Amicus Curiae Brief — City of Grants Pass, Oregon, Petitioner v. Gloria Johnson, et al., on Behalf of Themselves and All Others Similarly Situated
Supreme Court briefApr 3, 2024
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No. 23-175
In the
Supreme Court of the United States
CITY OF GRANTS PASS, OREGON,
Petitioner,
v.
GLORIA JOHNSON, ET AL., ON BEHALF OF THEMSELVES
AND ALL OTHERS SIMILARLY SITUATED,
Respondents.
On Writ of Certiorari to the United States
Court of Appeals for the Ninth Circuit
BRIEF OF AMICI CURIAE NATIONAL
COALITION FOR HOMELESS VETERANS,
UCLA VETERANS’ LEGAL CLINIC AND 43
OTHER VETERANS’ SERVICE PROVIDERS IN
SUPPORT OF RESPONDENTS
SUNITA PATEL
JEANNE NISHIMOTO
VETERANS LEGAL CLINIC
UCLA SCHOOL OF LAW
907 Westwood Blvd. #444
Los Angeles, CA 90024
(310) 268-3837
patel@law.ucla.edu
April 3, 2024
DAVID VENDERBUSH
Counsel of Record
ALSTON & BIRD LLP
90 Park Avenue
New York, NY 10016-1387
(212) 210-9532
david.venderbush@alston.com
Counsel for Amici Curiae
Becker Gallagher · Cincinnati, OH · Washington, D.C. · 800.890.5001
i
TABLE OF CONTENTS
TABLE OF AUTHORITIES ...................................... iv
INTEREST OF THE AMICI CURIAE....................... 1
SUMMARY OF ARGUMENT .................................... 1
ARGUMENT ............................................................... 3
I.
REVERSAL WILL THWART THE U.S. GOVERNMENT’S COMMITMENT TO END VETERAN HOMELESSNESS.................................... 3
A. Structural and Historic Barriers Related
to Housing Contribute to Veteran Homelessness .......................................................... 6
B. Systemic Barriers to Accessing Important
Veterans Affairs Benefits and Services
Proven to Uplift Veterans out of Homelessness .......................................................... 8
C. Bureaucratic Barriers and Paperwork
Challenges to Accessing Services ................ 15
II. UNHOUSED VETERANS REPORT CRIMINALIZATION AND SWEEPS MAKE IT
HARDER TO ACCESS SERVICES AND EXACERBATES THE SEVERITY OF HOMELESSNESS. ........................................................ 17
A. Enforcement Actions Make Homelessness
Worse for Disabled, Elderly, and Chronically Ill Veterans; Neglects Their Sacrifices to the Nation ........................................ 19
ii
1. Erin Spencer – Retired Marine with
Chronic Pain and Service-Connected
Disabilities Arrested for Habitation
and Injured in the Process .................... 19
2. Duane Nichols – 60-year-old Homeless
Veteran with Multiple Physical Disabilities and Visual Impairment ............ 22
3. Bob – Disabled Veteran in and out of
Homelessness for 10 Years Whose
Wife was Severely Injured During a
Sweep ..................................................... 24
4. Lucrecia – Homeless Veteran and
Cancer Survivor .................................... 26
B. Enforcement Actions Risk Banishment for
Homeless Veterans ...................................... 28
1. Doug Higgins – Unhoused Disabled Veteran Cited and Fined; Paid Rather
than Face Exile from Place He Considers Home ................................................ 28
2. Emilio Rodriguez – Police Target Marine
Veteran, Suggest Leaving City, and
Throw Irreplaceable Property Into Irrigation Canal........................................ 30
C. Sweeps Make Accessing Services Such as
Housing More Difficult ................................ 33
1. Ken – Homeless Veteran Has His Social Security Card, DD-214, Birth Certificate, and ID Destroyed in Sweep,
Leading to Loss of Access to Shelter
Space ...................................................... 33
iii
2. Jerry Roderick Burton—Police Take
Documents Necessary to Appeal VA
Disability Decision—and Thomas Peterson—Police Take Medals and Other
Property
from
Wheelchair-Using
Army Veteran—Both Veterans Subjected to Enforcement Actions in SubFreezing Temperatures ......................... 34
CONCLUSION ......................................................... 39
APPENDIX – List of Amici Curiae .......................... 1a
iv
TABLE OF AUTHORITIES
Cases
Bloom v. City of San Diego,
No. 3:17-cv-02324-AJB-NLS, 2018 WL 9539239
(S.D. Cal. Aug. 21, 2018).................................. 29, 30
Bloom v. City of San Diego,
No. 3:17-cv-02324-AJB-DEB, 2024 WL 1162103
(S.D. Cal. Mar. 18, 2024) ....................................... 30
Hous. is a Hum. Right Orange Cnty. v. Cnty. of
Orange,
No. 8:19-cv-00388-PA-JDE, 2019 WL 8012374
(C.D. Cal. Oct. 28, 2019) ........................................ 24
Kincaid v. City of Fresno,
No. 1:06-cv-1445 OWW SMS, 2006 WL
3542732 (E.D. Cal. Dec. 8, 2006) ..................... 30, 31
Lyall v. City of Denver,
No. 1:16-cv-02155-WJM-SKC, 2019 WL
9443748 (D. Colo. Feb. 21, 2019) ........................... 36
Prado v. City of Berkeley,
No. 23-cv-04537-EMC, 2023 WL 6307921 (N.D.
Cal. Sept. 27, 2023) ................................................ 19
Statutes
Vehicle Habitation Ordinance (San Diego
Municipal Code section 86.0137(f) ........................ 30
Regulations
Funding Opportunity Under Supportive Services
for Veteran Families Program, 88 Fed. Reg.
84,396 (Dec. 5, 2023) ................................................ 8
v
Proclamation No. 9962, National Veterans and
Military Families Month, 2019, 3 C.F.R. §206
(2020). ....................................................................... 3
Proclamation No. 10305, Veterans’ Day, 2021,
3 C.F.R. §300 (2022)................................................. 4
38 C.F.R. §62.34(a)(1), (7) (2023) .............................. 14
Other Authorities
Brandon Alford & Shawna J. Lee, Toward
Complete Inclusion: Lesbian, Gay, Bisexual &
Transgender Military Members After Repeal of
Don’t Ask, Don’t Tell, 61 Soc. Work 257 (2016) .... 10
Johanna K. Anderson et al., U.S. Dep’t Veterans
Affs. Health Servs. Rsch. & Dev. Serv., Factors
Associated with Homelessness Among U.S.
Veterans: A Systematic Review (2023)................. 6, 9
B21001: Sex by Age by Veteran Status for the
Civilian Population 18 Years and Over, 2022
American Community Survey, U.S. Census Bureau,
https://data.census.gov/table/ACSDT1Y2022.B2
1001?q= Veterans%20%20sex
[https://perma.cc/D3W9-ABY5] ............................... 5
Richard Bryant, Post-Traumatic Stress Disorder
vs. Traumatic Brain Injury, 13 Dialogues
Clinical Neuroscience 251 (2011) .......................... 10
City of Grants Pass Housing Production Strategy
(2023), [https://perma.cc/NK5T-B87N] ................... 8
Civil Minutes, Prado v. City of Berkeley, No. 23cv-04537-EMC (N.D. Cal. Nov. 15, 2023), Doc.
50 ............................................................................ 20
vi
Jamie Suki Chang et al., Harms of Encampment
Abatements on the Health of Unhoused People,
2 SSM-Qualitative Rsch. Health, no. 100064,
Dec. 2022 ................................................................ 12
Comm. to Evaluate Dep’t Veterans Affs. Mental
Health Servs., Nat’l Acads. of Scis., Eng’g &
Med., Evaluation of the Department of Veterans
Affairs Mental Health Services (2018),
[https://perma.cc/VNY6-H857] .............................. 12
Conn. Veterans Legal Ctr., Discretionary
Injustice (2022),
[https://perma.cc/46DG-TF8Q] ........................ 10, 11
Declaration of Jerry Roderick Burton, Lyall v.
City of Denver, No. 1:16-cv-02155-WJM-CBS
(D. Colo. Sept. 9, 2016),
Doc. No. 15-8 ........................................ 34, 35, 36, 37
Declaration of Jerry Burton in Support of Motion
in Limine for Order Suspending Camping Ban
Enforcement During Trial, Lyall v. City of
Denver, No. 1:16-cv-02155-WJM-SKC (D. Colo.
Feb. 4, 2019), Doc. No. 201-1 ................................. 36
Declaration of Doug Higgins in Support of Motion
for Summary Adjudication, Bloom v. City of
San Diego, No. 3:17-cv-02324-AJB-DEB (S.D.
Cal. Sept. 22, 2022), Doc. No. 232–35 ............. 28, 29
vii
Declaration of Doug Higgins in Support of
Plaintiffs’ Motion for Preliminary Injunction,
Bloom v. City of San Diego, No. 3:17-cv-02324AJB-DEB (S.D. Cal. Apr. 30, 2018), Doc. No.
26-12 ................................................................. 28, 29
Declaration of Duane Nichols in Support of a
Temporary Restraining Order, Hous. is a Hum.
Right Orange Cnty. v. Cnty. of Orange, No.
8:19-cv-00388-PA-JDE (C.D. Cal. June 30,
2019), Doc. No. 69-4 ......................................... 23, 24
Declaration of Thomas Peterson, Lyall v. City of
Denver, No. 1:16-cv-02155-WJM-CBS (D. Colo.
Sept. 9, 2016), Doc. No. 15-10 .................... 37, 38, 39
Declaration of Emilio Moses Rodriguez, Kincaid
v. City of Fresno, No. 1:06-cv-01445-LJO-SKO
(E.D. Cal. Nov. 6, 2006), Doc. No. 54 ........ 30, 31, 32
Declaration of Erin Spencer Iso Plaintiffs’ Motion
To Enforce, Prado v. City of Berkeley, No. 23cv-04537-EMC (N.D. Cal. Nov. 13, 2023), Doc.
No. 42-2 ............................................................ 20, 21
Final Order Approving Settlement, Kincaid v.
City of Fresno, 1:06-cv-1445-OWW-SMS (E.D.
Cal. July 25, 2008), Doc. No. 323 .......................... 32
First Amended Complaint for Declaratory and
Injunctive Relief, Prado v. City of Berkeley, No.
23-cv-04537-EMC (N.D. Cal. Nov. 10, 2023),
Doc. No. 41 ............................................................. 19
Gail Gamache et al., Overrepresentation of
Women Veterans Among Homeless Women, 93
Am. J. Pub. Health 1132 (2003) .............................. 4
viii
Hilary Herbold, Never a Level Playing Field:
Blacks and the GI Bill, 6 J. Blacks Higher
Educ. 104 (1994)....................................................... 9
HUD-VASH Vouchers, U.S. Dep’t Hous. & Urb.
Dev.,
https://www.hud.gov/program_offices/public_in
dian_hou-sing/programs/hcv/vash
[https://perma.cc/TUK6-L65W] ............................... 9
Interview with VA Psychiatrist
(Mar. 15, 2024) ........................................... 15, 16, 17
Invisible People, https://invisiblepeople.tv/,
[https://perma.cc/Q6RQ-KRCJ] ............................. 17
Invisible People, 17 Years Military to 10 Years
Homeless in Los Angeles, YouTube (Sept. 8,
2021),
https://www.youtube.com/watch?v=Pf13p_MEZ
ag ................................................................ 24, 25, 26
Invisible People, Cancer Survivor and Homeless
Veteran Living in a Tent in Los Angeles’s
Koreatown, YouTube (Feb. 10, 2020),
https://youtu.be/Omevex_4MOs ................ 26, 27, 28
Invisible People, Homeless Veteran’s ID Taken by
Police Stripped of Access to Shelter, YouTube,
(July 27, 2023),
https://youtu.be/CcLWFZ56OOU .................... 14, 33
ix
Kristen Lago, San Clemente Homeless Camp
Requires Proof of a Tie to the City, Spectrum
News (Sept. 4, 2019, 10:59 AM),
https://spectrumnews1.com/ca/orangecounty/news/2019/09 /04/san-clementehomeless-camp-requires-proof-of-a-tie-to-thecity-?cid=share_clip [https://perma.cc/8SBYXELY] ..................................................................... 22
Lyall v. City of Denver, No. 1:16-cv-02155-WJMSKC (D. Colo. Sept. 23, 2019), Doc. No. 226 ......... 39
Memorandum in Support of Motion for
Preliminary Approval of Settlement, Kincaid v.
City of Fresno, No. 1:06-cv-1445-LJO-SKO
(E.D. Cal. June 5, 2008), Doc. No. 304 .................. 32
Mental Illness, Nat’l Inst. Mental Health,
https://www.nimh.nih.gov/health/statistics/men
tal-illness [https://perma.cc/843Y-WHRZ] ............ 11
Ann Elizabeth Montgomery & Megan Cusack,
U.S. Dep’t Hous. & Urb. Dev., HUD-VASH Exit
Study: Final Report (2017),
[https://perma.cc/WQP9-UQ7N] ............................ 14
Nat’l Health Care for Homeless Council, Impact
of Encampment Sweeps on People Experiencing
Homelessness (2022), [https://perma.cc/JQJ2VSSJ] ................................................................ 13, 15
Brandon Nichter, Jack Tsai & Robert Pietrzak,
Prevalence, Correlates, and Mental Health
Burden Associated with Homelessness in U.S.
Military Veterans, 53 Psych. Med. 3952 (2023) .... 13
x
Order on Motions Regarding Dates and Incidents
That May Be Explored at Trial, Lyall v. City of
Denver, No. 1:16-cv-02155-WJM-SKC (D. Colo.
Oct. 5, 2018), Doc. No. 190..................................... 37
Order Temporarily Enjoining Encampment
Closure, Prado v. City of Berkeley, No. 23-cv04537-EMC (N.D. Cal. Nov. 13, 2023), Doc. No.
45, 2023 WL 7558960 ............................................ 20
Oregon Eviction Filings, Eviction Rsch. Network
(Nov. 12, 2023), [https://perma.cc/9HJY-GB4P] ..... 8
Or. Hous. & Cmty. Servs., Oregon, Demographic
and Hous-ing Profiles (2017),
[https://perma.cc/D475-8V2H] ................................. 8
OUTVETS, Harvard L. Sch. Legal Servs. Ctr. &
Veterans Legal Servs., Turned Away: How VA
Unlawfully Denies Healthcare to Veterans with
Bad Paper Discharges (2020),
[https://perma.cc/7GKS-F7KW] ......................... 9, 10
Plaintiffs’ Emergency Notice of Motion and
Motion for a Temporary Restraining Order and
Order to Show Cause Why Preliminary
Injunction Should Not Issue, Prado v. City of
Berkeley, No. 23-cv-04537-EMC (N.D. Cal.
Sept. 4, 2023), Doc. No. 2 ........................... 19, 20, 21
Remarks on the 20th Anniversary of the
Department of Veterans Affairs, 1 Pub. Papers
258 (Mar. 16, 2009) .................................................. 3
xi
Ericka Ritchie, Homeless at San Clemente’s North
Beach Relocated to City Lot, as Legal Motion Is
Filed to Remove Judge from Related Lawsuit,
Orange Cnty. Reg. (May 24, 2019, 8:03 PM),
https://www.ocregister.com/2019/05/24/homeles
s-at-san-clementes-north-beach-relocated-tocity-lot-as-legal-motion-is-filed-to-removejudge-from-related-lawsuit/ ................................... 22
S2101: Percent Veterans, 2022 American
Community Survey 1-Year Estimates, U.S.
Census Bureau,
[https://perma.cc/M6JC-Q8WM] .............................. 5
John A. Schinka et al., Increased Mortality
Among Older Veterans Admitted to VA
Homelessness Programs, 67 Psych. Servs. 465
(2016) ...................................................................... 13
Second Amended Class Action Complaint, Bloom
v. City of San Diego, No. 3:17-cv-02324-AJBDEB (S.D. Cal. May 1, 2020),
Doc. No. 137 ............................................... 28, 29, 30
Second Amended Complaint, Hous. is a Hum.
Right Orange Cnty. v. Cnty. of Orange, No.
8:19-cv-00388-PA-JDE (C.D. Cal. Sept. 16,
2019), Doc. No. 99 ............................................ 22, 23
Second Amended Complaint, Lyall v. City of
Denver, No. 1:16-cv-02155-WJM-SKC (D. Colo.
Feb. 1, 2017), Doc. No. 69-1 ................................... 38
Luz Mairena Semeah et al., Rental Housing
Needs and Barriers From the Perspective of
Veterans with Disabilities, 29 Hous. Pol’y
Debate 542 (2019) .............................................. 7, 14
xii
Tanya de Sousa et al., U.S. Dep’t of Hous. & Urb.
Dev., The 2023 Annual Homelessness
Assessment Report (AHAR) to Congress: Part 1,
(2023),
https://www.huduser.gov/portal/sites/default/fil
es/pdf/2023-AHAR-Part-1.pdf
[https://perma.cc/X7NX-9N3G]................ 2, 4, 5, 6, 7
Stipulation for Dismissal with Prejudice, Lyall v.
City of Denver, No. 1:16-cv-02155-WJM-SKC
(D. Colo. Apr. 11, 2017), Doc. No. 103 ................... 34
Linda Diem Tran, David Grant & May Ayadin,
The Mental Health Status of California
Veterans, UCLA Ctr. for Health Pol’y Rsch.,
Apr. 2016, [https://perma.cc/B6CV-E6E5] ............ 11
Ranak B. Trivedi et al., Prevalence, Comorbidity,
and Prognosis of Mental Health Among US
Veterans, 105 Am. J. Pub. Health 2564
(2015) ................................................................ 11, 12
Jack Tsai et al., Addressing Veteran
Homelessness to Prevent Veteran Suicide, 69
Psych. Servs. 935 (2018) ........................................ 13
J. Tsai & D. Hooshyar, Prevalence of Eviction,
Home Fore-closure, and Homelessness Among
Low-Income US Veterans: The National
Veteran Homeless and Other Poverty
Experiences Study, 213 Pub. Health 181
(2022) ...................................................................... 11
xiii
U.S. Dep’t of Hous. & Urb. Dev., HUD 2023
Continuum of Care Homeless Assistance
Programs Homeless Populations and
Subpopulations (Nov. 19, 2023),
[https://perma.cc/2X2E-L955] ................................ 11
U.S. Dep’t of Veterans Affs., American Indian
and Alaska Native Veterans: 2017 (2020),
[https://perma.cc/MC6K-9XJ7] ................................ 7
U.S. Gov’t Accountability Off., GAO 20-433,
Homelessness: Better HUD Oversight of Data
Collection Could Improve Estimates of
Homeless Population (2020),
[https://perma.cc/9MWY-XJFX] .............................. 5
VA Homeless Programs: Point-In-Time Count,
U.S. Dep’t Veterans Affs. (Jan. 3, 2024),
[https://perma.cc/2WPB-BCUS] .......................... 2, 4
VA Off. Mental Health & Suicide Prevention,
2023 National Veteran Suicide Prevention
Annual Report, [https://perma.cc/XG8M-WBP4] .. 14
Jonathan Vespa, Post-9/11 Veterans More Likely
to Have a Service-Connected Disability, U.S.
Census Bureau (June 2, 2020),
https://www.census.gov/library/stories/2020/06/
who-are-the-na-tions-veterans.html
[https://perma.cc/M7UC-HUXL]............................ 12
xiv
Supriya Yelimeli, Berkeley Police Arrest 2 at West
Berkeley Homeless Camp Closure, Berkeleyside
(Nov. 7, 2023, 4:35 PM),
https://www.berkeleyside.org/2023/11/07/berkeley-police-arrest-resident-observer-westberkeley-homeless-camp-closure
[https://perma.cc/K5YE-AHX9] ............................. 21
1
INTEREST OF THE AMICI CURIAE 1
Amici curiae are 45 organizations who provide
services to veterans of the U.S. military. Our memberships or clients face the harsh and dehumanizing consequences that accompany criminalization of homelessness, whether through civil infractions or low-level
criminal offenses that target survival activities of unhoused persons. We have a duty to ensure that the
voices of veterans are included in the resolution of this
case. The stories provided in this brief are not outliers.
They are representative of the over 35,000 unhoused
veterans, who despite having pledged willingness to
make the ultimate sacrifice for our country, now find
themselves sleeping on our sidewalks, under bridges,
on benches, and in abandoned buildings every night.
Appendix 1 includes a list of Amici.
SUMMARY OF ARGUMENT
Our nation’s leaders have expressed a commitment to veterans of the U.S. military. In recognition of
the sacrifices servicemembers make on our collective
behalf, government leaders at all levels, regardless of
political party, acknowledge the disgrace accompanying the phrase “homeless veteran.” Despite numerous
statements and initiatives to end veteran homelessness at the federal, state, and local levels, a disproportionate number of unsheltered veterans still stay on
our streets every night. The U.S. Department of Housing and Urban Development (HUD) counted 35,574
1 Pursuant to Supreme Court Rule 37.6, amici state that no
counsel for a party authored any part of this brief. No person or
entity other than amici and their counsel made a monetary contribution to the preparation or submission of this brief.
2
veterans experiencing homelessness (sheltered and
unsheltered) on one night in January 2023. 2 That figure represents an increase of over 7.4% from the previous year 3 and an appalling 14.3% increase in unsheltered veteran homelessness from 2022 to 2023, compared to a 9.7% increase in the unsheltered civilian
population. 4
Reversal in this case will criminalize thousands
of veterans merely for being unhoused. To permit
Grants Pass and other localities to punish survival—
sleeping with adequate coverings—will violate decades of this Court’s Eighth Amendment jurisprudence
prohibiting punishment of status. That outcome would
eviscerate the minimal protections unhoused veterans
have against degrading treatment while sleeping outside and in public spaces.
The Court cannot ignore the impact its decision
will have on our nation’s military veterans whose lived
experiences as unhoused veterans are captured in this
Brief. Part I presents data and information to understand the intertwined structural barriers and individual risks for homelessness among adult veterans.
Part II provides the lived realities of unhoused veterans. The stories depict criminalization like the antiPoint-In-Time Count, U.S. Dep’t
Veterans Affs. (Jan. 3, 2024), [https://perma.cc/2WPB-BCUS].
2 VA Homeless Programs:
3 Id.
4 Id. See also Tanya de Sousa et al., U.S. Dep’t of Hous. &
Urb. Dev., The 2023 Annual Homelessness Assessment Report
(AHAR) to Congress: Part 1, at 11, 66 (2023), https://www.huduser.gov/portal/sites/default/files/pdf/2023-AHAR-Part-1.pdf
[https://perma.cc/X7NX-9N3G] [hereinafter 2023 AHAR].
3
sleeping laws at issue in this case, as well as sweeps
and other enforcement actions. Veterans are less
likely to leave homelessness when vital records, medications, and other items needed to receive services are
discarded in those actions. Plus, local enforcement creates harsher and more cruel experiences for veterans.
ARGUMENT
I.
REVERSAL WILL THWART THE U.S. GOVERNMENT’S COMMITMENT TO END VETERAN HOMELESSNESS
Three Presidents have pledged to end veteran
homelessness. 5 In 2009, then President Barack
Obama promised to “provide new help for homeless
veterans, because those heroes have a home; it’s the
country they served, the United States of America.
And until we reach a day when not a single veteran
sleeps on our Nation’s streets, our work remains unfinished.” 6 Former President Trump recommitted:
“Each warrior who fights for our Nation, along with
their families, has earned our eternal gratitude . . . .
Together, we remain committed to fostering a national
community of support for these brave heroes and their
families.” 7 President Joe Biden echoed the obligation,
5 Throughout this brief, “homeless veteran” and “unhoused
veteran” are used interchangeably. Researchers often use “homeless experienced” to connote an individual who has experienced
homelessness in their lifetime.
6 Remarks on the 20th Anniversary of the Department of Veterans Affairs, 1 Pub. Papers 258, 259 (Mar. 16, 2009).
Proclamation No. 9962, National Veterans and Military
Families Month, 2019, 3 C.F.R. §§206, 207 (2020).
7
4
stating, “Our Nation has only one truly sacred obligation: to properly prepare and equip our service members when we send them into harm’s way and to care
for them and their families when they return home.” 8
Even with those commitments, and despite an
overall reduced percentage of unhoused veterans since
2009, 9 in 2023, HUD’s annual point-in-time count calculated a 7.4% increase in homeless veterans (sheltered and unsheltered) since the previous year. 10 Out
of the 35,574 homeless veterans counted, 15,507 veterans experienced unsheltered homelessness on one
night in January. 11 These figures show an appalling
14.3% increase in unsheltered veteran homelessness
from 2022 to 2023, compared to a 9.7% increase in the
unsheltered civilian population. 12 Veteran women are
particularly overrepresented; 13 making up 2.9% of the
population of unsheltered women though they only
8 Proclamation No. 10305, Veterans’ Day, 2021, 3 C.F.R. §300
(2022).
9 2023 AHAR, supra note 4, at 3 (noting 52% decline in veter-
ans experiencing homelessness since 2009, the baseline year in
the AHAR for this count).
2.
10 VA Homeless Programs: Point-In-Time Count, supra note
11 2023 AHAR, supra note 4, at 66.
12 VA Homeless Programs: Point-In-Time Count, supra note
2; see also 2023 AHAR, supra note 4, at 11, 66.
13 See Gail Gamache et al., Overrepresentation of Women Vet-
erans Among Homeless Women, 93 Am. J. Pub. Health 1132, 1134
(2003) (finding “the risk of homelessness to be 2 to 4 times greater
for women veterans than for nonveterans.”).
5
make up 1.3% of the adult population of women. 14
Data collection challenges suggest an undercount in
veteran homelessness. 15
The disproportionality in veteran homelessness
is starker when analyzed by state. 16 In Nevada, veterans are 12.6% of the homeless population, though they
are only 8.3% of the general adult population. Veterans are 16.9% of the homeless population in Wyoming,
but only 9.4% of the general adult population. 4.3% of
the general population in California are veterans, but
they comprise 5.8% of the homeless population. 17
The Court should take notice that Oregon is one
of the few states that has experienced an overall increase in veteran homelessness since 2009. 18 Veterans
make up 7.8% of the homeless population in Oregon
though they only comprise 7.4% of the general adult
14 2023 AHAR, supra note 4, at 13, 67; B21001: Sex by Age by
Veteran Status for the Civilian Population 18 Years and Over,
2022 American Community Survey, U.S. Census Bureau,
https://data.census.gov/table/ACSDT1Y2022.B21001?q=
Veterans%20%20sex [https://perma.cc/D3W9-ABY5].
15 2023 AHAR, supra note 4, at 65. See also U.S. Gov’t Ac-
countability Off., GAO 20-433, Homelessness: Better HUD Oversight of Data Collection Could Improve Estimates of Homeless
Population 7–8 (2020), [https://perma.cc/9MWY-XJFX].
16 2023 AHAR, supra note 4, at 69–71 & app.
17 For statewide homeless veteran calculations, see 2023
AHAR, supra note 4, app. For Veteran general adult population
share estimates see S2101: Percent Veterans, 2022 American
Community Survey 1-Year Estimates, U.S. Census Bureau, [https://perma.cc/M6JC-Q8WM].
18 2023 AHAR, supra note 4, at 71.
6
population. 19 Currently over half (56%) of all veterans
experiencing homelessness in Oregon are unsheltered. 20 Additionally, the state witnessed an alarming
23.4% increase in veteran homelessness from 2009 to
2023. 21
A. Structural and Historic Barriers Related
to Housing Contribute to Veteran Homelessness
Reversal in this case jeopardizes the country’s
success over the last 15 years in reducing overall veteran homelessness. As this Part shows, structural and
historic factors contribute to the rates of veteran
homelessness and the likelihood of moving into permanent housing. Community factors such as affordable housing stock, labor market conditions, eviction
policies and practices, racial discrimination, and inequality within the military are important to consider
alongside the individual-level vulnerabilities discussed below, such as risk of suicide, in-service
trauma, and chronic illnesses. 22 Criminalization only
exacerbates veterans’ experiences of both individuallevel and structural dynamics.
First, historic inequity contributes to women,
Black, and Indigenous veterans’ overrepresentation in
19 Id. at 110.
20 Id. at 69–71.
21 Id. at 70.
Johanna K. Anderson et al., U.S. Dep’t Veterans Affs.
Health Servs. Rsch. & Dev. Serv., Factors Associated with Homelessness Among U.S. Veterans: A Systematic Review 4, 13, 27
(2023).
22
7
the numbers of veterans experiencing homelessness.
According to the 2023 Annual Homelessness Assessment Report to Congress:
•
“[W]omen veterans experiencing homelessness
were more likely to be found in unsheltered locations than their male counterparts (54% vs.
42%).” 23
•
“Black veterans comprised 36[%] of veterans
experiencing sheltered homelessness and
25[%] of veterans experiencing unsheltered
homelessness but only 12[%] of all U.S. veterans.” 24
•
Veterans who identify as American Indian,
Alaska Native, or Indigenous made up 5[%] of
the unsheltered veteran population though
less than 1[%] of veterans. 25
Racial, income, disability, and family discrimination among renters likely compounds the inability
of such veterans to find and maintain housing. 26 Owners are less likely to rent to veterans with prior
23 2023 AHAR, supra note 4, at 68.
24 Id. Multiple longitudinal studies reported increased home-
lessness among Black veterans compared to white veterans. Anderson et al., supra note 22, at 25.
25 2023 AHAR, supra note 4, at 13; U.S. Dep’t of Veterans
Affs., American Indian and Alaska Native Veterans: 2017, at 6
(2020), [https://perma.cc/MC6K-9XJ7].
26 See, e.g., Luz Mairena Semeah et al., Rental Housing Needs
and Barriers From the Perspective of Veterans with Disabilities,
29 Hous. Pol’y Debate 542 (2019).
8
evictions or broken leases, criminal backgrounds, and
poor credit. 27
Second, systemic barriers to securing rental
housing in Oregon contribute to its high rate of veteran homelessness. “Between September 2022 to August 2023, the 12 month eviction filing rate [in Oregon] is at 4% (1 in 25 renter households) as compared
to 3% in 2019 (1 in 33 renter households).” 28 One out
of three renters in that state pays more than 50% of
their income in rent. 29 In Grants Pass, 58% of renters
are cost burdened (paying more than 30% of their income in rent) with the highest cost burdens falling on
those with the lowest incomes. 30
B. Systemic Barriers to Accessing Important
Veterans Affairs Benefits and Services
Proven to Uplift Veterans out of Homelessness
Multiple studies show veterans with higher VA
service-connected disability rating—corresponding to
higher compensation—had lower chances of experiencing homelessness than individuals with no or lower
27 See id.; see also Funding Opportunity Under Supportive
Services for Veteran Families Program, 88 Fed. Reg. 84,396,
84,397 (Dec. 5, 2023).
28 Oregon Eviction Filings, Eviction Rsch. Network (Nov. 12,
2023), [https://perma.cc/9HJY-GB4P].
29 Or. Hous. & Cmty. Servs., Oregon, Demographic and Housing Profiles (2017), [https://perma.cc/D475-8V2H].
City of Grants Pass Housing Production Strategy, at I
(2023), [https://perma.cc/NK5T-B87N].
30
9
ratings. 31 Assisting veterans in obtaining VA care and
VA benefits, including cash assistance, vocation and
employment support, and housing vouchers through
HUD-Veterans Affairs Supportive Housing (HUDVASH) is essential to ending veteran homelessness. 32
Discharge status plays a central role in unequal
access to VA benefits, healthcare, and services. Servicemembers are assigned a “character of service” or
“discharge status” upon leaving military service. A
servicemember’s character of service may be designated as Honorable, General, Other Than Honorable,
Bad Conduct, or Dishonorable. According to a report
from prominent veteran’s organizations, “While most
servicemembers receive Honorable discharge statuses, a substantial percentage—approximately 7[%]
of veterans discharged between 1980 and 2020—receive discharge statuses that are not Honorable, which
are known as ‘bad paper.’” 33
Former servicemembers with “bad paper” are
associated with higher rates of homelessness and unemployment. Historically, structural racism, 34
31 Anderson et al., supra note 22, at 17.
HUD-VASH Vouchers, U.S. Dep’t Hous. & Urb. Dev.,
https://www.hud.gov/program_offices/public_indian_housing/programs/hcv/vash [https://perma.cc/TUK6-L65W].
32
33 OUTVETS, Harvard L. Sch. Legal Servs. Ctr. & Veterans
Legal Servs., Turned Away: How VA Unlawfully Denies
Healthcare to Veterans with Bad Paper Discharges 1 (2020),
[https://perma.cc/7GKS-F7KW] [hereinafter Turned Away].
34 Hilary Herbold, Never a Level Playing Field: Blacks and
the GI Bill, 6 J. Blacks Higher Educ. 104 (1994).
10
traumatic brain injuries or mental health conditions, 35 in-service trauma (including racial harassment and military sexual trauma), and “Don’t Ask,
Don’t Tell” 36 have led to downgrading discharge statuses that disqualify former servicemembers from VA
healthcare, GI Bill, and VA home loan programs. 37 A
report from the Connecticut Veterans Legal Center
detailed the inequalities among Black servicemembers and discharge statuses. Based on government
data from 2014-2020, Black servicemembers:
•
“received over 25% of Other Than Honorable
discharges, and over 30% of General discharges” 38
•
“overall—across all service branches—were approximately 1.5 times as likely as white servicemembers to receive an Other Than Honorable
rather than Honorable discharge” 39
35 Richard Bryant, Post-Traumatic Stress Disorder vs. Trau-
matic Brain Injury, 13 Dialogues Clinical Neuroscience 251
(2011).
36 Brandon Alford & Shawna J. Lee, Toward Complete Inclu-
sion: Lesbian, Gay, Bisexual & Transgender Military Members
After Repeal of Don’t Ask, Don’t Tell, 61 Soc. Work 257 (2016).
37 See Turned Away, supra note 33, at 2–3, 5, 8; Conn. Veter-
ans Legal Ctr., Discretionary
[https://perma.cc/46DG-TF8Q].
Injustice
14–18
38 Discretionary Injustice, supra note 37, at 5.
39 Id.
(2022),
11
Finally, “[i]n the years 2014–2020, there was no discernable improvement over time in the racial disparities in discharge status.” 40
Discriminatory discharge statuses contribute to
an overall lack of access to VA healthcare for veterans.
Veterans without care for their chronic illnesses or
mental disabilities are more likely to live in poverty
than other veterans, 41 which puts them at heightened
risk for experiencing homelessness. 42 Although only
21% of unhoused adults experience Serious Mental Illness (SMI) 43 and only 3.7% of veterans experience
SMI, 44 meaning “a mental, behavioral or emotional
disorder resulting in serious functional impairment,
which substantially interferes with or limits one or
more major life activities,” 45 structural barriers to
40 Id.
41 Linda Diem Tran, David Grant & May Ayadin, The Mental
Health Status of California Veterans, UCLA Ctr. for Health Pol’y
Rsch., Apr. 2016, at 1, 3, [https://perma.cc/B6CV-E6E5].
42 J. Tsai & D. Hooshyar, Prevalence of Eviction, Home Fore-
closure, and Homelessness Among Low-Income US Veterans: The
National Veteran Homeless and Other Poverty Experiences Study,
213 Pub. Health 181 (2022).
43 U.S. Dep’t of Hous. & Urb. Dev., HUD 2023 Continuum of
Care Homeless Assistance Programs Homeless Populations and
Subpopulations (Nov. 19, 2023), [https://perma.cc/2X2E-L955].
44 Ranak B. Trivedi et al., Prevalence, Comorbidity, and Prognosis of Mental Health Among US Veterans, 105 Am. J. Pub.
Health 2564, 2565 (2015).
Mental
Illness,
Nat’l
Inst.
Mental
Health,
https://www.nimh.nih.gov/health/statistics/mental-illness
[https://perma.cc/843Y-WHRZ].
45
12
healthcare limit access to life improving resources and
lead to premature death. 46 Only half of veterans with
mental health disabilities related to their military service receive treatment. 47 Post-9/11 veterans have
higher rates of severe disability, mental health disorders, trauma-related injuries, and substance use than
their nonveteran peers and veterans of prior wars. 48
Enforcement actions have perilous consequences for the health and survival of houseless people, and their path to housing. Although sweeps are
not at issue in this case, they serve as the underlying
basis for property confiscation. One study found that
sweeps “severed people from possessions, resources,
and social supports needed to sustain health,” forced
people to relocate into “more isolated, hazardous, and
remote spaces,” and were “a persistent source of distress and tension between unhoused people and authorities.” 49 The National Health Care for the Homeless Council reports: “Health care providers (and other
direct service providers) often cannot find their
46 Trivedi et al., supra note 44, at 2566.
Comm. to Evaluate Dep’t Veterans Affs. Mental Health
Servs., Nat’l Acads. of Scis., Eng’g & Med., Evaluation of the Department of Veterans Affairs Mental Health Services 117 (2018),
[https://perma.cc/VNY6-H857].
47
48 Jonathan Vespa, Post-9/11 Veterans More Likely to Have a
Service-Connected Disability, U.S. Census Bureau (June 2, 2020),
https://www.census.gov/library/stories/2020/06/who-are-the-nations-veterans.html [https://perma.cc/M7UC-HUXL].
49 Jamie Suki Chang et al., Harms of Encampment Abate-
ments on the Health of Unhoused People, 2 SSM-Qualitative
Rsch. Health, no. 100064, Dec. 2022, at 9.
13
patients after a sweep, and have no knowledge of
where they might have gone.” 50 Prescription medications are lost and usually unrecoverable. 51
Tragically, housing instability and homelessness among veterans increase risk for suicide. Based
on a study using a nationally representative sample of
veterans, the rate of suicide attempts is more than five
times higher among veterans who experienced homelessness within the previous two years than veterans
without a history of homelessness. 52 Another more recent study found homeless experienced veterans were
twice as likely to attempt suicide in their lifetime and
had “nearly three times the odds of attempting suicide
two or more times.” 53 Older veterans experiencing
homelessness are “twice as likely to die by suicide
[than] those who were not.” 54 Tragically, the suicide
Nat'l Health Care for Homeless Council, Impact of Encampment Sweeps on People Experiencing Homelessness 3 (2022),
[https://perma.cc/JQJ2-VSSJ].
50
51 Id.
52 Jack Tsai et al., Addressing Veteran Homelessness to Pre-
vent Veteran Suicide, 69 Psych. Servs. 935, 936 (2018).
53 Brandon Nichter, Jack Tsai & Robert Pietrzak, Prevalence,
Correlates, and Mental Health Burden Associated with Homelessness in U.S. Military Veterans, 53 Psych. Med. 3952, 3959 (2023).
Id. (citing John A. Schinka et al., Increased Mortality
Among Older Veterans Admitted to VA Homelessness Programs,
67 Psych. Servs. 465 (2016)).
54
14
rate among veterans increased by 11.6% from 2020 to
2021, while non-veteran adults increased by 4.5%. 55
Unhoused veterans face barriers to housing
through veteran-specific housing opportunities. With
Supportive Services for Veteran Families (SSVF), the
housing payments are generally limited to six or nine
months and veteran families may be required to share
in the cost of rent. 56 In the HUD-VASH program, veterans with mental health or substance use conditions
were found to have more difficulty attaining and maintaining housing. 57 Generally, veterans with disabilities identified confusing housing regulations, unknowledgeable housing professionals, and affordable
housing shortages in neighborhoods reflecting the veterans’ needs as barriers to finding and maintaining affordable rental housing. 58 One veteran in Part II remarked that although many people believe it is easier
for veterans to escape homelessness, “that is not the
case” and “it is not a guaranteed thing,” despite the
options available to veterans. 59
VA Off. Mental Health & Suicide Prevention, 2023 National Veteran Suicide Prevention Annual Report 5,
[https://perma.cc/XG8M-WBP4].
55
56 38 C.F.R. § 62.34(a)(1), (7) (2023).
57 Ann Elizabeth Montgomery & Megan Cusack, U.S. Dep’t
Hous. & Urb. Dev., HUD-VASH Exit Study: Final Report 56, 77
(2017), [https://perma.cc/WQP9-UQ7N]. Cf. Semeah et al., supra
note 26 at 549.
58 Semeah et al., supra note 26, at 547–52.
Invisible People, Homeless Veteran's ID Taken by Police
Stripped of Access to Shelter, YouTube, at 00:01:52–00:03:05,
(July 27, 2023), https://youtu.be/CcLWFZ56OOU.
59
15
C. Bureaucratic Barriers and Paperwork
Challenges to Accessing Services
Although this case involves a challenge to the
extreme ordinances in Grants Pass punishing sleeping
or resting on public property with only a blanket, in
many communities, such laws serve as the basis for
property and paperwork confiscation through sweeps
of homeless individuals, undermining paths to income
stability and housing. Sweeps destroy job-related
items, such as uniforms or tools, and create criminal
records that disqualify homeless individuals from certain jobs. 60
A VA psychiatrist whose research and clinical
practice centers on homeless experienced veterans recounted the connection between attaining housing and
basic access to paperwork: “[T]he average person could
not envision how many hours [we] spen[d] getting
someone an ID or bank papers.” 61 When asked if she
could provide a specific example of a patient struggling to secure housing due to paperwork she mentioned “vividly” remembering one veteran. This person, who was 100% service-connected, had diagnoses
of schizophrenia and complex neurological disorder,
lived in his vehicle while receiving VA services. He secured competitive employment at the VA. Despite the
VA’s best efforts, after 8 months, he does not have
6.
60 Nat'l Health Care for Homeless Council, supra note 50, at
61 Interview with VA Psychiatrist (Mar. 15, 2024) (transcript
on file with authors).
16
necessary paperwork to enroll in HUD-VASH, so he
remains unhoused. 62 She continued:
Why isn’t this guy housed and he’s working a competitive job at the VA. . . . We
have these [ ] examples of guys like this.
They’re actually very engaged. They are
seeking care. He was on an injectable
medication. He wanted to work. He had
made this enormous recovery from being
on the streets, but it’s like, and why isn’t
he housed. It’s a paperwork problem, and
he’s been on hold for years.
She explains the significance of lost paperwork
and the connection to housing acquisition:
Hours and hours and days of time spent
getting documents sort of go down the
drain because we either can’t find [the
person] or we can’t get things mailed and
delivered, or we finally get the document
and they lose it because it was in a backpack that got confiscated, or in a you
know, a shopping cart that they were told
they couldn’t keep in a transitional housing facility that they had to move to because they couldn’t be on the street. The
documentation thing can’t be understated, but it’s just hard, and unless
62 Id.
17
you’ve sat with a veteran [you wouldn’t
know]. 63
She concluded, “You can see how many people get lost
in the shuffle, even in this extremely enriched [VA]
system of having so many resources and so many
vouchers.” 64
Veterans are willing to die for our freedom, and
the nation’s leaders have pledged to end veteran
homelessness. Yet, this Part shows veterans are disproportionality represented among the houseless and
provides structural and individual factors contributing to unsheltered veterans.
II.
UNHOUSED VETERANS REPORT CRIMINALIZATION AND SWEEPS MAKE IT
HARDER TO ACCESS SERVICES AND EXACERBATES THE SEVERITY OF HOMELESSNESS
To show the lived realities of unhoused veterans, Amici present stories of veteran plaintiffs in civil
rights actions and video testimonials available at the
Invisible People website. 65 They are presented in the
present tense, though some cases led to judgment, settled, or were dismissed on other grounds.
These stories include enforcement of anti-camping laws before this Court, but also encompass descriptions of sweeps and property confiscation. While this
63 Id.
64 Id.
Invisible
People,
[https://perma.cc/Q6RQ-KRCJ].
65
https://invisiblepeople.tv/,
18
case does not involve sweeps, when homeless people
are arrested pursuant to anti-camping ordinances like
those in Grants Pass, they face similar consequences
to individuals subjected to sweeps. A reversal of
Grants Pass will lead to harsher circumstances because police will cite and fine more unhoused veterans.
The stories of Erin, Duane, Bob, Lucrecia,
Doug, Emilio, Ken, Jerry, and Thomas presented here
serve three purposes, and sometimes illustrate more
than one goal. First, they show how enforcement actions affect those with chronic illnesses and exacerbate or are themselves disabling. Second, the veterans’
stories show the callousness of some localities, including banishment threats and dehumanizing treatment.
Third, they show the routine nature of property destruction—loss of vital records, photos, medals, and
medicine—for unhoused veterans.
These are their stories.
19
A. Enforcement Actions Make Homelessness
Worse for Disabled, Elderly, and Chronically Ill Veterans; Neglects Their Sacrifices to the Nation
1. Erin Spencer – Retired Marine with Chronic
Pain and Service-Connected Disabilities Arrested for Habitation and Injured in the Process
Erin Spencer is a disabled Marine Corps vet-
eran. 66 He has a shoulder injury from his time in ser-
vice that “puts pressure on the nerve” under his collar
bone, causing him chronic pain, and limiting his mobility. 67 It also limits his ability to lift weighty items. 68
Mr. Spencer also suffers from mental health conditions, stemming from “a childhood of abuse and neglect [and] from his time in the military . . . .” 69
Mr. Spencer stays at an encampment at 8th and
Harrison in Berkeley, California. 70 In his shelter, he
stores items he uses to make a living, such as tools and
bike parts. 71 He cannot move these items because of
66 Prado v. City of Berkeley, No. 23-cv-04537-EMC, 2023 WL
6307921, at *3 (N.D. Cal. Sept. 27, 2023).
67 Id.
68 Id.
69 First Amended Complaint for Declaratory and Injunctive
Relief ¶ 38, Prado v. City of Berkeley, No. 23-cv-04537-EMC (N.D.
Cal. Nov. 10, 2023), Doc. No. 41.
70 Id. ¶ 32.
71 Plaintiffs’ Emergency Notice of Motion and Motion for a
Temporary Restraining Order and Order to Show Cause Why
20
his disability. 72 Mr. Spencer requested, on numerous
occasions, that the City help him move his belongings. 73 Despite stating it will help, the City has never
done so. 74
On November 7, 2023, Mr. Spencer was arrested for “illegal lodging” in Berkeley when he was
leaving the Harrison Street encampment with his
cart: 75
All of a sudden, I was surrounded by police officers. They grabbed me and surrounded me. They forced me to sit on the
sidewalk. They hand-cuffed me before
ever telling me I was arrested or detained. I have a service-connected shoulder disability that makes it very painful
to have my arms behind my back and I
Preliminary Injunction Should Not Issue at 5, Prado v. City of
Berkeley, No. 23-cv-04537-EMC (N.D. Cal. Sept. 4, 2023), Doc.
No. 2 [hereinafter Pls.’ Emergency Mot.].
72 Id.
73 Id.
74 Id.
75 Declaration of Erin Spencer Iso Plaintiffs’ Motion To En-
force ¶¶ 2–3, Prado v. City of Berkeley, No. 23-cv-04537-EMC
(N.D. Cal. Nov. 13, 2023), Doc. No. 42-2 [hereinafter Decl. of
Spencer]. The court temporarily enjoined the City from closing
Spencer’s camp. Order Temporarily Enjoining Encampment Closure, Prado, No. 23-cv-04537-EMC (N.D. Cal. Nov. 13, 2023),
Doc. No. 45, 2023 WL 7558960, and later denied Plaintiffs’ injunctive relief on the abatement order, as the abatement was
over. Civil Minutes, Prado, No. 23-cv-04537-EMC (N.D. Cal. Nov.
15, 2023), Doc. 50. Litigation continues in this case.
21
told them this, but they cuffed me anyway even though I was not resisting. . . .
I have PTSD related to previous incarcerations, in addition to other traumas, and
I left jail feeling shaken and betrayed. I
have been having difficulty processing
my thoughts and memories since then. 76
After leaving jail, when Mr. Spencer came back
to the place he stays, “the sidewalk was just empty.” 77
Mr. Spencer’s belongings were gone, taken by the
City. 78 The arrest and property confiscation added insult to injury, especially because Mr. Spencer repeatedly communicated his need for accommodations to
the City. 79
Mr. Spencer described what it means to be a repeated victim of sweeps and clean-ups:
[T]he massive number of times the City
or State have taken all I possess leaves
me in a vacuous déjà vu, yet again. . . .
This is the ninth time the City has taken
nearly everything from me after I’ve constructed the carts necessary to keep
76 Decl. of Spencer, supra note 75, ¶¶ 2–5.
77 Id. ¶ 6.
78 Id. See generally Supriya Yelimeli, Berkeley Police Arrest 2
at West Berkeley Homeless Camp Closure, Berkeleyside (Nov. 7,
2023, 4:35 PM), https://www.berkeleyside.org/2023/11/07/berkeley-police-arrest-resident-observer-west-berkeley-homelesscamp-closure [https://perma.cc/K5YE-AHX9].
79
Pls.’ Emergency Mot., supra note 71, at 5.
22
myself mobile . . . . I fear my loved ones
will be left seeking redress for a corpse. 80
2. Duane Nichols – 60-year-old Homeless Veteran with Multiple Physical Disabilities and
Visual Impairment
Duane Nichols is a 60-year-old disabled, homeless Navy veteran81 living in San Clemente, California, with no source of income. 82 Mr. Nichols is disabled
and relies on a tricycle for mobility assistance. 83 He
suffers from limited vision, chronic obstructive pulmonary disease, arthritis, blood clots, and hip issues. 84
He has been homeless for the last 30 years. 85
80 Decl. of Spencer, supra note 75, ¶ 15.
81 Ericka Ritchie, Homeless at San Clemente’s North Beach
Relocated to City Lot, as Legal Motion Is Filed to Remove Judge
from Related Lawsuit, Orange Cnty. Reg. (May 24, 2019, 8:03
PM),
https://www.ocregister.com/2019/05/24/homeless-at-sanclementes-north-beach-relocated-to-city-lot-as-legal-motion-isfiled-to-remove-judge-from-related-lawsuit/.
82 Second Amended Complaint ¶ 68, Hous. is a Hum. Right
Orange Cnty. v. Cnty. of Orange, No. 8:19-cv-00388-PA-JDE
(C.D. Cal. Sept. 16, 2019), Doc. No. 99.
83 Id. ¶ 70.
84 Id.
Kristen Lago, San Clemente Homeless Camp Requires
Proof of a Tie to the City, Spectrum News 1 (Sept. 4, 2019, 10:59
AM), https://spectrumnews1.com/ca/orange-county/news/2019/09
/04/san-clemente-homeless-camp-requires-proof-of-a-tie-to-thecity-?cid=share_clip [https://perma.cc/8SBY-XELY].
85
23
For over two years, Mr. Nichols slept in a train
station’s parking lot. 86 At night, he was often told he
needed to leave and threatened with arrest by Orange
County Sheriff’s Deputies. 87 However, he had nowhere
else to go because the shelters serving the area were
always either at or over capacity. 88
Mr. Nichols takes blood-thinning medication for
his blood clot condition. 89 The medication makes it
dangerous for Mr. Nichols to be exposed to the sun. 90
Due to his chronic health conditions, San Clemente’s
law requiring unhoused people to take down their
tents every day is especially burdensome. 91 Amici note
sleeping in tents is not the type of law criminalized by
the City of Grants Pass and not an issue before the
Court.
Because of his age and disabilities, Mr. Nichols
tries to avoid encounters with law enforcement. 92
However, avoiding homeless enforcement is unlikely,
remarking:
86 Second Amended Complaint, supra note 82, ¶ 71.
87 Id.
88 Id. ¶ 69.
89 Declaration of Duane Nichols in Support of a Temporary
Restraining Order ¶ 15, Hous. is a Hum. Right Orange Cnty.
v. Cnty. of Orange, No. 8:19-cv-00388-PA-JDE (C.D. Cal. June 30,
2019), Doc. No. 69-4 [hereinafter Decl. of Nichols]; Second
Amended Complaint, supra note 82, ¶ 70.
90 Decl. of Nichols, supra note 89, ¶ 16.
91 Id. ¶ 18.
92 Id. ¶ 7.
24
It is very difficult when the police say
they will cite and arrest us for camping
even with no indoor option available because I am forced to choose between risking arrest and risking threats to my
health and safety in an open space with
no protection from the elements and no
access to food or water. 93
As a veteran with multiple disabilities, he cannot sustain the shuffling and stress of sweeps. 94
3. Bob – Disabled Veteran in and out of Homelessness for 10 Years Whose Wife was Severely Injured During a Sweep
Bob is a homeless, disabled Marine and Navy
veteran living in Los Angeles. 95 He served in the military for 17 ½ years before he was medically discharged. 96 He wanted to re-enlist but was “too damaged” from his years in service. 97
Despite his lengthy and decorated service to the
nation, Bob and his wife, a cancer survivor, are
93 Id. ¶ 17.
94 The court dismissed Mr. Nichols’ claims on the law without
discounting his story. Hous. is a Hum. Right Orange Cnty. v.
Cnty. of Orange, No. 8:19-cv-00388-PA-JDE, 2019 WL 8012374
(C.D. Cal. Oct. 28, 2019).
95 Invisible People, 17 Years Military to 10 Years Homeless in
Los Angeles, YouTube, at 00:00:11–00:00:40 (Sept. 8, 2021),
https://www.youtube.com/watch?v=Pf13p_MEZag.
96 Id. at 00:00:22–00:00:00:40.
97 Id. at 00:00:22–00:00:46.
25
homeless. 98 He has been homeless off and on for ten
years. 99 For a short period of time, Bob and his wife
rented an apartment, however, they lost it after it was
infested with bedbugs and they were unable to afford
to fumigate and replace their affected property. 100 Another time they stayed with a friend and helped with
rent. 101 Sadly, the friend passed away and they didn’t
have first and last month’s rent, necessary to sign a
lease with the landlord. 102
During sweeps occurring over three years, police discarded Bob’s most valuable property. They
threw away his tools, which he values at around
$22,000 dollars. 103 The police also took his tent, which
was his shelter at the time, leaving him “with nothing.” 104
Bob recounted, “My wife, she got hurt on a
clean-up because [the police] were trying to hurry [us]
up and we were trying to save my tools.” 105 As a result
of the police rushing them Bob’s wife tripped and
fell. 106 She cut her leg so severely that it resulted in a
98 Id. at 00:02:45–00:02:47.
99 Id. at 00:09:55–00–00:10:08.
100 Id. at 00:10:08–00:10:31.
101 Id. at 00:10:47–00:11:02.
102 Id.
103 Id. at 00:06:43–00:06:53.
104 Id. at 00:07:26–00:07:38.
105 Id. at 00:11:46–00:12:07.
106 Id. at 00:11:43–00:12:19.
26
blood infection. 107 At the time Bob shared his story,
his wife was hospitalized for almost two weeks. 108
Bob’s video paints the picture of a man wellknown in his community, working to change his circumstances, despite consequences to his health. 109 On
good days, he’s in the neighborhood fixing cars and
taking on odd jobs to make ends meet. 110 However, his
disabilities—stemming from his time in service—
make it hard to work every day, though he wants to. 111
4. Lucrecia – Homeless Veteran and Cancer
Survivor
Lucrecia is a homeless Army veteran and cancer survivor. 112 She lives in Los Angeles’s Koreatown. 113 She became homeless three years earlier
when she lost her job due to cancer and drug use that
started during her cancer treatments. 114 Lucrecia explained how her cancer was central to becoming unhoused:
107 Id. at 00:11:46–00:12:07.
108 Id. at 00:11:15–00:11:21.
109 Id. at 00:02:49–00:03:19.
110 Id. at 00:02:57–00:03:19.
Id. at 00:00:22–00:00:54; 00:03:01–00:03:19; 00:17:25–
00:18:29.
111
112 Invisible People, Cancer Survivor and Homeless Veteran
Living in a Tent in Los Angeles's Koreatown, YouTube, at
00:00:07–00:00:38;
00:01:42–00:01:44
(Feb.
10,
2020),
https://youtu.be/Omevex_4MOs.
113 Id. at 00:09:07–00:10:10.
114 Id. at 00:00:38–00:01:40.
27
So the tumor was very aggressive so that
I had [to] miss work. Miss work to the
point where I couldn’t stay working. My
health just got worse. Because even
though [the] cancer was gone, my immune system was really, really deteriorated. 115
While homeless, Lucrecia experienced repeated
sweeps and police harassment. 116 On one occasion, the
police confiscated all her property, leaving her with
just the clothes she was wearing. 117 Property confiscations of this nature became commonplace.
Over a six-week period, police confiscated Lucrecia’s property three times:
I was finally able to get an RV and then
pay for it little by little. . . . [T]hey took it
with everything I had and then a week
later they took everything I had in a tent.
. . . A week later, they wiped me out here,
everything. . . . 118
Prior to losing her housing, Lucrecia was an advocate of the unhoused. In March 2016, she received
an award from the Mayor of Los Angeles for her homeless “charity work.” 119 Lucrecia remains determined to
115 Id. at 00:01:26–00:01:40.
116 Id. at 00:08:25–00:08:58.
117 Id. at 00:08:42–00:08:55.
118 Id. at 00:09:38–00:10:10.
119 Id. at 00:12:19–00:12:48.
28
transition off the streets and return to helping the unhoused. 120
B. Enforcement Actions Risk Banishment for
Homeless Veterans
1. Doug Higgins – Unhoused Disabled Veteran
Cited and Fined; Paid Rather than Face Exile from Place He Considers Home
Doug Higgins is a 73-year-old unhoused veteran honorably discharged from the Army. 121 Mr. Higgins stays in San Diego, a place he considers home. 122
He experiences several physical and mental health
problems, including anxiety, depression, and a back
condition. 123 Mr. Higgins’ back pain is so severe that
he is unable to stand, sit, or walk for any significant
duration. 124
120 Id. at 00:12:04–00:12:17.
121 Declaration of Doug Higgins in Support of Motion for Sum-
mary Adjudication ¶ 2, Bloom v. City of San Diego, No. 3:17-cv02324-AJB-DEB (S.D. Cal. Sept. 22, 2022), Doc. No. 232–35
[hereinafter Decl. of Higgins Summ. Adj.]; Declaration of Doug
Higgins in Support of Plaintiffs’ Motion for Preliminary Injunction ¶2, Bloom v. City of San Diego, No. 3:17-cv-02324-AJB-DEB
(S.D. Cal. Apr. 30, 2018), Doc. No. 26-12 [hereinafter Decl. of Higgins Prelim. Inj.].
Second Amended Class Action Complaint ¶ 24, Bloom v.
City of San Diego, No. 3:17-cv-02324-AJB-DEB (S.D. Cal. May 1,
2020), Doc. No. 137.
122
123 Decl. of Higgins Prelim. Inj., supra note 121, ¶ 2.
124 Id.
29
In November 2016, Mr. Higgins received a habitation citation for living in his RV:
I was sitting on the couch in my RV reading a book when a police car parked directly behind my RV. I got out of my RV
and saw the officer writing a ticket. I
asked the officer why I was [getting] a
ticket and he said that I was ‘habitating.’
The officer did not explain how I was habitating. He just said that he could ticket
me at any time at any place. I asked the
officer what I could do to avoid a habitation ticket. The officer said that I could
avoid getting a habitation ticket by leaving San Diego. 125
In November 2017, the City cited Mr. Higgins
again, this time for nighttime RV parking. 126 Paying
the tickets was not easy. 127 Nonetheless, he paid to
avoid impoundment. 128
Mr. Higgins is anxious about the City’s citation
system because the fees place significant burdens on
125 Id. ¶ 4 (emphasis added); Bloom v. City of San Diego, No.
3:17-cv-02324-AJB-NLS, 2018 WL 9539239, at *4 (S.D. Cal. Aug.
21, 2018) (stating Higgins was ticketed for a “benign and lawful”
matter when the officer ticketed him though Higgins “was legally
parked in his RV reading a book”).
Second Amended Class Action Complaint, supra note
122, ¶ 24.
126
127 Id.
128 Decl. of Higgins Summ. Adj., supra note 121, ¶ 4.
30
him. 129 The threat of more citations and potential RV
impoundment exacerbates his poor health. 130 When
Mr. Higgins expressed these concerns to police officers, they told him that if he did not like the citations,
he should leave San Diego. 131
2. Emilio Rodriguez – Police Target Marine
Veteran, Suggest Leaving City, and Throw
Irreplaceable Property Into Irrigation Canal
Emilio Rodriguez is a 54-year-old Marine vetHe has been homeless for at least three
133
years.
Mr. Rodriguez does construction work and
painting when he can find the work, “but it is not
enough to be able to pay rent on an apartment.” 134 He
and a couple of other unhoused people received
eran. 132
129 Second Amended Class Action Complaint, supra note 122,
¶ 24.
130 Id.
131 Id. (emphasis added). The District Court enjoined enforce-
ment of the Vehicle Habitation Ordinance (San Diego Municipal
Code section 86.0137(f)). The ordinance violated plaintiffs’ constitutional rights. Bloom v. City of San Diego, No. 3:17-cv-02324AJB-DEB, 2018 WL 9539239, at *8 (S.D. Cal. Aug. 21, 2018). The
court granted preliminary approval of parties’ proposed class action settlement. Bloom, No. 3:17-cv-02324-AJB-DEB, 2024 WL
1162103 (S.D. Cal. Mar. 18, 2024).
132 Declaration of Emilio Moses Rodriguez ¶2, Kincaid v. City
of Fresno, No. 1:06-cv-01445-LJO-SKO (E.D. Cal. Nov. 6, 2006),
Doc. No. 54 [hereinafter Decl. of Rodriguez]; Kincaid v. City of
Fresno, No. 1:06-cv-1445 OWW SMS, 2006 WL 3542732, at *11
(E.D. Cal. Dec. 8, 2006).
133 Decl. of Rodriguez, supra note 132, ¶ 2.
134 Id. ¶ 2.
31
permission from a church to stay outside of its fence
line, near an irrigation canal. 135 Mr. Rodriguez remarks, “They referred to it as providing us sanctuary.
They just told us to keep our area clean, which we
did.” 136
Mr. Rodriguez had an encounter with police
that set him on a path towards escalating criminalization:
I had a run-in with two Fresno police officers, Officers Lee and Montoya, who patrol the area where I live. While I was
waiting outside a Chinese restaurant for
it to open for lunch, they came up and issued me a ticket for loitering . . . . Then
they asked me where I was staying. . . .
They told me “we don’t like you people”
and dismissed the idea that the church
could allow us to live where we were. 137
When Mr. Rodriguez returned to the church, his
neighbors living in nearby tents informed him the police came by after learning where he lives. 138 The police pushed Mr. Rodriguez’s shopping cart filled with
his belongings into a surging canal. 139 The Court describes the incident:
135 Id. ¶ 3.
136 Id.
137 Id. ¶ 4.
138 Id. ¶ 5.
139 Kincaid v. City of Fresno, No. 1:06-cv-1445 OWW SMS,
2006 WL 3542732, at *11 (E.D. Cal. Dec. 8, 2006).
32
Around the end of June 2006, a Fresno
police officer destroyed Ms. Nelson’s and
Mr. Rodriguez’s property, which Ms. Nelson was watching, by pushing their shopping carts packed with their belongings
into an irrigation canal of rushing water.
There was no prior notice of this seizure
and destruction. . . . Mr. Rodriguez lost
his cart containing his stereo, clothing,
bedding, toiletries and his prized photo
album containing pictures of him as a
young man in the Marine Corps, his children and grandsons. 140
Mr. Rodriguez commented, “Almost all of my possessions had washed away. . . .” 141
140 Id.
141 Decl. of Rodriguez, supra note 132, ¶ 6. The District Court
approved two settlement agreements in this case. Final Order
Approving Settlement, Kincaid, 1:06-cv-1445-OWW-SMS (E.D.
Cal. July 25, 2008), Doc. No. 323; Memorandum in Support of
Motion for Preliminary Approval of Settlement, Kincaid, No.
1:06-cv-1445-LJO-SKO (E.D. Cal. June 5, 2008), Doc. No. 304.
33
C. Sweeps Make Accessing Services Such as
Housing More Difficult
1. Ken – Homeless Veteran Has His Social Security Card, DD-214, Birth Certificate, and
ID Destroyed in Sweep, Leading to Loss of
Access to Shelter Space
After Ken concluded his service in the Air Force,
he settled in San Diego. 142 He became homeless after
losing his fishing boat, which he had operated for
work. 143
One sweep had disastrous effects on Ken and
his ability to find shelter and permanent housing.
While he was filling out forms at the Alpha Project to
get a bed at a shelter, the City “came and yanked
[Ken’s] stuff.” 144 He lost his birth certificate, identification documents, DD-214, and Social Security
card. 145 Without these documents, Ken reported he
was unable to get a bed at the Alpha Project shelter
and remained unsheltered. 146 He described how difficult it would be to get back on his feet, saying “it’s really not easy to overcome all the obstacles that are put
in place to get a home again.” 147
142 Invisible People, supra note 59, at 00:00:22–00:00:57,
00:09:42–00:09:46.
143 Id. at 00:00:40–00:01:27.
144 Id. at 00:05:44–00:05:45.
145 Id. at 00:05:40–00:06:58.
146 Id. at 00:05:27–00:06:25.
147 Id. at 00:01:38–00:01:48.
34
2. Jerry Roderick Burton—Police Take Documents Necessary to Appeal VA Disability
Decision—and Thomas Peterson—Police
Take Medals and Other Property from
Wheelchair-Using Army Veteran—Both
Veteran Subjected to Enforcement Actions
in Sub-Freezing Temperatures
Jerry Roderick Burton is a 54-year-old disabled
Marine Corps veteran. 148 He served in the Marines for
two and a half years at Camp Lejeune, North Carolina
and Guantanamo Bay, Cuba, before receiving an honorable discharge. 149 He has lived in the Denver area
for 26 years. 150 Mr. Burton grapples with a degenerative bone disease. 151 He does not receive a pension or
disability, “in part due to [homelessness] . . . and not
be[ing] able to maintain my records to appeal to the
VA.” 152 He has tried to work and attain housing, but
his disabilities and high rent prices make it “impossible.” 153
148 Declaration of Jerry Roderick Burton ¶ 2, Lyall v. City of
Denver, No. 1:16-cv-02155-WJM-CBS (D. Colo. Sept. 9, 2016),
Doc. No. 15-8 [hereinafter Decl. of Burton]. Mr. Burton was terminated as a plaintiff on April 11, 2017. Stipulation for Dismissal
with Prejudice, Lyall, No. 1:16-cv-02155-WJM-SKC (D. Colo.
Apr. 11, 2017), Doc. No. 103.
149 Decl. of Burton, supra note 148, ¶ 2.
150 Id.
151 Id.
152 Id. ¶ 3.
153 Id.
35
Despite his disabilities and service to this country, Mr. Burton is told to leave places where he is resting or staying:
The police are always telling me to move
along. I can’t go anywhere without them
hassling me. I ask them where I can go,
and they say go down to the Platte River.
Then they come down to the Platte River
and tell me to move. Whenever I try to
rest, the Denver Police Department
comes down on me hard. They always tell
me:“‘if you people would just leave Denver, then this would all stop.” I have lived
here 26 years. I have a son here and a
daughter. This is my home. 154
Mr. Burton explains how the constant movealong orders exacerbates his skeletal condition:
I have been woken up again and again by
Denver police shining their spotlights in
my face, ordering me to get up and move.
. . . I am a United States Military veteran
and suffer from degenerative bone disease so moving is extremely painful for
me. Especially in the morning when my
body is locked up and frozen and every
move I make makes me want to die with
154 Id. ¶ 4 (emphasis added).
36
pain. . . . Getting woken up every night is
a nightmare. 155
He expresses concern his “body is beginning to break
down faster than it should” from the police attention. 156
Beyond move-along orders, Mr. Burton has
been the victim of several police enforcement actions.
He described one 2016 sweep:
Around 8:30[A.M.] an officer from the Denver
Police Department came up to me and . . .
started telling me I had to leave. I asked him
why I had to leave as I wasn’t breaking any laws
and he responded by calling me a “bitch” and . .
. threatened [me] with arrest by saying: “I will
have your black ass in the back of my [squad]
car.”” 157
Police returned soon thereafter and began confiscating all of Mr. Burton’s property he used to survive on the streets. 158
Declaration of Jerry Burton in Support of Motion in
Limine for Order Suspending Camping Ban Enforcement During
Trial ¶¶ 2–3, 5, Lyall v. City of Denver, No. 1:16-cv-02155-WJMSKC (D. Colo. Feb. 4, 2019), Doc. No. 201-1 [hereinafter Burton
Limine]. The court denied the plaintiffs’ motion, Lyall, No. 1:16cv-02155-WJM-SKC, 2019 WL 9443748, at *3 (D. Colo. Feb. 21,
2019).
155
156 Burton Limine, supra note 155, ¶ 6.
157 Decl. of Burton, supra note 148, ¶ 5.
158 Id. ¶ 6.
37
Mr. Burton witnessed dehumanizing sweeps
where people were treated without regard for their
health or safety:
I was also there December 15, 2015, 159
where there was snow on the ground and
it was less than ten degrees and they
forced everyone to march out into the
snow. I tried to explain to the police that
we were human beings and had rights. It
meant nothing to them that we were
freezing like dogs. They wouldn’t give us
any help. There were two pregnant
women there. They took their stuff,
too. 160
Thomas Peterson is a 45-year old disabled Army
veteran living in Denver, Colorado. 161 Mr. Peterson
has many physical disabilities—a prosthetic right hip,
permanently “disabled jaw line,” and chronic pain—all
stemming from a hit and run “where [he] was run
159 The court indicated this event, while not factually refuted,
was not a relevant issue for the case because it did not meet the
definition of a “mass sweep,” as defined in the class certification.
Order on Motions Regarding Dates and Incidents That May Be
Explored at Trial at 4, Lyall v. City of Denver, No. 1:16-cv-02155WJM-SKC (D. Colo. Oct. 5, 2018), Doc. No. 190.
160 Decl. of Burton, supra note 148, ¶ 7. Veteran Thomas Pe-
terson described “half a foot of snow on the ground.” Declaration of Thomas Peterson ¶ 4, Lyall v. City of Denver, No. 1:16-cv02155-WJM-CBS (D. Colo. Sept. 9, 2016), Doc. No. 15-10 [hereinafter Decl. of Peterson].
161 Decl. of Peterson, supra note 160, ¶¶ 1–2, 4, Lyall v. City
of Denver, No. 1:16-cv-02155-WJM-CBS (D. Colo. Sept. 9, 2016),
Doc. No. 15-10.
38
over.” 162 Mr. Peterson relies on a wheelchair. 163 He describes the repeated police interactions—even when
resting in the shade to avoid 103-degree heat or waiting to enter a shelter—as a form of “constant harassment.” 164
In addition to the physical toll, he experiences
indignities during enforcement actions:
•
On October 24, 2016, the DPD confiscated Mr.
Peterson’s “wheelchair, his military records,
his identification and photographs of his family.” 165 He was forced to stand as the City confiscated and destroyed his possessions. 166
•
During the December 15, 2015 enforcement action, “police told us to go to shelters, but . . .
there is almost no room [or] space in Denver
day shelters, so that we had to stay outside
freezing trying to survive.” 167
As Mr. Peterson poignantly noted: “I served out
of a duty to protect our freedoms and our rights,
but . . . when it comes to the poor and homeless, there
162 Id. ¶ 2.
163 Second Amended Complaint ¶ 61, Lyall v. City of Denver,
No. 1:16-cv-02155-WJM-SKC (D. Colo. Feb. 1, 2017), Doc. No. 691.
164 Decl. of Peterson, supra note 160, ¶ 3.
165 Second Amended Complaint, supra note 163, ¶¶ 50, 61.
166 Id. ¶ 61.
167 Decl. of Peterson, supra note 160, ¶ 4.
39
ain’t no rights. . . . I didn’t [serve] to watch something
like this happen in America.” 168
***
This brief demonstrates that criminalization,
sweeps, and property confiscation make the situations
of unhoused veterans exponentially worse and undermine the national commitment to ending veteran
homelessness. Part I provides the structural, bureaucratic, and individual risks for veteran homelessness.
The stories in Part II show the lived realities for unhoused veterans.
CONCLUSION
This Court should affirm the Ninth Circuit.
Respectfully submitted,
SUNITA PATEL
JEANNE NISHIMOTO
VETERANS LEGAL CLINIC
UCLA SCHOOL OF LAW
907 Westwood Blvd. #444
Los Angeles, CA 90024
(310) 268-3837
patel@law.ucla.edu
April 3, 2024
DAVID VENDERBUSH
Counsel of Record
ALSTON & BIRD LLP
90 Park Avenue
New York, NY 10016-1387
(212) 210-9532
david.venderbush@alston.com
Counsel for Amici Curiae
168 Id. ¶ 4. The parties reached a settlement, which was ap-
proved by the District Court. Lyall v. City of Denver, No. 1:16-cv02155-WJM-SKC (D. Colo. Sept. 23, 2019), Doc. No. 226.
APPENDIX
1a
APPENDIX
LIST OF 45 AMICI CURIAE WHO
PROVIDE SERVICES TO VETERANS
National Coalition for Homeless Veterans
UCLA School of Law Veterans Legal Clinic
U.S. VETS
Service Women’s Action Network
Black Veterans Project
Minority Veterans of America
Iraq and Afghanistan Veterans of America
Women Veterans Interactive Foundation
National Law School Veterans Clinic Consortium
Cape and Island's Veterans Outreach Center
Project Love Coalition
Orange Tent Project
Cornell Law Veterans Law Practicum
Betty and Michael D. Wohl Veterans Legal Clinic at
Syracuse University College of Law
2a
Swords to Plowshares
Connecticut Veterans Legal Center
Community Hope
Texas A&M School of Law Family and Veterans
Advocacy Clinic
Minnesota Assistance Council for Veterans
Operation Dignity
Veterans Northeast Outreach Center, Inc.
New Visions Homeless Services
Soldiers' Angels
Helping Veterans And Families
Vets First Life Management
Albany Housing Coalition Inc.
American GI Forum-National Veterans Outreach
Program
Southwestern Oregon Veterans Outreach
Veterans Legal Institute
Michigan Veterans Foundation
3a
Veterans Strong Community Center
Veterans Integration Center
Black Veterans For Social Justice, Inc.
Access Housing Inc. District of Columbia
The Veterans Advocacy Law Clinic at the University
of Arizona James E. Rogers College of Law
Emmanuel House
The Community Veteran Justice Project
Nation’s Finest
Lady Veterans Connect
Family & Community Services, Inc.
Dixon Center for Military and Veterans' Services
Veteran Housing Corp
Services for the Underserved
University of Illinois College of Law Veteran’s Legal
Clinic
University of Detroit Mercy Veterans Law Clinic
Public Counsel’s Center for Veteran Advancement
4a
Jewish War Veterans of the United States of
America, Inc.
This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.