HomeMy WebLinkAbout2023-11-06 Study Sessionrqaixiiial,Cotn,,icil Study Sessiari Ageirlida
ASHLAND CITY COUNCIL
STUDY SESSION AGENDA
Tuesday, November 6,2023
Council Chambers, 1175 E Main Street
View on Channel 9 or Channels 180 and 181 (Charter Communications)
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Please submit your testimony no later than 10 a.m. the day of the meeting.
5:30 p.m. Study Session
1. Public Input (15 minutes - Public input or comment on City business not included on
the agenda)
2. Balancing Homelessness Services with Public Space Regulations for a More Livable City
3. Adjournment of Study Session
In compliance with the Americans with Disabilities Act, if you need special assistance to participate
in this meeting, please contact the City Manager's office at 541.488.6002 (TTY phone number
1.800.735.2900). Notification 72 hours prior to the meeting will enable the City to make reasonable
arrangements to ensure accessibility to the meeting (28 CFR 35.102-35.104 ADA Title 1).
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Over the past two decades, the legal landscape surrounding homelessness and transient populations inOregon
has evolved significantly. The City of Ashland has not been immune to these changes and has experienced a
substantial impact. Ashland's ordinances and law enforcement practices have continuously adopted to cope
with the growing influx of homeless individuals. However, recent federal and state laws have imposed additional
requirements on cities, necessitating specific adjustments to Ashland's longstanding laws and approach to
camping and public space occupation.
Over the last year and ohalf, the city has diligently worked toestablish alternative shelter spaces for homeless
individuals. As o result, the city is now Oto crucial juncture, poised to revise its prohibited camping ordinance.
This revision aims to effectively guide homeless individuals toward using the newly established shelter spaces
while ensuring legal compliance and addressing the broader issue of homelessness in our community.
This study session aims to provide the Council with an overview of recent case law and pertinent legislative
developments. In light of these updates, the legal department will present aseries ofproposed modifications to
our existing ordinances. These changes are designed to strike a balance between recognizing the unique
challenges faced by the homeless population and safeguarding the integrity of our public spaces.
Furthermore, this study session will introduce the concept ofon'AshlandLivability Team,'iDupired by successful
models in cities such as Medford and others. The primary objective of this proposed team is to approach the
issue of homelessness through a multifaceted strategy that combines enforcement measures with proactive
outreach efforts. The overarching goal is to enhance livability in our community while simultaneously providing
homeless individuals with opportunities to transition toward stable and independent living.
POLICIES, PLANS & GOALS SUPPORTED
Current city priorities encompass upholding effective code enforcement, promoting equity of access, and strong
supportive city services, and broadening social and economic opportunities for every member of our
BACKGROUND AND ADDITIONAL INFORMATION
Civil rights lawsuits filed in federal courts have contested the legality of camping prohibitions, resulting in
restrictions on the conventional enforcement of these measures. These legal challenges have invoked the 8th
Amendment, which safeguards individuals against cruel and unusual punishment. in a series of rulings, the
courts have maintained that itis essentially impermissible to penalize individuals for engaging in basic life
activities, such as sleeping, lying, or sitting, particularly when they are involuntarily homeless and lack alternative
locations toconduct these essential daily functions, You can find an in-depth explanation of the developing
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case law inthis field on homelessness, provided by the League ofOregon Cities. Oregon's legislature has
anticipated the need for comprehensive protections for homeless individuals on public property. This has led to
the passage of laws such as HB 3115 and HB 3124, which went into effect in July, 2023.
The proposed camping ordinance aims to provideoconcise approach the ckv'scapacity and necessity to
regulate camping on public property in a way that differentiates between addressing behavior rather than the
status of individuals who are involuntarily homeless. Prohibited Camping and Prohibited Occupancy are
updated versions of ordinances previously employed by our city, as well as by most municipalities throughout
the state. What sets Ashland apart isits distinctive prohibition oncamping oroccupying ospecific public area
with the intent ofexcluding others from its use, rather than establishing otemporary campsite for the purpose of
^rnointoining o temporary place to live," which istypically the norm in ordinances of other Oregon cities. This shift
in approach signifies o departure from prohibiting individuals from living in public spaces and, instead, places
emphasis on addressing the issue of individuals establishing residency or asserting a sense of ownership over
public property. The definition of occupancy also establishes the times in which people are prohibited from
exclusively using public spaces for camping, lying or sitting and the length of time for such use during the
permitted times.
The changes to the prohibited camping ordinance concentrate on clarifying definitions for phrases that have
either been utilized or left ambiguous by federal courts, as well as in HB 3115 and HB 3124. For instance, the term
"involuntarily homeless" in the proposed ordinance aligns precisely with the courts'established definition of the
term. In contrast, HB 3115 and HB 3124 employ terms like "established camping site" and "apparent value Or utility"
to respectively specify the duration a campsite must remain in place and what belongings can or cannot be left
at that campsite. These clear definitions provide a community standard that aligns with language in relevant
case law and that will allow for equal, fair, and compassionate enforcement.
The remaining adjustments tothese ordinances are crafted toalign with established ^tirne\place, and manner"
regulations commonly applied in constitutional analyses of government laws. These ordinances are designed to
prevent individuals from camping onstreets, parks, nrother unsuitable areas. Defendants are given the option
to cease their occupation of the site, or they may face citation and penalties. The restrictions related to the
"time" and duration for camping, lying, or sitting, as previously explained, are specified within the definition of
^occupy oroccupancy.
^
in terms of location or "place" restrictions, certain areas are designated as inherently prohibited for any form of
camping. These areas are typically identified as sensitive areas to ensure public safety, well-being, and the
preservation ofpublic spaces, such ooparks and buildings. There are amendments tothe ordinance that
address unique challenges posed bvcamping incars orRVaonpublic streets.
Additionally, there are considered changes to the City's Persistent Violation ordinance to not only correct the
boundaries of the existing Enhanced Lovv Enforcement Area /^ELEA^\ but to create ELEAs for other areas that are
especially sensitive or prone to increased unlawful activity and then becoming an attraction for more such
activity. Legal is also evaluating if there are avenues to address drug use in public without running afoul with
Measure llOpreemption issues.
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Regarding "manner" regulation, this ordinance anticipates situations where individuals experiencing involuntary
homelessness may not find available shelter spaces within the city limits. in such cases, the city may enter into
contracts with organizations across the region that offer accessible shelter, easily reachable via local public
transit, and designed and operated to safeguard involuntarily homeless individuals and other vulnerable
populations for up to 72 hours at a single location. Oregon's new laws also establish specific responsibilities for
the city in managing property left behind by both homeless individuals and others who may have left their
belongings due to lack of alternatives. In these instances, the ordinance sets reasonable limits on what the city is
required tostore and the quantity thereof.
FISCAL IMPACTS
None
SUGGESTED NEXT STEPS
Suggest any modifications to the proposed ordinances and ask to have them noticed to schedule a first read.
REFERENCES &ATTACHMENTS
Proposed ORDINANCE RELATING TO PROHIBITED CAMPING AND PROHIBITED OCCUPANCY;AMENDING AMC CHAPTER
l0�6.O2OAND AMC lO.4G.03O
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AN ORDINANCE RELATING TO PROHIBITED CAMPING AND PROHIBITED
OCCUPANCY; AMENDING AMC CHAPTER 10.46.020 AND AMC 10.46.030
Annotated to show deletions and additions to the Ashland Municipal Code sections being
modified. Deletions are bold lined through, and additions are bold underlined.
WHEREAS, the City of Ashland must balance and prioritize several interests: recognition
of the essential human dignity of everyone in the City of Ashland; the need to have safe and
orderer conditions in City rights -of -way for the safety and benefit of everyone in Ashland;
t_he_right of everyone in Ashland to have shelter and safety; and respect for public spaces
and public property in service to the entire community.
It is in the public interest to regulate public streets and dedicated rights of way in a way
that could allow all to use the roads and sidewalks as they are intended and in the way that
they remain safe and accessible. Similarly, it is in the public interest to regulate park
spaces, playgrounds, and other public areas protected by the nature of their cultural and
historic character and their importance to the businesses and community that relies upon
and enjoys their preservation.
The City acknowledges that living on its streets is often a last resort for individuals. For
many of these persons the lack access to shelter is involuntary due to unforeseen
circumstances beyond a person's control that occurs when a person lacks viable options to
obtain housing due to factors such as economic hardship, loss of social network, health or
disability, or having exhausted available options for temporary or permanent housing
assistance.
This chapter is intended to regulate the use of public rights -of -way and City property to
protect and preserve the above described public places for their designed and intended
purposes, while providing alternative space and shelter to rest and sleep for personswho
lack access to suitable temporary shelter due to either financial inability or the
unavailability of free, viable options.
While recent federal case law is unclear as to whether the city can differentiate between
those who voluntarily choose to live homeless from those who are homeless involuntarily,
this chapter and the City's enforcement efforts are primarily intended to minimizing public
health and safety concerns related to survival camping in public areas, taking into account
the resources and opportunities available to those experiencing involuntary homelessness.
Those persons who are involuntarily homeless should feel secure that they will not be
penalized for their condition. The objective of this ordinance is to differentiate between
those who _genuinely lack alternatives and use public spaces out of necessity, and those who
have access to suitable alternative spaces and shelter but instead willfully exploit public
ORDINANCE NO. XXXX Page 1 of 7
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spaces for personal j4ain or advantage, to the detriment of the 2enerai public that includes
the involuntarily homeless population.
THE PEOPLE OF THE CITY OF ASHLAND DO ORDAIN AS FOLLOWS:
SECTION 10.46. Ashland Municipal Code Chapter 10.46 is hereby amended as follows:
Section 10.46.010. Definitions.
A. "Apparent value or utility" in reference to personal property means property that is
essential in practicality and significance to the owner's daily life and well-beinIz, and
includes but is not limited to, clothinj4, bedding, personal hygiene items, identification
documents, and any tools or resources necessary for survival and meeting basic needs,
maintaining dignity, and facilitating self -care. This definition does not include such
property as non-functional or broken items, excessive or redundant items, hazardous or
dangerous materials, items with limited or no personal value.
B. "To camp" means to set up or to remain in or at a campsite.
C. "Campsite" means any place where bedding, sleeping bag, or other material used for
bedding purposes, or any stove, fire, or cooking apparatus, other than in a designated picnic area,
is placed, established, maintained, or occupied, so as to exclude the use of public property by the
general public, whether or not such place incorporates the use of any tent, lean-to, shack, or any
other structure, or any vehicle or part thereof.
D. "Established camping site" means a campsite that has been in its current location for at
least 72 hours. In the absence of evidence regarding the age of a campsite, a camping site is
presumed established.
E. "Designated space or shelter" those areas as depicted in Exhibit A attached to the
ordinance codified in this section, and includes adequate shelter that is readily accessible
by local public transit, and that is designed and reasonably operated for the purpose of
protecting involuntarily homeless persons and other at -risk populations for up to 72 hours
in one location.
G. "Involuntarily homeless" means a person who lacks access to suitable temporary
shelter due to either financial inability or the unavailability of free, viable options.
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H. "Occupy" or "Occupancy" means to maintain physical control over a publicly owned
area of 50 square feet or greater by a person or person's private property, wherein the
primary effect is to exclude the use of the public property by the general public for more
than two (2) hours during daytime hours between 8:00 AM and 8:00 P.M.
SECTION 10.46.020. Camping Prohibited
A. Except as otherwise provided herein, no person shall camp in or upon any sidewalk,
street, alley, lane, public right-of-way, business -front, park, playground, Enhanced Law
Enforcement Area(s) defined in AMC 10.120.010, or any other publicly owned
property or under any bridge or viaduct.
B. The prohibition on camping may be temporarily suspended under the following
conditions:
a. A camping exemption due to an emergency in accordance with AMC 2.62;
b. The offender is Involuntarily Homeless and a Designated Space or Shelter is
unavailable.
C. Camping is strictly prohibited under any circumstance that includes existence of a
fire or gas stove, or when the campsite exceeds 100 square feet (10 feet by 10 feet),
or when located:
L On Sidewalks,
ii. Lithia Park and parks with playl4rounds,
iii. The Enhanced Law Enforcement Area(s) defined in AMC 10.120.010
iv. Within 250 feet of a preschool, kindergarten, elementary or secondary
school, or a childcare center licensed, certified or authorized under
ORS 329a.250-329a.460, ORS 418.205 to 418.970: OAR 419-410-0010
to OAR 419-490--0170
v. Within 250 feet of a Designated Space or Shelter;
vi. Within 250 feet of freeway entrance or exits;
vii. Within 150 feet of other campsites;
ORDINANCE NO. XXXX
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viii. Within 100 feet of any river or steam; and
ix. Attached to any fence, trees, building, or vehicle.
D. Involuntarily Homeless persons who use vehicles for shelter in a lawful parking
space in the foilowin2 circumstances:
a. The vehicle must be operational and must be moved at least 1000 feet from
its original location every 24 hours.
b. The parkinIZ space cannot be within a 100' radius of any residence.
c. No building or erecting of any structures connecting or attaching to vehicles
is permitted, including tents that are not designed and manufactured to be
attached to a vehicle.
d. Persons may not accumulate, discard or leave behind garbage, debris,
unsanitary hazardous materials, or other items of no apparent utility in
public rights -of -way, on City Property, or on any adjacent public or private
pro pertV-
e. All animals must be under the keeper's control or otherwise leashed or
crated at all times.
f. Dumping of gray water (i.e. wastewater from baths, sinks, and the like) or
black water (i.e. sewage) into any facilities or places not intended for gray
water or black water disposal is prohibited. This includes but is not limited
to storm drains, which are not intended for disposal of gray water or black
water.
E. Except as provided herein, the City will remove established campsites and
unclaimed property having Apparent Value or Utility from a campsite as provided
by ORS 195.505.
a. The following campsites are subject to immediate removal:
L Campsites that are not established;
ii. Site contamination by hazardous materials, fire hazards, a public
health emergency or other immediate danger to human life or safety;
ORDINANCE NO. XXXX
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iii. The occurrence or presence of evidence of criminal activity or
violation of the Ashland Municipal Code (excluding this offense)
b. Property held having no apparent value or utility, unless hazardous, will be
held for fourteen (14) days upon the demand of owner, and processed as
follows:
L The owner may appeal the determination in accordance with AMC
2.30, seeking to have the determination rescinded and the property
returned. The appeal notice shall specify the relief sought and the
reason for said relief.
ii. The Hearing Officer shall uphold the determination if, upon de novo
review, the preponderance of the evidence establishes that the
property does not meet the definition of havinLy apparent value or
utility according to AMC 10.46.010(A).
F. The City Manager has the authority to establish additional administrative rules
re2ardin2 time, place, and manner regulations as deemed necessary to address
particular situations arising from conditions affectin14 Involuntarily Homeless
individuals, and that are intended to safeguard the safety, health, and welfare of
both the 14eneral public and those who are Involuntarily Homeless.
CRIPWRIPWIMITCANW.W111.:• : : : : :. ::•
SECTION 10.46.030. Sleepi„j ,,,, Be,,ehes. Prohibited Occupancy.
A. Subiect to AMC 10.46.020 or authorized permit, no person shall occupy a public
area or street furniture during the time as provide in definitions of "Occupancy" defined
under AMC 10.46.010 H.
B. Any person who violates any provision of this Chapter is subject to Section 1.0$.020 of
the Ashland Municipal Code. Any violation of this section is a Class IV Violation. (Ord.
I IN He PIUMN, NORM
ORDINANCE NO. XXXX
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SECTION 10.46.050. Removal of Campsite
A Violation of this section is punishable by an AMC Class IV fine. In lieu of a fine the may
be converted the eight hours community service.
B. The court shall consider in mitigation of any punishment imposed upon a person convicted
of prohibited camping whether or not the person immediately removed the campsite upon being
cited. For purpose of this section, removal of the campsite shall include all litter, including but
not limited to bottles, cans, garbage, rubbish and items of no apparent utility, deposited by the
ORDINANCE NO. XXXX Page 6 of 7
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person in and around the campsite. All litter in and around the campsite shall be presumed to be
deposited by the person convicted of prohibited camping. Such presumption shall be rebuttable,
however. If an offender, who has been cited for a violation of this Section, can show
meaningful en2a2ement with a referred service provider or a similar one before the
hearing, the iud2e may exercise discretion to reduce or waive the fine. (Ord. 3026, amended,
08/03/2010; Ord. 2972, amended, 11/04/2008)
SECTION 10.46.050. Application outside City
Pursuant to ORS 26.010, this chapter applies to acts committed on park property owned by the
City that is located outside the City. (Ord. 2972, amended, 11/04/2008)
SECTION 3. Codification. Provisions of this Ordinance shall be incorporated in the City
Code, and the word "ordinance" may be changed to "code", "article", "section", or another word,
and the sections of this Ordinance may be renumbered or re -lettered, provided however, that any
Whereas clauses and boilerplate provisions (i.e., Sections [No(s.)] need not be codified, and the
City Recorder is authorized to correct any cross-references and any typographical errors.
The foregoing ordinance was first read by title only in accordance with Article X, Section 2(C)
of the City Charter on the day of 1 2023, and duly PASSED and
ADOPTED this _ day of 2023.
ATTEST:
Alissa Kolodzinski, City Recorder
SIGNED and APPROVED this day of
Tonya Graham, Mayor
2023.
Page 7 of 7
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Guide to Persons Experiencing Homelessness in Public Spaces
Cities possess a significant amount of property — from parks, greenways, sidewalks, and public
buildings to both the developed and undeveloped rights of way — sizable portions of a city belong
to the city itself, and are held in trust for particular public purposes or use by residents.
Historically cities have regulated their various property holdings in a way that prohibits persons
from camping, sleeping, sitting or lying on the property. The historic regulation and
management of a city's public spaces must be reimagined in light of recent federal court
decisions and the Oregon Legislature's enactment of HB 3115, both of which direct cities to
consider their local regulations within the context of available local shelter services for those
persons experiencing homelessness.
As the homelessness crisis intensifies, and the legal parameters around how a city manages its
public property contract, cities need guidance on how they can regulate their property in a way
that respects each of its community members, complies with all legal principles, and protects its
public investments. A collective of municipal attorneys from across the state of Oregon
convened a work group to create this guide, which is intended to do two things: (1) explain the
legal principles involved in regulating public property in light of recent court decisions and
statutory enactments; and (2) provide a checklist of issues/questions cities should review before
enacting or amending any ordinances that may impact how their public property is managed.
Legal Principles Involved in Regulating Public Property
Two key federal court opinions, Martin v. Boise and Blake v. Grants Pass, have significantly
impacted the traditional manner in which cities regulate their public property. In addition to
these two pivotal cases, the Oregon Legislature enacted HB 3115 during the 2021 legislative
session as an attempt to clarify, expand, and codify some of the key holdings within the court
decisions. An additional piece of legislation, HB 3124, also impacts the manner in which cities
regulate public property in relation to its use by persons experiencing homelessness. And, as the
homelessness crisis intensifies, more legal decisions that directly impact how a city regulates its
public property when it is being used by persons experiencing homelessness are expected. Some
of these pending cases will seek to expand, limit, or clarify the decisions reached in Martin and
Blake; other pending cases seek to explain how the well -established legal principle known as
State Created Danger applies to actions taken, or not taken, by cities as they relate to persons
experiencing homelessness.
A. The Eighth Amendment to the U.S. Constitution
The Eighth Amendment to the U.S. Constitution states that excessive bail shall not be required,
nor excessive fines imposed, nor cruel and unusual punishment inflicted. In 1962, the U.S.
Supreme Court, in Robinson v. California, established the principle that "the Eighth Amendment
prohibits the state from punishing an involuntary act or condition if it is the unavoidable
consequence of one's status or being." 370 U.S. 660 (1962).
Guide to Persons Experiencing Homelessness in Public Spaces
B. Martin v. Boise
In 2018, the U.S. 91h Circuit Court of Appeals, in Martin v. Boise, interpreted the Supreme
Court's decision in Robinson to mean that the Eighth Amendment to the U.S. Constitution
"prohibits the imposition of criminal penalties for sitting, sleeping, or lying outside on public
property for homeless individuals who cannot obtain shelter ... because sitting, lying, and
sleeping are ... universal and unavoidable consequences of being human." The court declared
that a governmental entity cannot "criminalize conduct that is an unavoidable consequence of
being homeless — namely sitting, lying, or sleeping." 902 F3d 1031, 1048 (2018).
The 91h Circuit clearly stated in its Martin opinion that its decision was intentionally narrow, and
that some restrictions on sitting, lying, or sleeping outside at particular times or in particular
locations, or prohibitions on obstructing the rights of way or erecting certain structures, might be
permissible. But despite the narrowness of the decision, the opinion only truly answered some of
the many questions cities are rightly asking. After Martin, municipal attorneys could advise their
clients in limited ways: some things were clear, and others were pretty murky.
One of the most commonly misunderstood aspects of the Martin decision is the belief that a city
can never prohibit a person experiencing homelessness from sitting, sleeping or lying in public
places. The Martin decision, as noted, was deliberately limited. Cities are allowed to impose
city-wide prohibitions against persons sitting, sleeping, or lying in public, provided the city has a
shelter that is accessible to the person experiencing homelessness against whom the prohibition
is being enforced. Even if a city lacks enough shelter space to accommodate the specific person
experiencing homelessness against whom the prohibition is being enforced, it is still allowed to
limit sitting, sleeping, and lying in public places through reasonable restrictions on the time,
place and manner of these acts ("where, when, and how") — although what constitutes a
reasonable time, place and manner restriction is often difficult to define.
A key to understanding Martin is recognizing that an analysis of how a city's ordinance, and its
enforcement of that ordinance, can be individualized. Pretend a city has an ordinance which
prohibits persons from sleeping in city parks if a person has nowhere else to sleep. A person
who violates that ordinance can be cited and arrested. A law enforcement officer finds 11
persons sleeping in the park, and is able to locate and confirm that 10 of said persons have access
to a shelter bed or a different location in which they can sleep. If any of those 10 persons refuses
to avail themselves of the available shelter beds, the law enforcement officer is within their
rights, under Martin, to cite and arrest the persons who refuse to leave the park. The practicality
of such an individualized assessment is not to be ignored, and cities are encouraged to consider
the ability to make such an assessment as they review their ordinances, polices, and procedures.
What is clear from the Martin decision is the following:
1. Cities cannot punish a person who is experiencing homelessness for sitting, sleeping, or
lying on public property when that person has no place else to go;
2. Cities are not required to build or provide shelters for persons experiencing
homelessness;
Guide to Persons Experiencing Homelessness in Public Spaces 3
3. Cities can continue to impose the traditional sit, sleep, and lie prohibitions and
regulations on persons who do have access to shelter; and
4. Cities are allowed to build or provide shelters for persons experiencing homelessness.
After Martin, what remains murky, and unknown is the following:
What other involuntary acts or human conditions, aside from sleeping, lying and sitting,
are considered to be an unavoidable consequence of one's status or being?
2. Which specific time, place and manner restrictions can cities impose to regulate when,
where, and how a person can sleep, lie or sit on a public property?
3. What specific prohibitions can cities impose that will bar a person who is experiencing
homelessness from obstructing the right of way?
4. What specific prohibitions can cities impose that will prevent a person who is
experiencing homelessness from erecting a structure, be it temporary or permanent, on
public property?
The city of Boise asked the United States Supreme Court to review the 9t" Circuit's decision in
Martin. The Supreme Court declined to review the case, which means the opinion remains the
law in the 9t" Circuit. However, as other federal circuit courts begin considering a city's ability
to enforce sitting, sleeping and camping ordinances against persons experiencing homelessness,
there is a chance that the Supreme Court may review a separate but related opinion to clarify the
Martin decision and provide clarity to the outstanding issues raised in this guide.
C. Blake v. Grants Pass
Before many of the unanswered questions in Martin could be clarified by the 9th Circuit or the
U.S. Supreme Court, an Oregon federal district court issued an opinion, Blake v. Grants Pass,
which provided some clarity, but also provided an additional layer of murkiness.
From the District Court's ruling in the Blake case we know the following:
1. Whether a city's prohibition is a civil or criminal violation is irrelevant. If the prohibition
punishes an unavoidable consequence of one's status as a person experiencing
homelessness, then the prohibition, regardless of its form, is unconstitutional.
2. Persons experiencing homelessness who must sleep outside are entitled to take necessary
minimal measures to keep themselves warm and dry while they are sleeping.
3. A person does not have access to shelter if:
Guide to Persons Experiencing Homelessness in Public Spaces 4
• They cannot access the shelter because of their gender, age, disability or familial
status;
• Accessing the shelter requires a person to submit themselves to religious teaching
or doctrine for which they themselves do not believe;
• They cannot access the shelter because the shelter has a durational limitation that
has been met or exceeded; or
• Accessing the shelter is prohibited because the person seeking access is under the
influence of some substance (for example alcohol or drugs) or because of their
past or criminal behavior.
But much like Martin, the Blake decision left unanswered questions. The key unknown after
Blake, is this: What constitutes a minimal measure for a person to keep themselves warm and
dry —is it access to a blanket, a tent, a fire, etc.?
On September 28, 2022, the U.S. 9th Circuit Court of Appeals rendered their opinion and
affirmed Blake v. City of Grants Pass. 1 The 9th Circuit Court of Appeals upheld the U.S.
District Court's prior ruling that persons experiencing homelessness are entitled to take
necessary minimal measures to keep themselves warm and dry while sleeping outside. The 9th
Circuit Court of Appeals noted that the decision in this case was narrow and that "it is
`unconstitutional to [punish] simply sleeping somewhere in public if one has nowhere else to do
so. i,'2
The 9th Circuit Court of Appeals opined that cities violate the Eighth Amendment if they punish
a person for the mere act of sleeping outside or for sleeping in their vehicles at night when there
is no other place in the city for them to go. 3 As a result of this ruling, this decision expanded the
application of Martin v. Boise. The opinion concluded that class actions are permissible in these
types of cases and remanded the decision for the District Court to make findings on several
outstanding matters in the case.
This opinion, in most respects, affirmed what was already known from both the
Martin and Blake cases. However, the opinion failed to provide much anticipated clarification on
several issues, such as what constitutes "necessary minimal measures" to keep warm or dry or
what "rudimentary protections from elements" means.
The City of Grants Pass intends to file a petition for an en bane panel rehearing —a petition for
the three judge panel opinion be re -heard by a panel of twelve judges. During the pendency of
the petition process, the current opinion is in effect and the outstanding questions remain
unanswered by the Court.
` Johnson v. City of Grants Pass, 50 FAt' 787 (9th Cir. 2022) [formerly Blake v. City of Grants Pass; class
representative Blake became deceased during pendency of the appeal.]
2 jd. at 813,
3 Id.
Guide to Persons Experiencing Homelessness in Public Spaces 5
Municipal attorneys are still challenged in determining the answers to such questions as the
following: what types of changes should be expected, the severity of those changes, and when
those changes will occur. Given the fluidity surrounding the legal issues discussed in this guide,
before adopting any new policy, or revising an existing policy, that touches on the subject matter
described herein, cities are strongly encouraged to speak with their legal advisor to ensure the
policy is constitutional.
D. House Bill 3115
1113 3115 was enacted by the Oregon Legislature during its 2021 session. It is the product of a
workgroup involving the LOC and the Oregon Law Center as well as individual cities and
counties.
The bill requires that any city or county law regulating the acts of sitting, lying, sleeping or
keeping warm and dry outside on public property must be "objectively reasonable" based on the
totality of the circumstances as applied to all stakeholders, including persons experiencing
homelessness. What is objectively reasonable may look different in different communities.
The bill retains cities' ability to enact reasonable time, place and manner regulations, aiming to
preserve the ability of cities to manage public spaces effectively for the benefit of an entire
community.
1113 3115 includes a delayed implementation date of July 1, 2023, to allow local governments
time to review and update ordinances and support intentional community conversations.
From a strictly legal perspective, 1413 3115 did nothing more than restate the judicial decisions
found in Martin and Blake, albeit a hard deadline to comply with those judicial decisions was
imposed. The bill provided no further clarity to the judicial decisions, but it also imposed no
new requirements or restrictions.
E. House Bill 3124
Also enacted during the 2021 legislative session, 1113 3124 does two things. First, it changes and
adds to existing guidance and rules for how a city is to provide notice to homeless persons that
an established campsite on public property is being closed, previously codified at ORS 203.077
et seq., now found at ORS 195.500, et seq. Second, it gives instructions on how a city is to
oversee and manage property it removes from an established campsite located on public
property. It is important to remember that 1113 3124 applies to public property; iti Y s not
applicable to private property. This means that the rules and restrictions imposed by 1113 3124
are not applicable city-wide, rather they are only applicable to property classified as public.
1413 3124 does not specify, with any true certainty, what constitutes public property. There has
been significant discussion within the municipal legal field as to whether rights of way constitute
public property for the purpose of interpreting and implementing 1113 3124. The general
consensus of the attorneys involved in producing this guide is that rights of way should be
considered public property for purposes of 1113 3124. If an established homeless camp is located
on rights of way, it should generally be treated in the same manner as an established camp
Guide to Persons Experiencing Homelessness in Public Spaces 6
located in a city park. However, as discussed below, depending on the dangers involved with a
specific
peci ic location, exceptions to this general rule exist.
When a city seeks to remove an established camp site located on public property, it must do so
within certain parameters. Specifically, a city is required to provide 72-hour notice of its intent
to remove the established camp site. Notices of the intention to remove the established camp site
must be posted at each entrance to the site. In the event of an exceptional emergency, or the
presence of illegal activity other than camping at the established campsite, a city may act to
remove an established camp site from public property with less than 72-hour notice. Examples
of an exceptional emergency include: possible site contamination by hazardous materials, a
public health emergency, or immediate danger to human life or safety.
While HB 3124 specifies that the requirements contained therein apply to established camping
sites, it falls to define what constitutes an established camping site. With no clear definition of
what the word established means, guidance on when the 72-hour notice provisions of 1113 3124
apply is difficult to provide. The working group which developed this guide believes a cautious
approach to defining the word established at the local level is prudent. To that end, the LOC
recommends that if, for example, a city were to enact an ordinance which permits a person to
pitch a tent between the hours of 7 p.m. and 7 a.m., that the city also then consistently and
equitably enforce the removal of that tent by 7 a.m. each day, or as close as possible to 7 a.m.
Failing to require the tent's removal during restricted camping hours each day, may, given that
the word established is undefined, provide an argument that the tent is now an established camp
site that triggers the requirement of 1413 3124.
In the process of removing an established camp site, oftentimes city officials will also remove
property owned by persons who are experiencing homelessness. When removing items from
established camp sites, city officials should be aware of the following statutory requirements:
* Items with no apparent value or utility may be discarded immediately;
0 Items in an unsanitary condition may be discarded immediately;
0 Law enforcement officials may retain weapons, drugs, and stolen property;
• Items reasonably identified as belonging to an individual and that have apparent value or
utility must be preserved for at least 30 days so that the owner can reclaim them; and
• Items removed from established camping sites in counties other than Multnomah County
must be stored in a facility located in the same community as the camping site from
4D
which it was removed. Items removed from established camping sites located in
Multnomah County must be stored in a facility located within six blocks of a public
transit station.
Cities are encouraged to discuss with legal counsel the extent to which these or similar
requirements may apply to any camp site, "established" or not, because of due process
protections.
Guide to Persons Experiencing Homelessness in Public Spaces 7
F. Motor Vehicles and Recreational Vehicles
Cities need to be both thoughtful and intentional in how they define and regulate sitting,
sleeping, lying, and camping on public property. Is sleeping in a motor vehicle or a recreational
vehicle (RV) that is located on public property considered sitting, lying, sleeping, or camping on
public property under the city's ordinances and policies? This guide will not delve into the
manner in which cities can or should regulate what is commonly referred to as car or RV
camping; however, cities do need to be aware that they should consider how their ordinances and
policies relate to car and RV camping, and any legal consequences that might arise if such
regulations are combined with ordinances regulating sitting, lying, sleeping, or camping on
public property. Motor and recreational vehicles, their location on public property, their
maintenance on public property, and how they are used on or removed from public property are
heavily regulated by various state and local laws, and how those laws interact with a city's
ordinance regulating sitting, lying, sleeping, or camping on public property is an important
consideration of this process. Further, the Court of Appeals opinion in Blake v. City of Grants
Pass has potential implications in determining how cities can regulate motor vehicles.
G. State Created Danger
In 1989, the U.S. Supreme Court, in DeShaney v. Winnebago Cnty. Dept of Soc. Servs.,
interpreted the Fourteenth Amendment to the U.S. Constitution to impose a duty upon the
government to act when the government itself has created dangerous conditions — this
interpretation created the legal principle known as State Created Danger. 489 U.S. 189 (1989).
The 9th Circuit has interpreted the State Created Danger doctrine to mean that a governmental
entity has a duty to act when the government actor "affirmatively places the plaintiff in danger
by acting with 'deliberate indifference' to a 'known or obvious danger."' LA Alliance for
Human Rights v. City of Los Angeles, 2021 WL 1546235.
The State Created Danger principle has three elements. First, the government's own actions must
have created or exposed a person to an actual, particularized danger that the person would not
have otherwise faced. Second, the danger must have been one that is known or obvious. Third,
the government must act with deliberate indifference to the danger. Id. Deliberate indifference
requires proof of three elements:
"(1) there was an objectively substantial risk of harm; (2)
the [state] was subjectively aware of facts from which an
inference could be drawn that a substantial risk of serious
harm existed; and (3) the [state] either actually drew that
inference or a reasonable official would have been
compelled to draw that inference." Id.
Municipal attorneys are closely reviewing the State Created Danger principle as it relates to the
use of public spaces by persons experiencing homelessness for three reasons. First, many cities
are choosing to respond to the homeless crisis, the legal decisions of Martin and Blake, and 1-113
3115, by creating managed homeless camps where unhoused persons can find shelter and
Guide to Persons Experiencing Homelessness in Public Spaces 8
services that may open the door to many State Created Danger based claims of wrongdoing (e.g.
failure to protect from violence, overdoses, etc. within the government sanctioned camp).
Second, in California, at least one federal district court has recently ruled that cities have a duty
to act to protect homeless persons from the dangers they face by living on the streets, with the
court's opinion resting squarely on the State Created Danger principle. Third, when imposing
reasonable time, place, and manner restrictions to regulate the sitting, sleeping or lying of
persons on public rights of way, cities should consider whether their restrictions, and the
enforcement of those restrictions, trigger issues under the State Created Danger principle.
Fourth, when removing persons and their belongings from public rights of way, cities should be
mindful of whether the removal will implicate the State Created Danger principle.
In creating managed camps for persons experiencing homelessness, cities should strive to create
camps that would not reasonably expose a person living in the camp to a known or obvious
danger they would not have otherwise faced. And if there is a danger to living in the camp, a
city should not act with deliberate indifference to any known danger in allowing persons to live
in the camp.
And while the California opinion referenced above has subsequently been overturned by the 9t"
Circuit Court of Appeals, at least one federal district court in California has held that a city
"acted with deliberate indifference to individuals experiencing homelessness" when the city
allowed homeless persons to "reside near overpasses, underpasses, and ramps despite the
inherent dangers — such as pollutants and contaminant." LA Alliance for Human Rights v. City of
Los Angeles, 2022 WL 2615741. The court essentially found a State Create Danger situation
when a city allowed persons experiencing homelessness to live near interstates — a living
situation it "knew" to be dangerous.
Before a city official enforces a reasonable time, place, and manner restriction which regulates
the sitting, sleeping and lying of persons on public property, the official should review the
enforcement action they are about to take in in light of the State Created Danger principle. For
example, if a city has a restriction that allows persons to pitch a tent on public property between
the hours of 7 p.m. and 7 a.m., a city official requiring the person who pitched the tent to remove
it at 7:01 a.m. should be mindful of all environmental conditions present at the time their
enforcement order is made. The same thoughtful analysis should be undertaken when a city
removes a person and their belongings from the public rights of way.
How Cities Proceed
The law surrounding the use of public spaces by persons experiencing homelessness is newly
emerging, complex, and ripe for additional change. In an effort to simplify, as much as possible,
the complexity of this legal conundrum, below is an explanation of what municipal attorneys
know cities must do, must not do, and may potentially do.
A. nat Cities Must Do
In light of the court decisions discussed herein, and the recent House bills enacted by the Oregon
Legislature, cities must do the following:
Guide to Persons Experiencing Homelessness in Public Spaces
1. Review all ordinances and policies with your legal advisor to determine which ordinances
and policies, if any, are impacted by the court decisions or recently enacted statutes.
2. Review your city's response to the homelessness crisis with your legal advisor to ensure
the chosen response is consistent with all court decisions and statutory enactments.
If your city chooses to exclude persons experiencing homelessness from certain areas of
the city for violating a local or state law, the person must be provided the right to appeal
that expulsion order, and the order must be stayed while the appeal is pending.
3. If your city choses to remove a homeless person's established camp site, the city must
provide at least 72-hour notice of its intent to remove the site, with notices being posted
at entry point into the camp site.
4. If a city obtains possession of items reasonably identified as belonging to an individual
and that item has apparent value or utility, the city must preserve that item for at least 30
days so that the owner can reclaim the property, and store that property in a location that
complies with state law.
B. "at Cities Must Not Do
When the decisions rendered by the federal district court of Oregon and the 9th Circuit Court of
Appeals are read together, particularly in conjunction with Oregon statutes, cities must not do the
following:
1. Cities cannot punish a person who is experiencing homelessness for sitting, sleeping, or
lying on public property when that person has no place else to go within the city's
jurisdiction .
2. Cities cannot prohibit persons experiencing homelessness from taking necessary minimal
measures to keep themselves warm and dry when they must sleep outside.
3. Cities cannot presume that a person experiencing homelessness has access to shelter if
the available shelter options are:
• Not accessible because of their gender, age, or familial status;
• Ones which requires a person to submit themselves to religious teaching or
doctrine for which they themselves do not believe;
• Not accessible because the shelter has a durational limitation that has been met or
exceeded; or
• Ones which prohibit the person from entering the shelter because the person is
under the influence of some substance (for example alcohol or drugs) or because
of their past or criminal behavior.
Guide to Persons Experiencing Homelessness in Public Spaces 10
C. "at Cities May Potentially Do
As previously noted, the recent court decisions lack clarity in many key respects. This lack of
clarity, while frustrating, also provides cities some leeway to address the homelessness crisis,
specifically with how the crisis impacts the management of public property.
1. Cities may impose reasonable time, place and manner restrictions on where persons,
including those persons experiencing homelessness, may sit, sleep, or lie. Any such
regulation imposed by a city should be carefully vetted with the city's legal advisor.
2. Cities may prohibit persons, including those persons experiencing homelessness, from
blocking rights of way. Any such regulation should be carefully reviewed by the city's
legal advisor to ensure the regulation is reasonable and narrowly tailored.
Cities may prohibit persons, including those persons experiencing homelessness, from
erecting either temporary or permanent structures on public property. Given that cities
are required, by Blake, to allow persons experiencing homelessness to take reasonable
precautions to remain warm and dry when sleeping outside, any such provisions
regulating the erection of structures, particularly temporary structures, should be carefully
reviewed by a legal advisor to ensure the regulation complies with all relevant court
decisions and Oregon statutes.
4. If a city chooses to remove a camp site, when the camp site is removed, cities may
discard items with no apparent value or utility, may discard items that are in an
unsanitary condition, and may allow law enforcement officials to retain weapons, drugs,
and stolen property.
5. Cities may create managed camps where person experiencing homelessness can find safe
shelter and access to needed resources. In creating a managed camp, cities should work
closely with their legal advisor to ensure that in creating the camp they are not
inadvertently positioning themselves for a State Created Danger allegation.
D. What Cities Should Practically Consider
While this guide has focused exclusively on what the law permits and prohibits, cities are also
encouraged to consider the practicality of some of the actions they may wish to take. Prior to
imposing restrictions, cities should work with all impacted staff and community members to
identify if the suggested restrictions are practical to implement. Before requiring any tent
pitched in the public right of way to be removed by 8 a.m., cities should ask themselves if they
have the ability to practically enforce such a restriction — does the city have resources to ensure
all tents are removed from public property every morning 365 days a year? If a city intends to
remove property from a camp site, cities should practically ask themselves if they can store said
property in accordance with the requirements of 1-113 3124. Both questions are one of only
dozens of practical questions cities need to be discussing when reviewing and adopting policies
that touch on topics covered by this guide.
Guide to Persons Experiencing Homelessness in Public Spaces 11
Conclusion
Regulating public property, as it relates to persons experiencing homelessness, in light of recent
court decisions and legislative actions, is nuanced and complicated. It is difficult for cities to
know which regulations are permissible and which are problematic. This guide is an attempt to
answer some of the most common legal issues raised by Martin, BlakelJohnson, 1113 3115, HB
3124, and the State Created Danger doctrine — it does not contain every answer to every question
a city may have, nor does it provide guidance on what is in each community's best interest.
Ultimately, how a city chooses to regulate its public property, particularly in relation to persons
experiencing homelessness, is a decision each city must make on its own. A city's decision
should be made not just on the legal principles at play, but on its own community's needs, and be
done in coordination with all relevant partners. As with any major decision, cities are advised to
consult with experts on this topic, as well as best practice models, while considering the potential
range of public and private resources available for local communities. Cities will have greater
success in crafting ordinances which are not only legally acceptable, but are accepted by their
communities, if the process for creating such ordinances is an inclusive process that involves
advocates and people experiencing homelessness.
Additional Resources
The League of Oregon Cities (LOC), in preparing this guide, has obtained copies of ordinances
and policies that may be useful to cities as they consider their own next steps. Additionally,
several municipal advisors who participated in the development of this guide have expressed a
willingness to share their own experiences in regulating public rights of way, particularly as it
relates to persons experiencing homelessness, with Oregon local government officials. If you
believe these additional resources may be of use to you or your city, please feel free to contact a
member of the LOC's Legal Research Department.
Recognition and Appreciation
The LOC wishes to extend its sincerest thanks to the municipal attorneys who assisted in the
development of this guide. Attorneys from across Oregon came together over several months to
vet legal theories, share best practices, and create this guide. These attorneys donated their time,
experience, and resources — seeking nothing in return. And while a core team of attorneys was
gathered to build this guide, the LOC recognizes that the team's work stands on the shoulders of
every city and county attorney in Oregon who has been working, and who will continue to work,
to assist their community in addressing the homelessness crisis. For those attorneys not
specifically named below, please know your contributions are equally recognized and respected:
• Aaron Hisel, Montoya, Hisel & Associates;
• Chad Jacobs, Beery Elsner & Hammond;
• Eric Mitton, City of Medford;
Guide to Persons Experiencing Homelessness in Public Spaces 12
• Kirk Mylander, Citycounty Insurance Services;
• Elizabeth Oshel, City of Bend;
® Mary Winters, City of Bend; and
• Grace Wong, City of Beaverton.
Guide to Persons Experiencing Homelessness in Public Spaces 13
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Dana Smith
From: City ofAshland, Oregnn<administradon@ash|ondor.us>
Sent: Monday, November 62O231:30PK4
To: City Recorder; DorindaCottle
Subject: Council Public Testimony Form Submitted
[EXTERNAL SENDER]
*** FORM FIELD DATA***
Full Name: Kim &4ortenuon
Meeting Date: Monday Nov 6th
Type VfTestimony: WRITTEN
Written Testimony: Dear Councillors, The portable toilets behind the new shelter are anuisance and a blight. And the
black fence does nothing to screen them. It is transparent. Now that the leaves have dropped | see those bright blue
toilets from four different rooms in my house including my dining room. They are a public nuisance. I used to have a
beautiful view from my house. Please see AMC 9.08.060, which says it is a nuisance affecting public health and that
they may not be maintained unless in connection with a construction project. If it were one of us who put a bright
blue -or any color?portable toilet in our yard or driveway because we didn?t have enough for all the residents inside
the building that would not be OK with the neighbors or the city. Why is it OK for the city but not us? We were told
they would be screened from view. We believed what we were told. Please be good neighbors to us. So many of us
who live on Takelma Way are distressed to have to look at these every day. I pray on a daily basis that the city will
reconsider placing two homeless shelters in my neighborhood. It?s so sad what has happened to my neighborhood
since the OHRA shelter opened. The value of my property has decreased even more now. I worked very hard for 30
years tobeable tobuy ahouse. |twas a nice neighborhood when I bought it. Please choose another location for the
shelter. This neighborhood needs to be improved, not worsened. For two million taxpayer dollars, those sheltered
people should have indoor flush toilets. Especially in the winter. Another building in another neighborhood with
adequate toilets and showers would be perfect. And fair to all of us in this neighborhood. Sincerely, Kim Mortenson
*** USER INFORMATION
***
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RemoteAddress:66.241.70.75
RemoteHos1: 65.241.70.76
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Mayor and Councilors,
Why I care:
This spring our two families bought a lovely home on Clay Street with knowing
little about south Ashland's homelessness problem. Had we known this shelter
would be opened within arm's reach of the underpass and the bike path and
within two blocks of our home, probably we would have found a lovely home
elsewhere.
Our granddaughter had planned to use the bike path to walk or ride her
bike to school. But with the recent opening of the shelter, we understand that
transients continue to congregate under the bridge and on the tracks; are
intoxicated, use drugs, possibly deal them, dump trash, and heaven knows what
else. The underpass is not safe for our granddaughter or any neighborhood child.
Our daughter was looking forward to the variety of places she could walk
her dog. The situation under the bridge has put a stop to that and as you know,
parking on narrow Clay Street leaves little room for dog walking.
I, too, would walk along the bike path and see what lies around the corner
of the underpass, but frankly it scares this little old lady. Instead, I deep breath,
think beautiful thoughts and do my tai chi in the safety of home.
Here are a few requests to improve our livability within the vicinity of Clay
Street, the bike path and underpass from Wingspread to Clay— immediately
rather than someday:
1. Install lights under the bridge, and next to the chain link fence along the bike
path.
2. Better signage should be posted next to the underpass and should extend a
block or so further up Clay to state loud and clear: No Camping, No Overnight
Parking, No Loitering or Sleeping, No Littering or Dumping.
3.Also, I think if the police conduct daily patrols of this area, it would go a long
way convincing transients to move on to something more permanent.
4. 1 also suggest that the austere chain -link fence next to the underpass be made
to look less like the entrance to a prison. How about a low- maintanence garden
established close by to soften it. Also, the old fence along the bike path should be
replaced and that area beautified. In the words of Kati Case, "ugly fencing leads
to an overall feeling of decline and hopelessness" and only encourages dumping.
(my words) Ugly chain -link fencing cheapens and devalues the neighborhood.
5. A Beautification Project consisting of a mural that would warm up the coldness
of the underpass cement walls would go a long way to put much needed smiles
on the faces of our Clay Street residents, and people driving past.
Suggestion for mural: A biker flying by, a group of children on their way to
school, an older man & woman hand in hand walking, person walking a dog, a
couple stopping to chat, person running....
Question: Other than the metal profile of the firefighter at the fire station on
Ashland Street, are there any other works of public art on this side of Ashland?
Why I care?:
We understand that south Ashland is the gateway to Ashland. It is where
we live, work, play, and in Kati Case's words, '"we want to see it thriving,
attractive, clean, and safe for all." Ashland as a whole has always been proud of
its people, its culture, it's artistic bents, and its attractiveness. I believe Ashland
has been one of the most outstanding towns in Oregon. Take a good look around
at the entrance and exit along the freeway, folks. Is this the view you want to see
on a postcard?
Thank • for • time,
lwiip Riinrh
61 =11T. M.
TIIIS FORM IS A PUBLIC RECORD
REJUATE t,,V#jL4,HLE T11 WE PUBLIC
1) Complete this form, indicate the topic you want to speak on and return it to the City Recorder at
the start of the meeting.
2) State your name and address for the record.
3) Limit your comments to the amount of time given to you by the Mayor, usually 3 or 5 minutes.
4) If you present written materials, please give a copy to the City Recorder for the record.
5) You may give written comments to the City Recorder for the record if you do not wish to speak.
(Comments can be added to the back of this sheet if necessary)
6) Speakers are solely responsible for the content of their public statement.
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Name
Study Session
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The Public Meeting Law requires that all city meetings are open to the public. Oregon law does not
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Comments and statements by speakers do not represent the opinion of the City Council, City Officers or
employees or the City of Ashland.
Study Sessions
THIS FORM IS A PUBLIC RECORD
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THOSE INTERESTED IN GIVING ORAL TESTIMONY AT A COUNCIL MEETING WILL NEED TO:
1) Complete this form, including the topic you want to speak on and send to the City Recorder:
11,-�iltO -Ill CjiSS 11Ulitahi i),ashknd eel I
2) Begin the oral testimony during the meeting by stating your name for the record.
3) Limit your comments to the amount of time given to you by the Mayor, usually 3 or 5 minutes.
4) If you present written materials, please email a copy of the materials with this form to the City
Recorder for the record.
5) Speakers are solely responsible for the content of their public statement.
Meeting Date
Name J1e,t' v Llr`i
Agenda topic/item number/Topic"
The Public Meeting Law requires that all city meetings are open to the public. Oregon law does not
always require that the public be permitted to speak.
Comments and statements by speakers do not represent the opinion of the City Council, City Officers or
employees or the City of Ashland.
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1) Complete this form, indicate the topic you want to speak on and return it to the City Recorder at
the start of the meetin&
2) State your name and address for the record.
3) Limit your comments to the amount of time given to you by the Mayor, usually 3 or 5 minutes.
4) If you present written materials, please give a copy to the City Recorder for the record,
5) You may give written comments to the City Recorder for the record if you do not wish to speak.
(Comments can be added to the back of this sheet if necessary)
6) Speakers are solely responsible for the content of their public statement.
Agenda topic/item numberffopic-ftnAXA---�
The Public Meeting Law requires that all city meetings are open to the public. Oregon law does not
,filways require that the public be permitted to speak.
Comments and statements by speakers do not represent the opinion of the City Council, City Officers or
employees or the City of Ashland.