Decisions from the Ninth Circuit Court of Appeals affect nine western states, including Montana. Two recent court decisions impact how cities can regulate camping in public spaces. In Martin v. Boise, the Ninth Circuit court held the Cruel and Unusual Punishment clause, part of the Eighth Amendment to the United States Constitution, "prohibits the imposition of criminal penalties for sitting, sleeping, or lying outside on public property for homeless individuals who cannot obtain shelter." The Ninth Circuit extended this ruling in the Johnson v. Grant's Pass opinion, stating that the Cruel and Unusual Punishment clause also prohibits criminal enforcement against homeless individuals who use "the most rudimentary precautions" a homeless person might take against the elements, such as bedding, blankets or sleeping bags.