The ACLU and the ACLU of Florida filed suit against Miami-Dade County and the Florida Department of Corrections, seeking a permanent injunction against an unconstitutional housing ordinance that is extraordinarily difficult for former sex offenders to follow without becoming homeless.

The law prohibits former offenders from living 2,500 feet (almost half a mile) from any building the county labels a "school," a category the county has enforced arbitrarily since the ordinance went into effect in 2010. This restriction has left about fifty former offenders with nowhere to live other than an outdoor area along railroad tracks on the outskirts of Miami-Dade county. This site has no drinkable water and no shelter from the weather; people sleep in chairs and small tents, and under tarps.

The squalid conditions make it extremely difficult for former offenders to find and maintain stable employment and regular psychological treatment, which are the only two factors proven to reduce the likelihood of reoffending. Decades of research show that housing restrictions like Miami-Dade's have no impact on reoffending and are more likely to increase it.

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