Training Bulletin 24-02 - Orange Municipal Code Camping EnforcementTRUST ▪ CARE ▪ COMMITMENT
September 16, 2024 TB# 24-02
OMC CAMPING ENFORCEMENT
The purpose of this training bulletin is to provide Orange Police Officers with an update about
enforcement of the Orange Municipal Codes relating to public camping in light of a recent United States
Supreme Court Decision Grants Pass v. Johnson.
As has been discussed in past trainings, the Ninth Circuit Court of Appeal , in a case called Martin v. City
of Boise, held that arresting homeless people (essentially because they were homeless and had nowhere
else to sleep) was a violation of the 8th Amendment to the Constitution that prohibits “cruel and unusual
punishment”. This decision caused a lot of confusion and lawsuits. Essentially, the Federal Courts read
Martin v. Boise to mean that a homeless person could not be cited for public camping if shelter/housing
options were not available.
In Grants Pass, the United States Supreme Court overturned Martin v. Boise, essentially stating that the
8th Amendment’s “cruel and unusual” clause does not apply to the enforcement of anti-camping
ordinances. Because of this ruling, the City no longer is required to have “beds available” prior to citing
someone for camping in public. Now that the US supreme Court has weighed in, many cities in Orange
County are commencing more aggressive public camping enforcement.
There are two public camping Orange Municipal Code (OMC) sections: OMC 12.66.030 – Use
Street/Public Property for Camping and OMC 12.48.045 – City Park Camping (no permit). The language
of these OMC sections describes and defines what constitutes camping on public property.
OMC DEFINITIONS:
“Camping” means the use of public streets or public property for living accommodation or habitation
purposes such as sleeping activities or making preparations to sleep, including the laying down of bedding
for purposes of sleeping or using or storing personal belongings such as non-designated City cooking
equipment, camping stoves, portable barbecues, sleeping bags, cots, beds, hammocks, extra clothing, or
personal items when it reasonably appears, in light of all the circumstances, that the participants, in
conducting these activities, are, in fact, using the public street or public property for living
accommodation or habitation purposes.
“Public Property” means the exterior of any building or structure, parking lot, plaza or square, owned or
controlled by the City of Orange.
“Public Street” means and includes streets, roads, highways, alleys, sidewalks, parkways, bridges,
culverts, drains, and all other facilities and areas necessary for the construction, improvement, and
maintenance of streets and roads.
ORANGE POLICE DEPARTMENT
LAW ENFORCEMENT TRAINING BULLETIN
Dan Adams, Chief of Police
TRUST ▪ CARE ▪ COMMITMENT
"Park" means any public park or any portion thereof, including body of water, land, recreation,
playground area, or any building thereon within the City of Orange owned and maintained by the City as a
public park whether or not such has been formally dedicated for such purpose. (Of note: Community
Services also designated as part of Hart Park the City owned property west of Glassell/west of Hart Park ,
otherwise referred to as the City owned portion of the river bottom.)
ENFORCEMENT SECTIONS:
OMC 12.66.030 (A) – No person shall: Unless otherwise permitted, maintain, erect, or permit the erection
of any hut, shanty, tent, tarpaulin, or any other type of temporary structure under his control upon any
public street or public property.
OMC 12.66.030(B) – No person shall: Use public street or public property for the purpose of camping
except on public property designated by the City for such purpose.
OMC 12.48.045(A) – No person shall: Use the park for the purposes of camping, except by permit or
under the auspices of a program of the Department of Community Services.
OMC 12.48.045(B) – No person shall: Maintain, erect or permit the erection of any hut, shanty, tent,
tarpaulin, or any other type of temporary structure under his or her control in any park except with a
permit from the department or as part of an approved recreation activity.
OMC 12.48.090 - No person shall enter, be, or remain in any park during the time when such park is
closed unless he or she has obtained a permit from the Director.
POLICE REPORT PROCEDURES:
Like any police reports involving OMC violations, the definitions and enforcement language should be
used as a guide to officers when writing reports as a result of contact with a homeless person. In order to
prosecute violations (and establish evidence for a prosecutor to try the case ), a thorough description of the
violation must be documented including a detailed description of the camping observed. For example, the
type of structure/tent, clothing, bedding, and other property present. In addition, document the community
impact of camping and/or encampments and provide this information in the report. For example, the
encampment is causing some kind of public nuisance blocking a sidewalk or the camp is near a
playground or school, etc. Also include in your report that you offered assistance and/or resources and the
individual’s response.
During the initial detention, officers should gather any additional information (including basic questioning
the homeless person) to establish the OMC violation. Questions should include: a. how long the subject
has been at the location; b. does the camping property belong to him/her; c. does the person have
somewhere to live and/or obtain shelter; d. does the person have any warrants or open citations for
camping; e. has the subject been previously warned for camping in the area. Regardless of whether or not
you choose to cite, you must ask the subject if they desire assistance with resources. If the subject desires
resources, officers may still proceed with a citation (if evidence exist) and then follow protocol for
providing assistance. Please ensure BWC’s are activated during these contacts as video provides strong
evidence in court. If an arrest is to take place, officers need to be mindful of providing a Miranda warning
when necessary.
Supervisors should also tag the Bike Team in FBR for all camping reports.
TRUST ▪ CARE ▪ COMMITMENT
PROPERTY:
If the subject is taken into custody, Policy 422 covers Homeless Persons and 422.4 discusses how to
handle personal property. Officers should make reasonable accommodations to secure the property. Any
personal property, whether from an encampment or an individual, must be inventoried to identify the
personal property items and the property must be booked and held for safekeeping. If booking the property
for safekeeping is not viable, alternative options to disposition the property with the owner’s consent
should be recorded on BWC. The property shall not be left abandoned at the location. Property that is
contaminated, soiled, or infested can be discarded and not taken to the department. However, you must
capture this on the BWC so that the City can defend any allegation that you discarded an item of value.
BOTTOM LINE:
Effective immediately, officers may take enforcement action for violations of public camping municipal
codes, such as OMC 12.66.030 and OMC 12.48.045. Warnings are not required prior to taking
enforcement action, and officers may still issue a citation if the subject accepts resources and/or
assistance. Reports for these offenses must thoroughly describe the illegal camping and/or encampments
to help establish the elements of the violation.