Airport tarmac and tiny homes: How California cities have tried to clear homeless camps

California has the largest homeless population in the country — with more than 160,000 estimated unhoused people — according to the United States Interagency Council on Homelessness. And in Sacramento shelters are often full on any given night.

A landmark ruling passed by the 9th Circuit Court of Appeals in 2018 generally prevents cities from penalizing people sleeping outside or living in tents if adequate shelter is unavailable or not offered.

California cities have struggled with how to manage homelessness since the decision, with many local governments attempting to move camps in accordance with guidance from the ruling.

Sacramento cleared a highly-visible camp on Monday, and activists questioned the move’s legality, citing the Martin vs. Boise decision.

The Bee looked at how other cities in California — including Modesto, Los Angeles and Chico — have cleared camps since the key ruling:

Modesto shelter efforts

In response to a growing amount of homeless people putting up tents outside, Modesto officials decided to ramp up sheltering efforts.

When the Boise decision first took effect in 2018, the city opened Beard Brook Park as a camp, then later closed it as it opened an outdoor emergency shelter as they planned to create more shelter beds.

In 2019, the county ordered 600 additional shelter beds to include emergency shelters, supportive housing and transitional housing throughout Stanislaus County to alleviate the number of homeless people living on the street and in camps, The Modesto Bee reported.

Venice Beach clears camp

In the summer of 2021, Venice Beach officials decided to clear out a homeless camp that had become a fixture on the city’s boardwalk. In order to do so, the city offered temporary and even permanent housing to around 200 homeless people displaced from the sweep, according to The Los Angeles Times.

“That’s why the program doesn’t end when there are no tents on the boardwalk,” L.A. City Councilman Mike Bonin wrote in an August statement from his website. “The program ends when every person has gotten into permanent housing.”

Most people from the Venice Beach sweep were placed into interim housing that included hotels and emergency shelters. In November 2021, the city of Los Angeles opened a 117-tiny-home village, which provides a transitional housing option for homeless people in the area, Business Insider reported.

Outdoor shelter in Chico

In an effort to provide homeless people living on the street a place to stay, in June 2021, Chico attempted to turn parts of its municipal airport into a shelter, according to reporting from Courthouse News Service. Officials brought in benches and gazebos for homeless people to stay the night in a sectioned off area of the airport last summer.

The city had opened the tarmac to try and legally enforce its anti-camping ban and comply with the Boise decision. It was in response to an ongoing lawsuit — Warren vs. City of Chico — filed the previous April, according to a Chico Enterprise Record timeline.

U.S. District Judge Morrison England however found that the airport site did not count as sufficient shelter and could not be used as an available housing option to cite people living on the street.

In a July 2021 ruling that sided with eight homeless plaintiffs and granted a motion for a preliminary injunction against the city ordinances, England wrote that the asphalt tarmac that lacks a roof “affords no real cover or protection to anyone.”

In this case the judge determined, though the Boise decision does not make clear a definition of shelter, it “seems to contemplate shelter will offer individuals a place to sleep ‘indoors.’”

The civil case continued until January, and the lawsuit was settled.

Sacramento officials sweep highly visible camp

Sacramento city officials cleared peoples’ belongings in a sweep of a homeless camp Monday, displacing around 30 people who lived on the publicly-owned grassy lot.

The city had been trying to find housing for some of the people living at the camp over the last few months. While some residents were able to find temporary housing before the sweep, many were left without a place to stay.

Sacramento recently leased the property to a group called the Howe/Fair Oaks Property Owners Association. Leases aren’t mentioned in the Boise decision, so it is unclear if the sweep was legal.

This story was originally published April 14, 2022 at 5:00 AM.