Last Friday marked the one-year anniversary of the Supreme Court’s landmark ruling in Grants Pass v. Johnson. The decision effectively overturned the 9th Circuit’s 2018 ruling in Martin v. Boise, which held that cities could not punish people for sleeping in public if no shelter beds were available. Grants Pass gave cities broader authority to enforce anti-camping laws, even in the absence of available shelter.
Since the Grants Pass ruling, arrests and citations of unhoused individuals have surged across California, according to a recent CalMatters analysis. Notably, even cities that did not revise their encampment policies saw increases in enforcement activity in the months that followed.
In San Francisco, arrests and citations for illegal lodging increased by 500% in the six-month period after the decision. In Los Angeles, homelessness-related arrests rose by 68%, despite no official change in policy. Mayor Karen Bass and other city leaders have repeatedly stated they prefer housing-based strategies over punitive measures.
In San Diego, citations and arrests related to homelessness doubled following Grants Pass. In Sacramento, they nearly tripled. In Stockton, the number of citations skyrocketed — growing by more than 1,400%
“It wasn’t just big cities that saw more enforcement,” CalMatters notes. “Citations and arrests increased by more than two-thirds in Ukiah, on the North Coast, and more than doubled in Merced, in the San Joaquin Valley.”
Over the past year, Governor Gavin Newsom has excoriated local governments for failing to clean up homeless encampments. But the available data shows they have stepped up enforcement — sometimes dramatically. What cities say they lack are the long-term resources to make lasting progress. That’s a challenge made even harder by the state’s new budget, which allocates no Homeless Housing, Assistance and Prevention (HHAP) funding this fiscal year and only half the usual amount in 2026–27.