HomeMy WebLinkAbout2019CV30889 - Adam Wiemold V. City Of Fort Collins - 029 - Order On Appeal - Reversed And Remanded With Directions1
DISTRICT COURT, LARIMER COUNTY, COLORADO
201 Laporte Avenue, Suite 100
Fort Collins, Colorado 80521-2761
(970) 494-3800
▲ COURT USE ONLY ▲
PEOPLE OF THE STATE OF COLORADO,
Plaintiff/Appellee,
v.
ADAM WIEMOLD,
Defendant/Appellant.
Case No. 19CV30889
Courtroom: 5A
ORDER ON APPEAL: REVERSED AND REMANDED WITH DIRECTIONS
This matter comes before the Court on Defendant/Appellant Adam Wiemold’s
appeal of the Municipal Court’s denial of his Motion to Dismiss and Motion to Vacate
Conviction and Enjoin the Imposition of Any Sentence. The Court has considered the
briefs, the transcript of the hearing, and the complete record in this matter. Being fully
advised in the premises, the Court reverses the denial of the Motion to Dismiss.
I. BACKGROUND
On September 10, 2018 Mr. Wiemold (“Appellant”) was homeless. Mr.
Wiemold works full time as a supervisor of the Catholic Charities homeless shelter,
one of the two homeless shelters in Fort Collins. Appellant makes $16.00 per hour.
Appellant’s job included managing daily operations at the shelter, ensuring clients
followed the shelter’s rules, suspending people from the shelter for rule violations,
and enforcing such suspensions.
Appellant testified that he had been homeless for about two years because he
was paying off credit card debt. The record indicates that on September 10, 2018
Appellant could not stay at either of the homeless shelters in Fort Collins available to
DATE FILED: February 4, 2021 4:29 PM
CASE NUMBER: 2019CV30889
2
single men. Appellant was not able to stay at Catholic Charities because of shelter
policies. Appellant could not stay at Fort Collins Rescue Mission (FCRM) because
the shelter populations overlapped. Additionally, he could not stay at FCRM because
of fraternization rules and to avoid potentially unsafe situations. Appellant testified
that he did not ask his employer for an exception to this rule. Appellant testified that
he did not go to either homeless shelter to request a bed, nor did he look for a room
to rent. The record indicates that both shelters had reached bed capacity on the
evening of September 10, 2020.
On the night of September 10, 2018 Mr. Wiemold parked in the parking lot at
the Poudre rest area and slept in his vehicle. Appellant was asleep in his vehicle when
the Fort Collins Police Services (FCPS) officers conducted an enforcement operation
at the rest area. They did so at the request of Wesley Mansfield, a supervisor who
worked for the rest area’s owner, the Colorado Department of Transportation
(CDOT). Mr. Mansfield texted FCPS officer Chip Avinger complaining about people
who are homeless in the area and repeatedly asked officer Avinger to force the
individuals who are homeless to leave the rest area. Mr. Mansfield alleged ongoing
issues with homeless campers in the area causing damage, refuse and in violation of
the City’s prohibition of camping on public property.
Officer Avinger arranged a date and time to conduct an operation at the
Poudre rest area. FCPS officers woke Appellant up around 6:00 am and cited him for
sleeping in his vehicle. On September 11, 2018, Mr. Wiemold received a summons
for an alleged violation of Fort Collins Municipal Ordinance § 17-181 “Camping on
Public Property.” After the enforcement operation, officer Avinger sent a text
message to Mr. Mansfield informing him they had charged six people with Camping
on Public Property.
Mr. Wiemold filed a Motion to Dismiss arguing the same issues argued in this
3
appeal. The municipal court held an evidentiary hearing and denied the motion. The
court denied the claim for cruel and unusual punishment as an issue only properly
brought after conviction. The court denied the claim for selective enforcement based
on the evidence presented. The parties stipulated to a court trial. Appellant waived
his right to a full trial, and the parties stipulated to the evidence previously presented
at the motions hearing. The municipal court issued its Findings and Ruling and held
that the evidence showed that Mr. Wiemold was found sleeping in the back of his car
in 2-hour parking on public property, and that Mr. Wiemold admitted to being in his
vehicle overnight. The municipal court held that the evidence was sufficient to prove
the charge of Camping on Public Property against Appellant beyond a reasonable
doubt.
Appellant filed a Motion to Vacate Conviction and Enjoin the Imposition of
Any Sentence. Appellant argued that the municipal court should vacate his conviction
and dismiss all charges against him because issuing him a camping citation was cruel
and unusual punishment under the Eighth Amendment and the Colorado
Constitution. The municipal court issued its Order denying Appellant’s Motion to
Vacate.
Mr. Wiemold filed this appeal and asserted that the municipal court erred when
denying his Motion to Dismiss, and when it denied his Motion to Vacate Conviction.
Appellant requests this Court reverse the ruling and remand with direction to the
municipal court to vacate his conviction and dismiss the charge against him.
Appellant argues that because he was homeless and could not have stayed at
either of the Fort Collins homeless shelters, prosecuting and convicting him of this
charge violates the prohibition on cruel and unusual punishment under the Eighth
Amendment and Colorado Constitution. Appellant further argues that because the
FCPS officers went to the parking area with the plan of contacting and citing people
4
suspected of being homeless, his citation was selective enforcement by the FCPS in
violation of the Fourteenth Amendment. Appellee asserts that this case does not fall
under the reasoning of Appellant’s argued case law, and that the courts should not be
used to attempt to push policy changes as constitutional challenges. Appellee asserts
that Mr. Wiemold’s argument for cruel and unusual punishment is a facial challenge
with broad implications, and his claims cannot succeed under the facial challenge
standard. Appellee further argues that Mr. Wiemold cannot meet the requirements of
a rational basis review for the equal protection selective enforcement claim.
II. STANDARD OF REVIEW
After the final judgment of a municipal court, a defendant may appeal to the
district court within thirty-five (35) days. Crim. P. 37.1.; C.R.M.P. 237.
The trial court’s order denying Appellant’s Motion to Dismiss and Motion to
Vacate may be dependent on factual findings. People v. Mershon, 874 P.2d 1025, 1034
(Colo. 1994) (en banc). On review, this Court gives deference to the trial court’s factual
findings if they are adequately supported by competent evidence in the record. Id.; People
v. Matheny, 46 P.3d 453, 461 (Colo. 2002) (en banc). When reviewing questions of law,
the appellate court need not defer to the trial court. Id. (citing Evans v. Romer, 854 P.2d
1270, 1274 (Colo. 1993). The appellate court’s application of the legal standard to the
facts, which resolves the “ultimate constitutional question,” merits de novo review. People
v. Al-Yousif, 49 P. 3d 1165, 1169 (Colo. 2002) (en banc) (citing Matheny, 46 P.3d at 462).
Whether a punishment is in violation of the Eighth Amendment and article II, §
20 of the Colorado Constitution is a question of law and does not require deference to
the municipal court. Wells-Yates v. People, 454 P.3d 191, 204 (Colo. 2019); Melton v. People,
451 P.3d 415, 417 (Colo. 2019) (citing Mershon, 874 P.2d at 1035). When reviewing
challenges to the Fourteenth Amendment any legal issues relating to the
constitutionality of a city ordinance is decided de novo. Joel v. City of Orlando, 232 F.3d
5
1353, 1357 (11th Cir. 2000). Therefore, the Court’s review of both issues presented is
de novo.
III. DISCUSSION
a. Cruel and Unusual Punishment
The Eighth Amendment and article II, § 20 of the Colorado Constitution state:
“Excessive bail shall not be required, nor excessive fines imposed, nor cruel and
unusual punishments inflicted.” U.S. Const. Amend. VIII; Colo. Const. art. II, § 20.
Here, Appellant challenges the municipal court’s denial of his Motion to
Dismiss and Motion to Vacate and argues that when he was cited for sleeping in his
vehicle at the rest stop when he could not stay at a shelter. And, because he was
sleeping outdoors involuntarily, it is cruel and unusual punishment to criminalize his
sleeping outdoors.
Appellee argues that Mr. Wiemold never attempted to access shelter the night
he was cited. Appellee asserts that Mr. Wiemold had a vehicle, so he could access a
shelter in an alternative location, or that he had financial means to purchase shelter
and chose not to. Appellee further asserts Mr. Wiemold’s camping was therefore
voluntary.
i. Case Law Standard
Both parties rely heavily upon Martin v. City of Boise, 902 F.3d 1031 (9th Cir.
2018), cert. denied, 920 F.3d 584 (2019); Powell v. Texas, 392 U.S. 514 (1968); Robinson v.
California, 370 U.S. 660 (1962); Jones v. City of Los Angeles, 444 F.3d 1118 (9th Cir.
2006); and Joel v. City of Orlando, 232 F.3d 1353 (11th Cir. 2000). The parties also cite
to various United States District Court opinions that are related to the issues in this
case, but which are less persuasive. With no precedent in the Colorado courts, this
6
Court looks primarily to the federal cases from the U.S. Supreme Court and Courts of
Appeals.1
Appellant argues that courts have held it unconstitutional to impose a criminal
sanction on a person who is homeless for sleeping on public property when that
person could not access shelter. Appellee asserts that the Court should decline to
follow the case law supporting Appellant’s position.
In Martin, the court held that the “Eighth Amendment prohibits the imposition
of criminal penalties for sitting, sleeping, or lying outside on public property for
homeless individuals who cannot obtain shelter.” Martin, 902 F.3d at 1048. The Martin
court held that the Cruel and Unusual Punishment Clause precludes enforcement of a
statute prohibiting sleeping outside against individuals who are homeless with no
access to shelter. Id. at 1046. The Martin decision pulls much of its analysis from the
Jones, Powell, and Robinson opinions. See id. at 1046–49.
In Robinson, the defendant was convicted under a statute that made it a
misdemeanor for a person to use narcotics or be addicted to the use of narcotics.
Robinson, 370 U.S. at 662. The court distinguished between the use of narcotics being
the act of using narcotics and the addiction to narcotics being based upon condition
or status. Id. The court held that a statute that criminalizes status means a defendant
“may be prosecuted at any time before he reforms” and was unfair to a defendant
with that status. Id. at 666. The Robinson court determined that the State recognized
narcotic addiction to be an illness, one which could be contracted innocently or
involuntarily; thus, the statute at issue imposed cruel and unusual punishment by
criminalizing status. Id. at 667.
1 Rather than summarize all the numerous cases mentioned by the parties, the Court bases its findings on the most
pertinent cases. The Court finds it unnecessary to discuss each individual case that was cited, particularly those
peripheral to the analysis here.
7
The plurality opinion in Powell interpreted Robinson to prohibit only
criminalization of status and not criminalization of “involuntary” conduct. Powell, 392
U.S. at 533; Martin, 902 F.3d at 1047; Jones, 444 F.3d at 1133. The Powell opinion held
that Robinson did not deal with whether conduct can be constitutionally punished
because it is “involuntary.” Powell, 392 U.S. at 533. Justices Black and Harlan
concurred with the decision and amplified the reasoning to include that “punishmen t
for a status is particularly obnoxious, and in many instances can reasonably be called
cruel and usual, because it involves punishment for a mere propensity, a desire to
commit an offense.” Powell, 392 U.S. at 543 (Black, J., concurring). But the
concurrence agreed with the plurality opinion, as to the question of whether an act is
“involuntary” as being elusive and the court’s limitation of Robinson to pure status
crimes was proper. Id. at 544.
Justice White concurred, but alternatively reasoned that some chronic
alcoholics are also homeless and in those instances there may be no other place to
drink or be drunk except on the streets. Powell, 392 U.S. at 551 (White, J., concurring);
Martin, 902 F.3d at 1047. Justice White further explained that when the statute at issue
is applied to individuals who are homeless, and who cannot avoid public places while
intoxicated, then it was a violation of the Eighth Amendment to convict them of the
act of getting drunk. Powell, 392 U.S. at 551 (White, J., concurring); Martin, 902 F.3d at
1047. The four dissenting Justices held a position similar to Justice White’s,
determining that “criminal penalties may not be inflicted upon a person for being in a
condition he is powerless to change.” Powell, 392 U.S. at 567 (Fortas, J. dissenting);
Martin, 902 F.3d at 1048; Jones, 444 F.3d at 1133. The dissenting Justices further
addressed the involuntariness of Powell’s behavior and the obvious comparison to the
facts in Robinson. Powell, 392 U.S. at 567 (Fortas, J. dissenting); Martin, 902 F.3d at
1048; Jones, 444 F.3d at 1133–34. Accordingly, in the 4-1-4 decision, five Justices in
Powell understood that under Robinson, the Eighth Amendment prohibits the state
8
from punishing an involuntary act or condition if it is the unavoidable consequence of
one’s status or being. Martin, 902 F.3d at 1048; Jones, 444 F.3d at 1135.
Appellee argues the Court should not look to Powell for guidance because
Marks v. U.S., 430 U.S. 188 (1977), applies to the fragmented decision. Appellee
argues that Powell changes nothing and Robinson should be relied on to address these
issues. However, Appellee’s reasoning is flawed. The Marks court held when a
fragmented court decides a case and no single rationale explaining the result has the
agreement of five Justices, the holding may be viewed as the position taken by those
Justices who concurred in the judgment on the narrowest grounds. Marks, 430 U.S. at
193 (citing Gregg v. Georgia, 428 U.S. 153, 169 n. 15 (1976)). The direct application of
Marks would essentially render the Powell decision useless as precedent. However, a
strict reading of Marks suggests the assent of five Justices supports the majority
Justices’ reasoning. Although Justice White’s concurrence and the dissents did not
share complete agreement, the reasoning they did agree upon should be considered a
majority, and thus persuasive.
Both the Ninth and Fourth Circuits discussed Powell in detail and concluded
that Justice White’s concurring opinion was highly persuasive. Martin, 902 F.3d at
1047–48; Jones, 444 F.3d at 1133–36; Manning v. Caldwell, 930 F.3d 264, 281–84. The
court in Manning determined it would not ignore the reasoning by Justice White,
because his opinion was shared by four other Justices and provided important
reasoning for cases related to individuals who are homeless. Manning, 390 F.3d at 282.
Justice White made clear that although he voted to affirm Powell’s conviction it was
not because of the act-status theory in the plurality opinion, but solely because Powell
failed to produce facts to establish involuntariness of his public alcoholism. Id. Similar
to the mentioned cases, this Court does not simply set aside the Powell opinion, but
adopts the interpretation of the five Justices in Powell as persuasive authority.
9
Appellee argues that Joel held that the ordinance at issue did not violate the
Eighth Amendment because of the conduct/status distinction. Joel v. City of Orlando,
232 F.3d 1353 (2000). In Joel, the defendant argued that the ordinance at issue
punished persons as a result of their status of being homeless. Joel, 232 F.3d at 1361.
Joel argued that the Robinson case supported this argument, as does Pottinger v. City of
Miami, 810 F.Supp. 1551 (S.D.Fla. 1992) and Johnson v. City of Dallas, 860 F.Supp. 344
(N.D.Tex. 1994). Id. at 1361–62. The court held that the reasoning in Pottinger and
Johnson specifically relied on the lack of sufficient homeless shelter spaces, and those
courts reasoned that sleeping in public was involuntary for those who could not get
shelter. Id. at 1362. The court further determined that, if it followed the reasoning
from Pottinger and Johnson, the Joel case is clearly distinguishable because the ordinance
does not criminalize involuntary behavior; Joel had an opportunity to comply with the
ordinance. In Joel, the court reasoned that the plurality opinion in Powell supported
that the ordinance in Joel targeted conduct and did not punish based on status. Id. The
Joel court’s reasoning clearly recognized Pottinger and Johnson but held that these cases
did not apply to Joel because the city demonstrated that the homeless shelter had
never reached maximum capacity. Because of this difference in facts, the cases Joel
presented in his argument were not particularly persuasive.
Under the above analysis, the state cannot criminalize the consequence of one’s
status of being homeless. This Court must therefore consider the distinction between
an involuntary act or condition and a voluntary one.
ii. Involuntary
The Eighth Amendment prohibits the state from punishing an involuntary act
if it is the unavoidable consequence of one’s status or being. Jones, 444 F.3d at 1135.
The consensus among the Fourth, Ninth and Eleventh Circuits is that the Eighth
Amendment prohibits criminal penalties for sleeping outside on public property for
those individuals who are homeless who cannot obtain shelter. Manning, 930 F.3d 264;
10
Jones, 444 F.3d 1118; Martin, 902 F.3d 1031; Joel, 232 F.3d 1353. Additionally, a
multitude of Federal District Courts have utilized Robinson, Powell, and Jones to
determine that, without available shelter space, criminalizing camping is criminalizing
involuntary conduct. Pottinger, 810 F.Supp. at 1564 (holding that arresting the
homeless for involuntary acts such as sleeping in public is cruel and unusual); Johnson,
860 F.Supp. at 350 (“as long as the homeless have no other place to be, they may not
be prevented from sleeping in public . . . but as long as homeless persons must live in
public, their sleeping may not be constitutionally criminalized”); Cobine v. City of
Eureka, 250 F.Supp.3d 423, 432 (N.D. Tex. 2017) (holding that the factual record
must establish that there was no available or adequate homeless shelter space for the
camping ordinance to be criminalizing involuntary conduct as a result of
homelessness); Anderson v. City of Portland, Civ. No. 08–1447–AA, 2009 WL 2386056,
at *7 (D. Or. July 31, 2009) (holding that people who are homeless cannot access
shelters for various factors and to enforce anti-camping ordinances criminalizes them
for being homeless). Courts have held that when individuals who are homeless cannot
obtain shelter, criminalizing sleeping violates the Cruel and Unusual Punishment
Clause. Jones, 444 F.3d 1136.
The Jones court held that involuntary conduct and status are inseparable,
specifically as it relates to humans who are biologically compelled to rest, whether that
be sitting, lying, or sleeping. Id. The Martin court held that a municipality cannot
criminalize behavior consistently with the Eighth Amendment when no space is
available in any shelter. Martin, 902 F.3d at 1048. Involuntary behavior cannot be
criminalized under the Eighth Amendment; this Court must therefore determine
whether Appellant’s inability to stay at a shelter on September 11, 2018 was
involuntary.
Appellant argues that he had no choice except to sleep outdoors on the
morning he was cited. Appellant asserts because of his employment at Catholic
11
Charities he could not stay at either homeless shelter in Fort Collins that accepts adult
men. Appellant further asserts that both Fort Collins shelters were full that night.
Appellee argues that Mr. Wiemold’s camping was voluntary. Appellee asserts
that Mr. Wiemold was employed full time with a working vehicle and was camping to
get out of debt, therefore was voluntarily camping. Appellee asserts that Mr. Wiemold
chose an employer who prohibits him from accessing the Fort Collins shelters.
Appellee asserts Mr. Wiemold had choices he chose to ignore, for example, he could
drive to Loveland and say at a shelter there or drive a mile or two outside of Fort
Collins and legally camp there. Appellee asserts that Appellant had a variety of options
and instead voluntarily chose to camp illegally.
Appellant is a shelter supervisor at Catholic Charities. Appellant’s supervisor,
Joe Domko, the regional director of Catholic Charities of Larimer County, confirmed
that many people who stay at Catholic Charities also stay at the other shelter in Fort
Collins. Mr. Domko confirmed that all employees, including Appellant, are given a
copy of the Employee Handbook. He testified that the fraternization policy was in
effect at Catholic Charities when Appellant was cited for camping. Policy 3.24 in the
employee handbook, “Fraternization with Clients/Boundaries,” states, “Staff may
only interact with clients at the Agency itself or at the Agency-sponsored activities,
only during the staff person’s assigned working hours, and only within the scope of
the employee’s job description.” Ex. 8, Catholic Charities Employee Handbook pg.
28.
Mr. Domko further testified that the night of September 10, 2018, Catholic
Charities’ shelter was full. The report shows the shelter was at one hundred percent
capacity, and that same report indicates that FCRM was also full but had not yet
turned away any clients. Mr. Domko testified that when people are turned away from
Catholic Charities, they are directed to FCRM if FCRM has capacity.
12
Appellant testified that when he was cited, he had been working for Catholic
Charities for four years. He testified that he could not stay at either Fort Collins
shelter on the night he was cited because of the fraternization policy. Appellant
indicated that staying at either shelter would implicate safety concerns. Appellant
testified that, as a shelter supervisor he had to ensure rules were being followed and
suspend people who failed to follow the rules. Appellant testified he has suspended
between one to two people per week during his time as a shelter supervisor. Because
on these suspensions, Appellant testified that staying at FCRM could be unsafe if he
were to encounter a person he had suspended from Catholic Charities.
On cross examination, Appellant testified that when he was cited, he had
continuous employment and no dependents to support. Appellant testified that he
had excessive debt and could not afford to both pay his credit card bills and pay for
housing. Appellant testified that he had too much pride to declare bankruptcy and he
didn’t want to stop paying his credit card bills and risk going into collections.
Appellant testified that if he stopped paying his credit card bills, he could afford an
apartment or room to rent. Mr. Wiemold testified that he was able to pay off $10,000
over two years by camping. Appellant testified that he did not seek low income
housing and he did not try to go to a nearby shelter in Loveland or another nearby
city. Appellant testified that he searched for a room on Craigslist and could not find
an affordable option, and that he had stopped looking for a room by September 2018.
Mr. Wiemold testified that he could only afford to stay in a hotel or motel about twice
a week or twice a month. Further, Appellant testified that he did not look for a
different job, and he did not ask his boss for an exception to the fraternization rule to
allow him to sleep at one of the Fort Collins shelters.
Appellee asks the Court to make a subjective decision as to whether Appellant
could afford shelter. The Martin court held that its decision did not apply to people
who choose not to use temporary shelter they can pay for or shelter available for free.
13
Martin, 920 F.3d at 617. Appellee provides no case law to support an in-depth analysis
of the factors a court should apply to determine voluntary homelessness. With no case
law to support a decision about consideration of individual personal factors that
attribute to homelessness, the Court will not consider whether Mr. Wiemold made
valid choices here.
Appellee asks the court to consider Appellant’s choices under the dictionary
definition of “involuntary.” The Court looks to the case law to determine what is
“involuntary” as it relates to individuals who are homeless under the Eighth
Amendment. The holding in Martin is clear if there is no access to shelter, people who
are homeless cannot be presumed to have a choice in the decision to sleep outdoors.
Martin, 902 F.3d at 1048. In Jones, the court held that an individual may become
homeless based on factors both within and beyond his immed iate control. However,
just because Appellant may be able to obtain shelter on some nights or eventually
escape homelessness altogether does not render his status at the time of citation to be
any less worthy of protection. Jones, 444 F.3d at 1137.
There is no dispute that the Catholic Charities shelter and FCRM shelter were
both at capacity on the night Appellant was cited. Further, the record shows that, due
to Mr. Wiemold’s employment, it would not have been practicable, realistic, or safe
for Appellant to stay at one of the Fort Collins shelters. The Court declines to impose
subjective determinations about whether Mr. Wiemold’s personal factors led to a
volition to remain homeless. The case law is clear that shelter availability determines
the standard of voluntary or involuntary homelessness. The Court concludes that
shelter was unavailable to Appellant on the night he was cited, and thus his
homelessness was involuntary.
14
iii. As-applied vs. Facial Challenge
Appellee argues that Appellant’s Eight Amendment claim is a facial challenge,
not an as-applied challenge. Appellee argues that Mr. Wiemold has brought his appeal
under his individual circumstances but seeks relief that is much broader. Appellee
argues that Mr. Wiemold seeks a decision that would determine that camping for
people who are homeless is always involuntary, so anytime the Fort Collins shelters
are full the camping prohibition is unenforceable. Appellee argues that Appellant’s
constitutional challenge specifically asks the Court for a decision that will carry legal
effects beyond only Mr. Wiemold which makes this a facial challenge.
Appellant asserts that he is not arguing that the ordinance is always
unconstitutional, only that it is unconstitutional as applied to his circumstances. Mr.
Wiemold asserts that under his particular circumstances there was no shelter available
to him in Fort Collins, so it would be unconstitutional to impose a criminal sanction
against him for camping at the rest area. Appellant asserts there is likely no other
employee at the shelter who is also homeless, so the Court’s decision would be
confined to only his circumstances.
The difference between a facial challenge to the constitutionality of a statute
and an as-applied challenge is that an as-applied challenge asserts that the statute
would be unconstitutional under the circumstances specific to an individual. Sanger v.
Dennis, 148 P.3d 404, 410 (Colo. App. 2006). When a statute is held unconstitutional
as-applied, that statute may be applied to the specific challenge but is otherwise
enforceable and could be applied in the future in a similar context. Id.; Minnesota
Majority v. Mansky, 708 F.3d 1051, 1059 (8th Cir. 2013). A facial challenge alleges that
there are no circumstances when the statute can be applied constitutionally. People v.
Trujillo, 369 P.3d 693, 697 (Colo. App. 2015).
15
Appellee argues this case provides a gray area between a facial challenge and an
as-applied challenge. The Court disagrees. Appellant has brought this case alleging
that based on his unique circumstances, the citation of public camping is
unconstitutional as applied to him. The facts here would likely not apply to other
individuals who are homeless in Fort Collins who would have access to either shelter
in Fort Collins. Appellant does not argue that this statute is unconstitutional as to all
individuals who are homeless each time they do not have access to shelter in Fort
Collins. Based on the facts specific to this case and Mr. Wiemold’s inability to stay at
the shelters because of his job, the Court finds his claim to be a constitutional
challenge as-applied to the Appellant specifically.
b. Selective Enforcement in Violation of the Fourteenth Amendment
Appellant argues that when he received his citation, the officers intentionally
targeted and enforced the camping ordinance against only individuals who are
homeless. Appellant argues this was selective enforcement and violates the Fourteenth
Amendment. Appellant argues the evidence shows that the officers’ enforcement at
the rest area was intentionally aimed at the individuals who are homeless parked at the
rest stop and not the vehicles parked in the truck parking lot. Appellant argues there
is no rational basis for the officers to selectively target him or the people who are
homeless inside their vehicles while not enforcing the ordinance against the truck
drivers who engaged in the same activity.
Appellee argues that Mr. Wiemold has failed to show there is a discriminatory
effect. Appellee asserts that the evidence does not establish that all of the other
individuals cited were homeless, and there is no evidence to establish that there were
similarly situated individuals who were not cited. Appellee notes that Mr. Wiemold
testified that he could not be sure whether any trucks were present in the truck lot
when he went to sleep and still there when he woke up. Appellee further argues the
16
parking lots are separate with different regulations, hence the trucks parked in the truck
lot were not similarly situated. Appellee asserts there is an obvious rational basis to
enforce in the car lot because the increase of problems and damage in the car parking
lot and conditions of the rest area. Appellee argues because the record does not
establish these facts, Mr. Wiemold cannot prove a claim for selective enforcement
under the Fourteenth Amendment.
Given the Court’s decision on the Eighth Amendment above, the Court
need not address the Fourteenth Amendment argument.
IV. CONCLUSION
The Court finds that the hearing officer’s decision was erroneous. On appeal
the Court REVERSES the decision of the Fort Collins Municipal Court. The Court
REMANDS the matter to the municipal court and directs that Appellant’s Motion to
Vacate be granted and Mr. Wiemold’s charges be dismissed.
SO ORDERED.
Dated: February 4, 2021.
BY THE COURT:
Julie Kunce Field
District Court Judge