This comment examines the recent Ninth Circuit case, Desertrain v. City of Los Angeles. The Ninth Circuit seeks to establish a standard that prohibits discretionary enforcement of city municipal codes against homeless people, removing one tool that cities use to keep homeless people out of public spaces. However, the court does not provide cities with an alternative policy option to police public spaces. Thus, the court's standard must work in tandem with community advocates and elected officials to achieve true change for homeless people.