Orange County and its cities cannot enforce sit-lie or anti-camping ordinances against unsheltered residents when no shelter beds are available, under Martin v. Boise (9th Circuit 2018) and subsequent Ninth Circuit case law shaping county enforcement.
The Ninth Circuit's 2018 Martin v. Boise decision held that the Eighth Amendment prohibits enforcing public-camping or sit-lie laws against homeless individuals who lack access to shelter, an interpretation governing Orange County. The 2024 U.S. Supreme Court Grants Pass v. Johnson decision narrowed Martin but California voters and Governor Newsom retained shelter-based enforcement standards through executive policy. OC operates a Continuum of Care and shelters in Anaheim, Santa Ana, Tustin, and Costa Mesa to maintain enforcement availability. The county's flood-control beds (Bridges at Kraemer, Yale Navigation Center) figure into capacity calculations.
Issuing sit-lie or camping citations without verifying shelter capacity, sweeping encampments without notice, or using force can expose the county to ADA, due-process, and Section 1983 civil-rights claims.
See how other cities in Orange County handle sit-lie rules.
See how Fullerton's sit-lie rules rules stack up against other locations.
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