’s

unworkable and confusing rule prevents local and

4 https://x.com/gavinnewsom/status/1696600790188822690?s=

46&t=KKw0PCXg7R0gudKVowDDtA.

8

state elected officials from addressing the crisis in a

way that protects the public—including the homeless

men and women who are members of the public.

II.

THE

COURT

SHOULD

GRANT

CERTIORARI BECAUSE THE DECISION

BELOW EXACERBATES THE DAMAGE

TO PRIVATE PROPERTY THAT IS

OCCURRING

BECAUSE

OF

THE

HOMELESSNESS CRISIS

Recent news reports detailing the decline of city

life litter the newspapers and news stations of the

West. These stories universally tie the decline to the

increase in crime, disease, and drug use that the

rising tide of homeless bring to these cities.

For example, in the Lincoln Heights section of Los

Angeles, earlier this year business owners explained

that they regularly see gun violence, gang activity,

drug use, and vehicles broken into in the homeless

encampment near their stores, and that the problem

is getting worse. 5 One explained: “Customers come to

me, so many customers. Once they come over here to

my place for my service, and they see the [homeless in

the] area, they just leave.” 6

Likewise, over in the San Fernando Valley

business owners describe a drop in business directly

tied to the open drug use and trash piling up in the

5 Carlos Granda, Business owners struggle to deal with homeless

encampments they say bring crime, hurt bottom line, ABC 7 News

Los Angeles (Mar. 22, 2023) (quoting business owners in the

Lincoln Heights section of Los Angeles), https://abc7.com/lincolnheights-homeless-encampment-los-angeles-city-council/

12988239/.

6 Id.

9

homeless encampment set up directly in front of or

adjacent to their businesses, and they describe a city

government that is doing nothing about it. 7

Circumstances

Montana:

are

no

better

in

Missoula,

Some 600 people without homes live in the

Northern Rockies college town [Missoula],

triple the number of a decade ago, many of them

in tents in city parks. Their presence has sown

growing anger among residents who say the

parks have become dirty and unsafe.

Shannone Hart said a group of teens she

works with saw homeless people fighting in a

park and that she moved in June from a house

near an encampment along the Clark Fork.

“Just the sheer litter and feces and garbage

pollution that was going into the river was

concerning,” Hart said.

Jim Carlton, A Montana Town Faces a Homelessness

Problem Similar to San Francisco and L.A., The Wall

Street Journal (Sept. 2, 2023). 8

The Journal story explains why Missoula officials

cannot address the problem: “Missoula has a decadesold law that makes it illegal to camp in a park, but

can’t enforce it because of a 2018 ruling [Martin] by

the Ninth Circuit . . . that found removing anyone

7

KCAL-News Staff, Northridge business owner says

homelessness hurting sales, CBS Los Angeles (July 29, 2022),

https://www.cbsnews.com/losangeles/news/northridge-businessowner-says-homelessness-hurting-sales/.

8

https://www.wsj.com/business/hospitality/a-montana-townfaces-a-homelessness-problem-similar-to-san-francisco-and-l-aeba26824.

10

camping in a public space . . . when there isn’t a

shelter bed for them constitutes cruel and unusual

punishment.” Id. The story goes on to note that

Missoula has less than half the beds necessary to

comply with the order. Id.

Other cities in the West fare no better, with recent

news stories from Phoenix, 9 Seattle, 10 Honolulu, 11 and

of course San Francisco, 12 all describing how the

9 Associated Press, Phoenix faces dueling lawsuits over homeless

crisis as advocates scramble for more shelter, AZPM News

(May 27, 2023) (describing homeless crisis in area of town known

as “The Zone”), https://news.azpm.org/p/newsc/2023/5/27/216199

-phoenix-faces-dueling-lawsuits-over-homeless-crisis-asadvocates-scramble-for-more-shelter/.

10 Sara Jean Green, Citing ‘dire conditions,’ 33 King County

Superior Court judges urge immediate shutdown of Seattle’s City

Hall [Homeless] Park, The Seattle Times (June 25, 2021)

(describing dangerous conditions for judges, court personnel, and

jurors because of homeless encampments near courthouse),

https://www.seattletimes.com/seattle-news/law-justice/citingdire-conditions-33-king-county-superior-court-judges-urgeimmediate-shutdown-of-seattles-city-hall-park/?utm_source=

marketingcloud&utm_medium=email&utm_campaign=BNA_06

2621032006+33+judges+urge+immediate+shutdown+of+City+H

all+Park_6_25_2021&utm_term=Active%20subscriber.

11 Annalisa Burgos, Businesses plead for long-term solutions as

they ‘play police’ with aggressive patrons, Hawaii News Now

(Jan. 19, 2023) (describing how Honolulu businesses are

reporting more confrontations with aggressive homeless people

and that the homeless crisis is impacting their bottom line),

https://www.hawaiinewsnow.com/2023/01/20/hawaiis-homelesscrisis-takes-toll-local-restaurants/.

12 Alexander Nazaryan, San Francisco is in trouble, battered by

remote work and the homeless crisis, Yahoo! News (June 16,

2023) (setting out how the easy availability of fentanyl and the

lack of mental health services, combined with the pandemic,

exacerbated the chaos occasioned by the homeless crisis in San

Francisco), https://news.yahoo.com/san-francisco-is-in-trouble-

11

homeless crisis—largely arising from drug abuse and

mental health problems—is getting worse, hurting

businesses, and escapes easy answers.

Likewise, homeowners living in cities in the Ninth

Circuit’s jurisdiction also face the homeless crisis—

often right on their doorstep. In Portland, realtors say

the recent increase in homelessness is the number one

reason people are seeking to move out of town, and

they point to homeless encampments on public

property specifically as a driver behind the desire to

flee the city. 13 And the Sacramento Bee points to the

“exploding” homeless crisis as a significant factor

driving hundreds of thousands of Californians to leave

the state. 14

The Martin and Johnson decisions have only

exacerbated the problem facing elected leaders,

businesses, and residents. The Court should grant the

petition in order to clarify a workable rule that allows

cities to better address the crisis.

battered-by-remote-work-and-the-homeless-crisis160203782.html.

13 Rachel Saslow, Fleeing Portland? We have bad news about

home prices in surrounding bedroom towns, Willamette Week

(Apr. 13, 2022), https://www.wweek.com/news/2022/04/13/

fleeing-portland-we-have-bad-news-about-home-prices-insurrounding-bedroom-towns/.

14 Ryan Lillis, ‘A better life.’ How a Facebook community helps

thousands fleeing California for other states, The Sacramento

Bee (July 13, 2022), https://www.sacbee.com/news/california/

article263363228.html#storylink=cpy.

12

CONCLUSION

This Court should grant the petition.

DATED: September 2023.

Respectfully submitted,

MARK MILLER

Counsel of Record

Pacific Legal Foundation

4440 PGA Blvd., Ste. 307

Palm Beach Gardens, FL

33410

(561) 691-5000

Mark@pacificlegal.org

Counsel for Amici Curiae

Pacific Legal Foundation

and California Business

Properties Association