Bobby Joe Joyce, Timothy E. Smith, Thomas O’Halloran, and Jim Tullah, homeless persons, brought an action against the city seeking a preliminary injunction against the Matrix Program that targeted violation of certain ordinances (quality of life offenses) and thus allegedly penalized homeless persons for engaging in life-sustaining activities. U.S. District Judge Lowell Jensen denied the plaintiffs’ motion for a preliminary injunction. JENSEN, J.

Plaintiffs to this action seek preliminary injunctive relief, an order to stop enforcing the ordinances, on behalf of themselves and a class of homeless individuals alleged to be adversely affected by the City and County of San Francisco’s (the “City’s”) “Matrix Program.” Institution of the Matrix Program followed the issuance of a report in April 1992 by the San Francisco Mayor’s Office of Economic Planning and Development, which attributed to homelessness a $173 million drain on sales in the City.

In August of 1993, the City announced commencement of the Matrix Program, and the San Francisco Police Department began stringently enforcing a number of criminal laws. The City describes the program as “initiated to address citizen complaints about a broad range of offenses occurring on the streets and in parks and neighborhoods. [The Matrix Program is] a directed effort to end street crimes of all kinds.” 

QUESTIONS 

1. Describe the main elements of the Matrix Program. 

2. Why did San Francisco adopt the Matrix Program? 

3. What are the plaintiffs’ objections to the Matrix Program? 

4. Assume you’re the attorney for San Francisco and argue that the Court should deny the injunction. 

5. Assume you’re the attorney for the homeless people and argue that the Court should issue the injunction. 

6. If you could, what terms would you include in an injunction in this case?