News on fighting camping ban

Peace be with you

Last Friday Tracy Herrin filed a Motion to Dismiss in the case of Aaron Peoples. I don’t have any means to show you the motion as it is, but have copied the text of the filing below.

I know many people out there are grateful to Tracy for all her hard, pro bono, work on behalf of the houseless. Though most of the gratitude comes from the houseless, who have had it way too fucking hard for way too long, but they are appreciative none the less. I wish to thank Tracy publicly on behalf of all those who have been denied sleep in our communities.

And without further ado:


Enforcement against houseless individuals, at all times and in all places within the City of Eureka, of an ordinance criminalizing sleeping activities in public, violates the U.S. Constitution’s Eighth Amendment’s prohibition against cruel and unusual punishment.1 The City of Eureka’s camping ban expressly criminalizes the status of houselessness by criminalizing acts that are an integral aspect of that status, thereby violating the Eighth Amendment.

Eureka Municipal Code (EMC) section 93.02 specifically prohibits sleeping “in any public or private space or public or private street, except in areas specifically designated for such use.” Because houseless persons who are houseless involuntarily have no access to private spaces, they can only perform those acts which are unavoidable necessities in public.

Over forty years ago, the United States Supreme Court analyzed two separate and independent statutes and applied the Eighth Amendment to each. In Robinson v. California (1962) 370 U.S. 660, 666-667, the Court announced limits on what the state may criminalize consistent with the Eight Amendment. At a minimum, Robinson established that criminalization of “being” inflicts a cruel and unusual punishment.

In Powell v. Texas (1968) 392 U.S. 514, 551, five justices agreed that the state cannot impose punishment for certain conditions, whether the conditions are acquired involuntarily or arising from the individual’s own conduct. Justice White, concurring in the judgment, established that “the proper subject of inquiry is whether volitional acts [sufficiently proximate to the condition] brought about the criminalized conduct or condition.” Id. at 550 n.2.

For a human, sleeping is a physiological need. Resisting sleep (at all times) is impossible. In re Eichorn (1998) 69 Cal.App.4th 382, 389-390 (stating, in pertinent part, that “[s]leep is a physiological need, not an option for humans. It is common knowledge that loss of sleep produces a host of physical and mental problems (mood irritability, energy drain and low motivation, slow reaction time, inability to concentrate and process information). Certainly, no one would suggest that a groggy truck driver who stops his rig on the side of a road rather than risk falling asleep at the wheel does not act to prevent a significant evil, i.e., harm to himself and others. Indeed, Judge Margines had denied Eichorn’s request for funds to hire an expert to testify about the harmful effects of sleep loss: “I mean it doesn’t take an expert to tell us that, to convince a person, that there are ill effects that arise from sleep [deprivation].”)

For a houseless human (or any human without shelter), avoiding private and public spaces is also impossible. In the case now before the Court, it has been demonstrated that the number of houseless persons in the City of Eureka far exceeds the number of available shelter beds at all times. The City of Eureka has a substantial shortage of shelter, especially as offered to a non-Christian single man. And violations of EMC §93.02 are only cited to houseless persons.

Mr. Aaron Peoples (hereinafter “Aaron”) cannot be punished for sleeping in a public space because his status as houseless is involuntary and because he cannot reasonably be expected by the City of Eureka to refrain from sleeping at all times and in all spaces. The conduct at issue here (sleeping at night-time) is involuntary and as such, is inseparable from status (houselessness); they are one and the same because biologically, humans must sleep.

A District Court in Florida held that the Eighth Amendment right and due process rights are violated when homeless persons are arrested for harmless, involuntary conduct. Pottinger v. City of Miami, 810 F. Supp. 1551. In that matter, the plaintiffs were a class of 6,000 homeless individuals residing in Miami who alleged that the City’s sleeping and bathing arrests (and destruction of property) violated their rights under the Eighth Amendment. Of particular interest as to the matter now before this Court, the record in Pottinger established that being homeless is rarely a choice, and that the homeless plaintiffs lacked any place where they could lawfully be, and that living in public places because of the unavailability of low-income housing or alternative shelter could not realistically be viewed as a choice.

By enforcing EMC §93.02 at all times and in all private and public spaces against humans with no other place to sleep, other than in public spaces, the City of Eureka criminalizes the status of houselessness in violation of the Eighth and Fourteenth Amendments to the U.S. Constitution.2

Just as the Eighth Amendment prohibits criminal punishment for being a drug addict (Robinson, supra at 667) and/or for some unavoidable consequence of being a chronic alcoholic without a house (Powell, supra at 551), it also prohibits infliction of criminal punishment by the City of Eureka upon an individual involuntarily sleeping in public spaces as an “unavoidable consequence” of being human and houseless in the City of Eureka.

In Joyce v. City and County of San Francisco (1994) 846 F.Supp. 843, the court declined to find a San Francisco ordinance unconstitutional where houseless plaintiffs alleged that certain aspects of a comprehensive houseless program of San Francisco violated their Eight Amendment rights. Joyce is inapplicable in the matter now before this Court because unlike in Aaron’s case: 1) the ordinance examined by the Joyce court penalized conduct, not status; 2) the Joyce record failed to make the necessary evidentiary showing of a substantial disparity between the number of houseless individuals and the number of shelter beds available on any given night; and 3) the relief sought (by houseless civil plaintiffs) in Joyce would have enveloped punishable (because it was voluntary) conduct as well as involuntary conduct.

Based upon these significant factual differences, Aaron asserts that this Court must analyze: 1) Status-based punishment (Robinson and Powell) as applied to Aaron (and other homeless individuals); 2) Aaron’s clear and convincing evidence regarding the substantial disparity between the number of houseless individuals and the number of shelter beds available in the City of Eureka; and 3) The limited relief sought by Aaron in this case.

Similarly, Tobe, et. al. v. City of Santa Ana (1995) 9 Cal. 4th 1069 does not apply. The Tobe court was faced with a facial challenge to a statute, and found that Santa Ana’s camping ban withstood constitutional scrutiny. Here, Aaron is asking this Court to determine the cruel and unusual nature of punishment as applied to himself and as applied to individuals merely for their status as houseless.

Also, the Santa Ana statute examined by the Tobe court defined camp as “to pitch or occupy camp facilities (defined as tents, huts, or temporary shelters); to use camp paraphernalia (defined as tarpaulins, cots, beds, sleeping bags, hammocks or non-city designated cooking facilities and similar equipment.”) The Tobe statute was upheld because it prohibits conduct rather than criminalize the status of homelessness.

EMC 93.02 is not akin to the Tobe statute because it is a strict prohibition on sleeping. The Santa Ana camping ordinance is more akin to restrictive statutes of at least seven separate and independent cities’ camping ordinances – each narrowly tailored to criminalize conduct, not status.

Las Vegas’ statute, written in 2005, prohibits standing or lying in a public way only when it obstructs pedestrian or vehicular traffic. Portland’s statute, written in 2006, prohibits obstruction of public sidewalks. Seattle’s, Tuscon’s, and Houston’s statutes limit the hours of enforcement as a safe harbor. Philadelphia’s, Reno’s and Seattle’s statutes restrict the geography of enforcement as a safe harbor. (Las Vegas, Nevada Municipal Code § 10.47.020 (2005); Portland, Oregon Municipal Code §§ 14A.50.020, 14A.50.030 (2005); Seattle, Washington Municipal Code § 15.48.040 (2005); Tuscon, Arizona Municipal Code §11-36.2(a) (2005); Houston, Texas Municipal Code § 40-352(a) (2006); Philadelphia, Pennsylvania Municipal Code §§ 10-611(1)(b)-(c), 10-611(2)(g)-(h) (2005); Reno, Nevada Municipal Code § 8.12.015(b) (2005).

After prohibiting camping in any public or private space or street (except in designated areas undefined by statute and unknown to law enforcement), EMC 93.02 defines camp as “residing in or using [any] space for living accommodation purposes, such as sleeping activities, or …” The phrase “such as sleeping activities” means that sleeping activities alone qualify as “using [a] space for living accommodation purposes;” without any other conduct in combination, the statute can be violated when an individual is sleeping and doing nothing else.

We anticipate that the People will assert that EMC 93.02’s language lists sleeping as one of various indications of an intent to use the public space as a living accommodation, and/or that the statute is clear that more than sleeping is necessary to show a violation. But because Eureka’s camping ban prohibits “sleeping activities” in any public or private space, its enforcement may rely upon sleeping as a single indication of violation – regardless of any other conduct which also meets the definition.

To illustrate this point:
Sleeping, sitting or lying + Some additional conduct = Constitutional Ordinance

Sleeping, sitting, or lying = Unconstitutional Ordinance
___________ (Criminalizes Status)_________

Therefore, Defendant asserts that EMC 93.02:

Sleeping [or other activity] = Unconstitutional Ordinance (Criminalizes Status)


Because the antisleeping ordinance uses the word “or” after its use of the term “sleeping activities,” “sleeping activities” is one of multiple examples – rather than one of various indications – of conduct which means “using [a] space for living accommodation.”

In our case, Aaron asserts that so long as there exists a “chronic and severe gap between the number of homeless individuals and the number of available beds in the city,” the city should not be permitted to enforce a strict prohibition on sleeping where the effect of enforcement is criminalization of status (houseless). Such enforcement violates the Eight Amendment.


The right to travel is a fundamental right3, protected by the United States Constitution.4 Intrastate and interstate migration within the United States are both long-recognized constitutional protections; potential textual sources of the right to travel include the first amendment, the privileges and immunities clause of Article IV, the privileges and immunities clause of the fourteenth amendment, the commerce clause, the due process clause, and the equal protection clause.

The right earned judicial recognition in 1823 and was formally noted by the United States Supreme Court in 1849. Corfield v. Coryell (1823) 6 F.Cas. 546, 552 and Smith v. Turner (1849) 48 U.S. 282, 491-492. The Supreme Court applied an equal protection analysis of the fourteenth amendment in 1969, finding the right to travel a fundamental right and holding that any penalizing classification of exercise of the right to travel is “unconstitutional unless shown to be necessary to serve a compelling state interest.” Shapiro v. Thompson (1969) 394 U.S. 618, 627. Other cases have found the right to travel based upon application of the due process clause. See Sosna v. Iowa (1974) 419 U.S. 393, 406-409 (application of a balancing test weighing the individual right to travel against the state interest involved).

A. Burdens on the fundamental right to travel.

An ordinance which burdens a fundamental right is constitutional only if it is found necessary to serve a compelling state interest. Shapiro, supra at 627. Essentially, courts have established four methods by which an ordinance burdens travel: 1) erecting an actual barrier to travel (Edwards v. California (1941) 314 U.S. 160, 177-186); 2) intending to deter travel (Zobel v. Williams (1982) 457 U.S. 55, 62 n.9); 3) indirectly penalizing travel (Shapiro, supra at 634); and 4) actually deterring travel (Memorial Hospital v. Maricopa County (1974) 415 U.S. 250, 257-258).

Specifically applied to anti-sleeping ordinances, the right to travel is unconstitutionally burdened where: 1) the anti-sleeping ordinance erects a direct barrier to travel; 2) the primary objective of the anti-sleeping ordinance is to impede travel; and/or 3) an anti-sleeping ordinance penalizes migration.

B. Eureka Municipal Code section 93.02 erects a direct barrier to travel.

The City of Eureka is a jurisdiction where no available shelter exists for a non-Christian, houseless, single man (and arguably very little shelter available for others); as such, the City of Eureka’s anti-sleeping ordinance prohibiting overnight sleeping in all public (and private) spaces burdens the fundamental right to travel because its primary effect and objective is to ban in-migration of houseless people and/or to force out those houseless people already in the City of Eureka.

On the nights he was cited for violation of EMC §93.02, Aaron was faced with a choice between two equally-repugnant options: to exclude himself from the City of Eureka or to face arrest and prosecution for violation of Eureka’s anti-sleeping ordinance. Aaron violates EMC §93.02 each time he succumbs to his need for sleep; the ordinance prevents Aaron from exercising his right to travel to Eureka for longer than he can physically stay awake. In this regard, EMC §93.02 erects a direct barrier to travel, and therefore is an unconstitutional burden.

C. The primary objective of Eureka Municipal Code section 93.02 is to impede travel.

EMC §93.02 burdens travel unconstitutionally because it primarily seeks to discourage houseless individuals from moving into or remaining in the City of Eureka. As applied to a zoning ordinance, one court has found that the right to travel is violated by “any and all features of [a zoning] plan which, directly or indirectly, seek to control” migration. Construction Industry Association v. City of Petaluma (1974) 375 F.Supp. 574, 581. That court held that the zoning ordinance examined had a “primary purpose … to prevent the entrance of newcomers in order to avoid future burdens, economic or otherwise … cannot be held valid … It is not for any given township to say who may or may not live within its confines … ” Id. at 585-586.

As applied to Aaron’s matter, any feature of EMC §93.02 which seeks to control migration should require this Court to declare the ordinance an unconstitutional burden on Aaron’s right to travel, and therefore an unconstitutional burden as applied to houseless individuals’ right to travel. The City of Eureka cannot demonstrate that EMC §93.02 is enforced against any individual other than transient and/or houseless individuals. In criminalizing sleeping in public spaces without restriction as to time, place, or any other factor, EMC §93.02 seeks to control the migration of involuntarily houseless individuals, who need to sleep in public spaces.

The city of Eureka cannot demonstrate that EMC §93.02 is enforced against any individual other than transient/houseless individuals, but we continue to invite the City to demonstrate that its antisleeping ordinance is enforced against anyone who is not houseless and/or transient. In criminalizing sleeping in public spaces without restriction as to time, place, or any other factor, EMC §93.02 seeks to control the migration of involuntarily houseless individuals, who need to sleep in public places.
Because it is only enforced as against houseless individuals, this Court can infer evidence of the purpose of Eureka’s anti-sleeping ordinance from the overwhelmingly disproportionate effect it has on the houseless. Also, EMC §93.02 effectively evicts the houseless by criminalizing conduct vital to human survival. Aaron must sleep outdoors or not at all. EMC §93.02 fails to account for Aaron’s involuntary condition.

D. Eureka Municipal Code section 93.02 penalizes migration.

Historically, courts have been more likely to find that the right to travel is implicated by a “penalty” when the migrant is deprived of a “necessity of life,” such as welfare for indigents (Shapiro, supra at 634) and free non-emergency medical care (Memorial Hospital, supra at 259). Sleep is arguably of greater necessity to life than either welfare or non-emergency medical care, and anti-sleeping ordinances such as EMC §93.02 create the same concerns as deprivation of welfare or medical care. Sleep for the weary “involves the immediate and pressing need for preservation of life and health. Eggert, supra at 802. And a criminal sanction is arguably more strictly penalizing than deprivation of a government benefit.

In Aaron’s case specifically, EMC §93.02 has had the practical effect of penalizing Aaron’s migration to the City of Eureka. The underlying fact that Eureka cannot demonstrate that it enforces its anti-sleeping ordinance against any individual who is not houseless or transient demonstrate its penalizing nature upon migration.

E. Notions of Liberty

The United States Supreme Court has stated that, “the right to travel includes the right to migrate, resettle, find a new job, and start a new life. Shapiro, supra at 629; Memorial Hospital, supra at 255. According to one Constitutional Law treatise, “just as a government should not be allowed to imprison those dissatisfied with the status quo, it should not be allowed to expel those who have become a burden or a source of friction or unrest. L. Tribe, American Constitutional Law §15-14, at 1382 (1988).
For the above reasons, a showing of purpose and direct negative effects upon Aaron – and other houseless individuals sleeping in Eureka – meets the evidentiary standard for this Court to find that Eureka’s anti-sleeping ordinance unconstitutionally burdens Aaron’s fundamental right to travel.

G. Eureka Municipal Code Section 93.02 Violates Equal Protection.

A “strict scrutiny” analysis is applied under the Equal Protection Doctrine. Cleburne v. Cleburne Living Center (1985) 473 U.S. 432, 440. The right to travel is a fundamental right; as such, ordinances burdening the right are subject to the strict scrutiny analysis – the burden on travel must be outweighed by a compelling state interest. Additionally, the court must find that the ordinance is necessary to serve the stated interest.

In a prior case, the City of Eureka has claimed the underlying purpose of EMC §93.02 is to address “numerous serious health and safety issues and problems that arise in correlation with illegal camping … those problems include: fire hazards, human excrement and other waste and garbage issues, vector issues, drugs, violence, theft, damage to public and private property, and related problems.”

Though addressing the above-proposed health and safety issues and problems may be deemed compelling, banning outdoor sleeping is not necessary to achieve this interest.
Sleeping persons pose no criminal danger. Poverty and immorality are not synonymous. Edwards, supra at 177. The City of Eureka implies that Aaron was contributing to the City of Eureka’s health and safety concerns, beyond his conduct of merely sleeping in a public space.

Also, the City of Eureka has other methods of addressing its health and safety concerns. Indeed, the penal code establishes a statutory framework for addressing fire hazards, drugs, violence, theft, and damage to public and private property. Other sections of the EMC can be enforced as to human excrement, waste and garbage issues. Even if, for the sake of argument, this Court found that the City’s health and safety concerns are a “compelling” interest, it tortures logic to reasonably state that the anti-sleeping ordinance is necessary to address those concerns.

The Constitution prohibits “attempts on the part of any single State to isolate itself from difficulties common to all.” Id. at 173. Prohibiting the migration of needy persons into a jurisdiction is not a permissible state interest (Shapiro, supra at 629), regardless of the financial health of the jurisdiction (Memorial Hospital, supra at 263).


At least one court has struck down an antisleeping ordinance as unconstitutionally vague and overbroad. State v. Penley (1973) 276 So. 2d 180, 181. The ordinance in the Penley matter prohibited sleeping upon or in any street, park, wharf, or other public place.

The California Supreme Court struck down an ordinance prohibiting lying on public lawns, applying an Equal Protection rational basis analysis; though the ordinance was found to be facially neutral, its stated purpose was to protect public property from “hippies.” Parr v. Municipal Court (1971) 3 Cal.3d 861, 864.

Both the Parr Court and the Penley court’s analyses interpreted the U.S. Constitution, rather than their own state’s constitution.

Municipalities have historically evicted transients or houseless individuals by criminalizing vagrancy and/or loitering. On both issues, the United States Supreme Court has examined the language of the conduct prohibited by the ordinance(s), and has found that the ordinance(s) envelop lawful conduct, and therefore, each was found to be unconstitutionally vague.

Papachristou v. City of Jacksonville (1973) 405 U.S. 156 involved the Court’s analysis of permissive police powers, and determined that the New York vagrancy ordinance exceeded permissible police powers by allowing punishment for the status of “vagrant.”

When vagrancy ordinances failed to withstand constitutional scrutiny, municipalities turned to loitering laws in a fresh attempt to rid themselves of houseless individuals. The U.S. Supreme Court found loitering laws, as well, to be unconstitutionally vague.
In describing the vagueness of the ordinance in Kolender v. Lawson (1983) 461 U.S. 352, the Court found that statutes could not require loiterers to present identification to a peace officer; in Shuttlesworth v. Birmingham (1965) 382 U.S. 87, 90, the Court indicated that the ordinance was unconstitutionally vague because it allowed a person to loiter on a public street or sidewalk “only at the whim of any police officer…”
Statutes prohibiting loitering which are specifically limited in their scope by time and/or place have been more regularly upheld as constitutional. See e.g. United States v. Cassignol (1970) 420 F.2d 868.

Similarly, EMC § 93.02 is unconstitutionally vague because it allows sleeping in public “only at the whim of any police officer.” And, Eureka’s antisleeping statute is not restricted by time of space or geography.

Likewise, vagrancy, loitering and antisleeping statutes are unconstitutionally overbroad because each ordinance inevitably must rest upon an assumption that folks who sleep outdoors are responsible for an increase in crime.

Even if the City of Eureka could demonstrate that Aaron specifically (and/or homeless individuals in general) are more prone than the general population to criminal activity, the City has alternative and less restrictive methods to meet its concern regarding increase in crime – existing criminal statutes and other municipal ordinances address any identifiable permissive purpose.

As discussed above (as to cruel and unusual punishment), several cities have enacted ordinances which have been upheld as lawful where they prohibit sleeping but limit the ordinance’s application to specific times (certain times as a safe harbor), places (certain spaces only are prohibited), and/or manner (can sleep but not if it obstructs traffic). (Las Vegas, Nevada Municipal Code § 10.47.020 (2005); Portland, Oregon Municipal Code §§ 14A.50.020, 14A.50.030 (2005); Seattle, Washington Municipal Code § 15.48.040 (2005); Tuscon, Arizona Municipal Code §11-36.2(a) (2005); Houston, Texas Municipal Code § 40-352(a) (2006); Philadelphia, Pennsylvania Municipal Code §§ 10-611(1)(b)-(c), 10-611(2)(g)-(h) (2005); Reno, Nevada Municipal Code § 8.12.015(b) (2005)).

But Eureka’s sleeping ordinance does not reflect any such restriction as to time, place, or manner. It prohibits other things as well, but its strict prohibition upon “sleeping activities” must be viewed – as a matter of law – as unconstitutionally overbroad.


120 years ago, the United States Supreme Court held that when a case is dismissed on constitutional grounds, dismissal is a bar to further prosecution for that offense. Yick Wo v. Hopkins (1886) 118 U.S. 356.

As applied to houseless individuals, EMC §93.02 is unconstitutional. If this Court finds that Eureka’s antisleeping ordinance is unconstitutional by any of the above three arguments – cruel and unusual punishment, burden upon the right to travel, and/or vague and overbroad, than this Court should issue a declaratory judgment stating its grounds, and should prohibit the City of Eureka from continuing to enforce the ordinance, at least at certain times, places and/or in a certain manner.

DATED: March ____, 2009
Respectfully Submitted,

Attorney for Defendant


8 Responses to “News on fighting camping ban”

  1. SoHumNoob Says:

    Pardon my crude language but where the fuck are all the “Christians” in this?

    Have God’s so called people lost their damn minds?

    All caught up in the great apostasy I suspect.

    Seems to me they all run around with WWJD (what would Jesus do) bracelets and then do nothing because they have no clue what Jesus would do.

    Well Jesus would let the sleepy sleep and would feed the hungry.
    Just how afraid of the homeless are you guys?

    If I owned a home in Humboldt all the houseless could stay at my house as guest.
    Fill the house and the yard and wait for the pigs to show up.

    All you so called “Christians” that have made or allowed this ordnance (the not sleeping in public one) should be exposed as the uncaring, fearful, spineless “Christians” that you are.

    Jesus had no place to sleep either so I guess he would be arrested or harassed when he tried to sleep in public.

    Matthew 8:20 – And Jesus saith unto him, The foxes have holes, and the birds of the heaven [have] nests; but the Son of man hath not where to lay his head.




  2. SoHumNoob Says:

    “Hey Rockie watch me pull a rabbit out of my hat.”

    Lets call up the ACLU and get them to do what they are doing to Santa Barbara.

    Santa Barbara sued over public sleeping law
    The Associated Press

    2:52 p.m. March 6, 2009

    SANTA BARBARA, Calif. — The city is unfairly criminalizing homeless people by enforcing a ban on nighttime sleeping on public property, a civil rights group claimed in a lawsuit filed Friday.

    Santa Barbara’s “anti-sleeping ordinance” violates constitutional rights, according to the suit brought by the American Civil Liberties Union of Southern California. The ordinance makes it illegal for a person to sleep overnight on public property, including beaches.

    “By citing and arresting mentally ill or physically disabled homeless persons for sleeping in public places when there are no reasonable alternatives available to them, the city engages in arbitrary and unreasonable conduct,” said Mark Rosenbaum, legal director for the ACLU group. “The city and its law-enforcement personnel treat the chronically homeless as if they were outlaws.”

    City Attorney Stephen Wiley said the city rarely enforces the anti-sleeping ordinance and instead applies an anti-camping ordinance aimed at curbing homeless people erecting tents and having bonfires on the beach. He said there usually is enough room in various city shelters to accommodate people.

    “The legal merits are extremely far-fetched,” Wiley said of the suit. “Essentially they are saying there is a constitutional right to camp on a beach. We are pretty sure a judge isn’t going to see it that way.

    Wiley said Santa Barbara looks after its homeless population better than many cities in California and homeless people are virtually never arrested. Even if they do get a citation, the courts rarely follow up if they fail to pay, he said.

    The ACLU said 11 homeless people have died on Santa Barbara streets this year. The group is concerned about the fate of more than 100 homeless people living in a temporary shelter scheduled to close April 1.

    On Tuesday, the city of Laguna Beach repealed a ban on sleeping on the street in response to an ACLU lawsuit.

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  5. Tim Adams Says:

    Hello everyone! We are trying to get a national movement together called FREEDOM OF SLEEP. If you are involved or interested in causes like this please go to our facebook page and look for updates on our next national conference calls etc. Sleep is an NATURAL RIGHT, UNALIENABLE. Even if the founding fathers wrote the constitution just for themselves, they would have protected the right to sleep but they could never forsee an America where people are arrested for sleeping on the Earth. To make sleeping a crime is an attack on humanity and the natural law of the Universe.

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