After Patrick McArdle’s eighth arrest in early 2019 for sleeping on public property in Ocala, Florida, he could no longer accept the injustice of being arrested merely because he was unhoused. When he was unable to make bond, he decided to spend his time in jail in the library, researching constitutional caselaw about sleeping ordinances. When he stumbled upon Martin v. Boise, he felt vindicated — he was now sure the City’s efforts to arrest and incarcerate unhoused residents in Ocala for sleeping outside were, like Boise’s, in violation of the Eighth Amendment’s prohibition against cruel and unusual punishment.