We'll hear arguments first this morning in case 23175, City of Grant's Pass v. Johnson.

Ms. Evangelis?

Mr. Chief Justice, and may it please the Court, like cities nationwide, grants pass relies on camping laws to protect its public spaces.

These generally applicable laws prohibit specific conduct and are essential to public

health and safety. The Ninth Circuit tied cities' hands by constitutionalizing the policy

debate over how to address growing encampments. It's holding that the Eighth Amendment

bars grants pass from enforcing its

camping laws is wrong for three reasons. First, the cruel and unusual punishments clause

governs which punishments are permitted, not what conduct can be prohibited. Second, no precedent

supports the Ninth Circuit's rule.

Respondents in the United States abandon its reliance on Powell. Instead, they misread Robinson

to bar any punishment for involuntary conduct that's linked to a status. But Robinson

held only that states cannot outlaw the status of drug addiction.

It made clear that they can prohibit conduct like drug use.

This Court should not rewrite Robinson six decades later.

Third, the Ninth Circuit's approach has proven unworkable.

The Eighth Amendment does not tell courts who is involuntarily

homeless, what shelter is adequate, or what time, place, and manner regulations are allowed.

But in 35 suits and counting, federal courts are now deciding everything, from the exact size of campsites in San Rafael to the

adequacy of empty beds at specific shelters, like the Gospel Rescue Mission and Grants Pass,

and cities are struggling to apply arbitrary shifting standards in the field.

This Court should reverse and end the Ninth Circuit's failed experiment,

...