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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

A Society Without a Name v. Commonwealth of Virginia, 655 F.3d 342 (2011)

Citation
A Society Without a Name v. Commonwealth of Virginia, 655 F.3d 342 (2011)
Parent Document
A Society Without a Name v. Commonwealth of Virginia, 655 F.3d 342 (2011)
Effective Date
2011-08-24

Other Sections in This Document (158)

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. I give here only a brief summary of the exhaustive and detailed allegations of historical facts (many of which are substantiated by documents in the Joint Appendix) leading to the recent isolation efforts that are the gravamen of the Second Amended Complaint. ASWAN alleges that through most of the '80s and '90s, the Daily Planet provided overnight shelter, daytime residency, meals, and employment assistance services to Richmond's homeless population at the Street Center, which was located on West Canal Street downtown. ASWAN further alleges that: In 1993, the City of Richmond sold the West Canal Street location and promised to assist in finding a new site for the Street Center. The Daily Planet settled on a site on West Grace Street "in Richmond’s mainstream near VCU’s campus.” Despite a substantial grant from the United States Department of Housing and Urban Development to purchase and develop the West Grace Street site, the Daily Planet did not pursue the site because VCU and the City threatened to curtail finan*355cial support. VCU and the City conceitedly dissuaded the Daily Planet from pursuing other locations, including the City's restrictive zoning ordinances, which became the subject of a 1997 lawsuit. VCU and the City persistently urged the Daily Planet to relocate its services for the homeless on 17th Street (later renamed Oliver Hill Way). In 1997, the City adopted the Downtown Plan, which stated a policy of relocating services for homeless and other defined “street persons” away from downtown. Because of the Daily Planet’s unwillingness to accept the Oliver Hill Way location, the defendants allegedly propositioned Freedom House, another provider of homeless services in Richmond. Freedom House accepted the proposal, leased the Oliver Hill Way site from VCU, obtained from the City a special use permit to build a homeless shelter, and opened the doors of the Conrad Center on February 5, 2007. --- 010combined --- PUBLISHED