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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)

Full Text

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ASWAN alleges that a conspiracy has existed since at least
1995 to "segregate . . . homeless people and to reduce the visi-
bility of black homeless people and ADA protected people
and handicapped homeless people from Richmond’s main-
stream, its downtown," which includes VCU’s main campus
            A SOCIETY WITHOUT A NAME v. VIRGINIA               7
and the surrounding majority-white neighborhoods. But on
the required element of a conspiracy of two or more persons,
the complaint alleges nothing more specific than statements
that the "Doe(s) and the City entered into a conspiracy," that
they had a "meeting of the minds that they would act in con-
cert with VCU" to pressure the Daily Planet to relocate to Oli-
ver Hill Way, and that "Homeward was created as part of the
conspiracy and . . . became part of the conspiracy."