Cities and towns are passing ordinances against public sleeping, sittling or lyingfaster than a politician can distort the truth. Seems nobody wants to see the homeless become too conspicuous, and since there are not enough shelters to accommodate the growing ranks of homeless, passing laws forcing the them to move on is perceived as the next best solution. A recent study found that in 187 cities surveyed 34% ban camping; 43% ban sleeping in vehicles; and 53% ban sitting and lying in public. Bans against sleeping in cars have increased 119% in the last four years. In a case filed against the city of Boise, Idaho on behalf of local homeless, the court cited a previous decision (Jones v. City of Los Angeles) that found enforcement of such ordinances to be unconstitutional in violation of the Eighth Amendment when there is inadequate shelter space because sleeping in public is involuntary and inseperable from the status of being homeless. The Department of Justice issued a statement of interest in the Boise case, saying these prohibitions may be "cruel and unusual punishment". The department told the court that 43% of homeless people slept in public in 2014. On any given night about 153,000 homeless are unsheltered.