mr. kneedler. mr kneedler: justice, and may it please the court: in robinson, this court held that the government cannot criminalize status. and respondent has conceded here today that the city cannot criminalize the status of being homeless. our narrow submission in this case is that government cannot circumvent the principle of robinson by making it unlawful for a person to reside in the jurisdiction if he has that status. that is what the ordinances here do. as applied to someone who has nowhere else to sleep, which is an essential human function, the ordinances are the equivalent of making it a crime to be homeless while living in grants pass. although we think the ninth circuit was right to recognize that the core principle of robinson is implicated in this case, the court was wrong to award broad injunctive relief in the circumstances and manner in which it did. the robinson principle requires an individualized determination, and the ninth circuit's failure to require such a determination and