Vannucci v. County of Sonoma

Background

The defendants moved for summary judgment on standing. Standing is the requirement that a plaintiff show a legally sufficient injury that the court can address. The order concerns whether Juanita Butterfly and Homeless Action! had established standing at the summary-judgment stage.

Juanita Butterfly’s Standing

The court held that Butterfly had standing to seek injunctive relief, meaning court orders requiring or prohibiting future conduct. She presented evidence that she was homeless, that defendants had taken her belongings during encampment sweeps, and that she had sought and been denied disability accommodations, including non-congregate shelter.

Although defendants argued that Butterfly’s belongings had sometimes been stored rather than discarded and that she had previously been offered non-congregate shelter, the court noted evidence that her belongings were thrown away three times—in November 2024, April 2025, and May 2025—and that she requested and was denied accommodations during an April 2025 stay at Sam Jones Hall. The court found this evidence sufficient to support a high likelihood of future injury. It also noted that defendants presented no evidence showing how Butterfly’s earlier shelter rule violations affected their present ability to provide accommodations.

Homeless Action!’s Organizational Standing

The court described Homeless Action!’s standing as a very close question but held that the organization had established standing at this stage.

Homeless Action! asserted two types of organizational injury. First, it claimed that it diverted volunteer time from activities such as community education and advocacy to respond to encampment sweeps. The court held that this injury was no longer legally sufficient, citing the rule that an organization cannot create standing merely by spending money or gathering information to oppose a defendant’s conduct.

Second, Homeless Action! argued that defendants’ actions directly interfered with its core activities, including providing resources and support to unhoused residents. The court held that this type of direct organizational injury remained legally sufficient under the cited precedent.

The court identified two uncertainties. First, the evidence was mixed about whether direct services were among Homeless Action!’s core activities before the sweeps began around 2017. Declarations described outreach and direct assistance before that time, but Homeless Action! had also stated that it shifted from advocacy toward emergency monitoring and efforts to stop the sweeps in response to defendants’ actions. The court found a genuine dispute of fact on that issue.

Second, the court was uncertain how much the requested injunction would address Homeless Action!’s injury. After the Supreme Court’s decision in Grants Pass, the plaintiffs were no longer seeking to stop all encampment sweeps. They instead sought orders concerning seizure of property without notice, placement of people in more dangerous locations, and denial of reasonable disability accommodations in shelter placements and other homelessness-related services. The court found some evidence that the requested relief would at least partly help Homeless Action!, but expressed skepticism that the organization could ultimately prove meaningful redress at trial.

Americans with Disabilities Act Claims

Defendants also argued that Homeless Action! could not pursue the Americans with Disabilities Act claims because the organization was not itself a qualified individual with a disability. The court rejected that argument at this stage. Under current Ninth Circuit law, the organization could sue on its own behalf if it established a direct organizational injury, and the court concluded that Homeless Action! had narrowly done so.

Disposition

The court denied defendants’ motion for summary judgment on standing. The order did not state that the court had resolved the underlying claims on their merits. Because the court ruled on a summary-judgment motion, this opinion is classified as a substantive ruling under the stated classification convention.