38 McGeorge L. Rev. 195 (2007)
Chapter 794: A Qualified No to the Practice of Homeless Dumping

handle is hein.journals/mcglr38 and id is 215 raw text is: Health and Safety
Chapter 794: A Qualified No to the Practice of Homeless
Megan M. Moore
Code Section Affected
Health and Safety Code § 1262.4 (new).
AB 2745 (Jones); 2006 STAT. Ch. 794.
In late December 2003, a deaf and mute homeless man with a disfigured
hand and only one eye was discharged from a Roseville psychiatric facility.' No
homeless shelters existed in Placer County at the time, so the facility had
nowhere to place the man.2 Sometime later that day, he climbed out of a Placer
County vehicle in front of Loaves and Fishes, an organization located in
Sacramento that aids the homeless.3 When the man realized where he was, he
attempted to return to the vehicle, but the driver locked the doors and drove
Two years later, Loaves and Fishes experienced a similar episode.5 This time,
the person arrived in a taxi-cab after a 101-mile journey from Barton Memorial
Hospital, located in El Dorado County.6 The woman, who suffered from
cirrhosis7 and was in the end stages of alcoholism, could barely walk after
consuming a pint of alcohol during her journey.8 El Dorado County, like Placer
County, had no shelters in which to place the woman, so they sent her to
These stories describe two of the more egregious examples of a common
practice in California and what those in the field call dumping.' Dumping
occurs when a hospital in a county without homeless services sends a discharged
1. Jocelyn Wiener, Is Placer Dumping Homeless?, SACRAMENTO BEE, Feb. 22, 2004, at B 1.
2. Id.
3. Id.; Letter from Tim Brown, Exec. Dir., Sacramento Loaves & Fishes, to Assembly Member Wilma
Chan, Cal. State Assembly (Apr. 19, 2006) [hereinafter Loaves & Fishes Letter] (on file with the McGeorge
Law Review).
4. Loaves & Fishes Letter, supra note 3.
5. Jocelyn Wiener, Under Fire for Lack of Shelter, SACRAMENTO BEE, Dec. 17, 2005, at Al.
6. Id.
7. See WEBSTER'S COLLEGE DICTIONARY 247 (1996) (defining cirrhosis as a chronic disease of the
liver in which fibrous tissue invades and replaces normal tissue, disrupting important functions, as digestion and
8. Wiener, supra note 5, at Al.
9. Id.
10. Loaves & Fishes Letter, supra note 3.

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