COMPLAINT TO U.S. DEPARTMENT OF JUSTICE OVER CITY OF HONOLULU'S CRIMINALIZATION OF HOMELESSNESS (2015)

Supporting documents and appendices:

• Appendix A – Complaint for Declaratory Relief and Damages
• Appendix B – MPI and Memo
• Appendix C – Client and Witness Decls.
• Appendix D – Depositions
• Appendix E – Honolulu Star-Advertiser Articles
• Appendix F – Letter from ACLU and Response
• Appendix G – Letter from ACLU and Response

From the complaint: “The ACLU of Hawai‘i seeks to end the City’s practice of violating the constitutional rights of Honolulu’s homeless residents. The ACLU is aware that the Department of Justice has a keen, present interest in preventing “unconstitutional and abusive policing”; ensuring that “justice is applied fairly regardless of wealth or status”; “breaking the cycle of poverty”; and preventing the “criminalization of homelessness.”203 The ACLU acknowledges and appreciates that the Department of Justice has recently intervened in at least one analogous scenario in which local government effectively criminalized homelessness in violation of the Eighth Amendment.204.

The ACLU respectfully requests that the Department of Justice investigate the
claims of Honolulu’s homeless residents and order the City and County of Honolulu to cease its unconstitutional policies and practices.”