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Not Guilty by Reason of Poverty:

A Position Paper on the Decriminalization of Poverty

Deborah Rutherford

Southern New Hampshire University

SOC324: Sociology of Crime and Violence

Professor Amanda Eaton

April 7, 2024
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Not Guilty by Reason of Poverty: A Position Paper on the Decriminalization of Poverty

Introduction

Overview

In 2011, a woman in Maine got a routine speeding ticket. She was unable to get time off

work to contest it and did not have the money to pay for it. She had no family around except her

two kids under two and their father, who was himself an unemployed student. Without a work-

able solution to resolve the ticket, her license was suspended. However, she lived in rural Maine

and needed to work, so she continued driving. She kept getting caught. Multiple suspensions led

to a three-year habitual offender revocation. Since she could no longer get her kids to daycare,

she was only able to work limited hours at minimum-wage jobs near home. After the revocation

was up, she resumed driving, but was pulled over for a headlight and found that she had missed a

reinstatement fee, leading to another suspension. This time, the state imposed an alternative sen-

tence of five-day residential community service; however, they wanted a $500 fee for it. Unable

to pay the fee, she took the ten-day jail sentence. A simple speeding ticket had turned into a

years-long ordeal, with multiple suspensions, thousands of dollars in fines, incarceration, and a

criminal record, all because she was poor.

This is the criminalization of poverty. State and local governments make and enforce

policies that "trap people in the criminal legal system for engaging in activities to survive" (Vera

Institute of Justice, 2022). Whether they are being arrested for sleeping in public, being stigma-

tized applying for benefits, or sitting in jail because they could not afford bail or a fine, America

has made it a crime to be poor (Ehrenreich, 2011).

That woman in Maine was me. The research assistant position at Golden Door Advocacy

was a perfect fit because their work to decriminalize poverty is a cause that means something to
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me personally. According to the United States Census Bureau’s official poverty measure in

2022, 37.9 million Americans would agree (Shrider & Creamer, 2023). What was originally a so-

cial problem has turned into a legal problem. Millions of people across the country are economi-

cally insecure and being forced to make choices between food, housing, medical care, and utili-

ties.

There are multiple factors that combine to form and perpetuate the culture of poverty. To

truly effect change, we must be cognizant of these factors and identify their roots. One explana-

tion of the American poverty cycle lies in conflict theory. Developed in the 1960s by Karl Marx

and Friedrich Engels, conflict theory states that laws exist to "maintain the interests of specific

groups who hold political power" (Zembroski, 2011, p. 249). This theory says that it is the strug-

gle over resources, especially power, which creates class distinctions, leading to a divide be-

tween those who hold the power and those who do not. The ruling class therefore has the power

and means to exploit the working class and to criminalize actions they believe to be a challenge

to their preferred way of life (Nickerson, 2023). This is then enforced by social institutions, such

as the police, courts and prisons, and the welfare system, and has significant implications for

housing and employment.

Evidence

Through analysis of stereotypes, social changes, and historical and modern views of

poverty, Golden Door Advocacy focuses on four major areas: homelessness, welfare reform,

court fees and fines, and mass incarceration. From debtors’ prisons in colonial days, to the Fer-

guson, Missouri, police department’s revenue-generating methods, to over 7,000 New Yorkers

sitting in jail “because they are poor, not because they are guilty” (Monea, 2022, p.4), the crimi-

nalization of poverty in America is not a novel concept.


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Position Statement

It is the belief of Golden Door Advocacy that the criminalization of poverty, or "state-

sponsored efforts at enforcement, surveillance, labeling, and punishment" (Pager et al., 2022, p.

531) has produced intrusive and unfair public policies that marginalize and penalize people for

being poor. This is unjust and wrong. Golden Door Advocacy aims to change the criminalization

of poverty through legal advocacy, policy advising, research, and case management.

Analysis

Position

Nelson Mandela said that "a nation should not be judged by how it treats its highest citi-

zens, but how it treats its lowest" (as cited in United Nations, n.d.). Class stratification based on

economic status effectively separates American citizens into these highest and lowest groups,

Karl Marx’s bourgeoisie and proletariat classes respectively (Nickerson, 2023). The evolution of

class stratification throughout the history of the country has widened this divide through stereo-

types, policies, ordinances, and laws. Many of these are unfounded and unfair but are continually

enforced as the economy continues to decline (Ehrenreich, 2011).

The National Law Center on Homelessness and Poverty found in 2017 that over half of

the 187 cities they studied had bans on camping and sitting or sleeping in public, and more than

two-thirds enforced bans on loitering and begging (Herring et al., 2020). Between 2006 and 2016

alone, nationwide bans on living in a vehicle rose by 143 percent (Herring et al., 2020). Welfare

recipients were at one time subjected to “midnight raids” (Gustafson, 2009, p. 649) to “catch

men sleeping in the homes of women receiving welfare” (p. 649). It was assumed that an unmar-

ried woman sleeping with a man was not morally suited to receive welfare benefits. The court

system has used fees and fines to trap people in cycles of nonpayment, creating criminal records
5

and extending their involvement with the criminal justice system for years longer than is neces-

sary. Sociologists have referred to these practices as “permanent punishment” (Pager et al., 2022,

p. 530) and “layaway freedom” (p. 530). Many social science studies have found direct, quantita-

tive correlations between mass incarceration and homelessness. The decrease in funding for pub-

lic housing and simultaneous increase in corrections funding ensured that the prison system has

become the “primary provider of affordable housing” (Herring et al., 2020, p. 132) in the coun-

try.

Stereotypes

When confronted with statistics such as these, one might wonder how the country

became so economically divided. Part of the answer lies in stereotypes of the poor that have per-

sisted throughout history. Typical stereotypes of people experiencing poverty include images of

dirty, diseased street people, often dangerous and involved in crimes such as theft or prostitution

(Amster, 2003). Also implicit in stereotypes of poor people is their helplessness or victim status

(Kawash, 1998). Different studies have found these same stereotypes in the media as well, noth-

ing that the media shows "the underclass in behavioral terms as criminals, alcoholics, and drug

addicts" (Clawson & Trice, 2000, p. 54). A study of a Washington Post series on poverty found

representations of the poor as "lazy, sexually irresponsible, and criminally deviant" (Clawson &

Trice, 2000, p. 54).

Stereotypes also extend to racial characteristics. A study conducted on five magazines,

Business Week, Newsweek, New York Times Magazine, Time, and U.S. News & World Report,

analyzed portrayals of the American poor over a five-year span (Clawson & Trice, 2000). The

study found that in the media, African Americans were depicted as making up 49% of the poor,

but according to census data, the real figure was 27%. In contrast, white people were depicted as
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making up 33% of the poor, but the data showed the real figure was 45% (Clawson & Trice,

2000). The study also found that when there were stories on unpopular issues, such as welfare re-

form, pregnancy, public housing, and the welfare cycle of dependency, blacks were overrepre-

sented in the news stories (Clawson & Trice, 2000).

There is also the oft-cited "welfare queen" stereotype. Media and literature portrayals

show the welfare queen as someone who milks the system using taxpayer money, has children to

get more benefits, will not marry to keep those benefits, is lazy and uneducated, and refuses to

get a job and come off welfare (Gustafson, 2009). Guy Drake, in his 1970 song “Welfare Cadil-

lac” sings “I’ve been poor all my life, I guess all I really own is ten kids and a wife,” “I sure

don’t pay no rent, I get the check the first of every month from this here federal government, and

“we get peanut butter and cheese, and man, they give us flour by the sack, course them welfare

checks, they make the payments on this new Cadillac” (Drake, 1970). Lyrics like these promote

the stereotype of welfare recipients as ungrateful people who have no moral qualms about taking

taxpayers’ hard-earned money.

The original “welfare queen” stereotype came from the Chicago Tribune’s coverage of

Linda Taylor in 1974 (Kohler-Hausmann, 2007). The media thoroughly covered this case, which

stunned Taylor's hometown of Chicago as well as the entire nation. Linda Taylor was charged

with welfare fraud after receiving over $200,000 in benefits through illegal means, including

multiple aliases and identities in twelve different states. These benefits included welfare cash as-

sistance, food stamps, and social security benefits (Kohler-Haussmann, 2007). During Taylor’s

prosecution, the Chicago Tribune ramped up the public view of welfare recipients by publishing

the hotline number where people could report cheaters, as well as the names of people being

charged with welfare fraud, effectively identifying and humiliating them. Evidence that this
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worked is seen in the numbers; in 1977, this hotline received 10,047 calls, and over 30,000 be-

tween 1977 and 1980 (Kohler-Haussman, 2007).

It is also clear that these stereotypes were rarely valid. Most people did not have a clear

understanding of what constituted welfare fraud and mainly called in tips about “the more tradi-

tional targets of state sanction, such as morally stigmatized unmarried mothers” (Kohler-Hauss-

man, 2007, p. 339). Only 3,400 welfare cases were affected after investigation, meaning the ac-

tual rate of fraud as reported by the hotline was about 10%. One anonymous letter sent to a state

senator reported that their neighbors had many children, and both worked and received welfare

benefits. Whoever wrote the letter stated that their neighbors spent money on clothes, pets, and

toys, indicating that they took offense to the family buying and possessing more than necessities.

When officials investigated the situation, they found that the family in question had not received

public assistance for over a year (Kohler-Haussman, 2007).

Historical Interpretations

Throughout history, these stereotypes have evolved. Early colonial poor laws were de-

rived from English common laws, which indicated that communities needed to help their mem-

bers that were struggling (Katz, 2013). However, there was interest in separating the people who

genuinely needed help and those who were just lazy and entitled, creating Marx’s bourgeoisie

and proletariat classes. Josiah Quincy, the eventual president of Harvard University and mayor of

Boston, wrote in 1821 of the two classes of poor people. He labeled one class "the impotent

poor," (Katz, 2013, p. 5) referring to infants, the elderly, and the sick and disabled who could not

work. The second class was what Quincy called the "able poor," (Katz, 2013, p. 5) or those who

could work, but had varying degrees of capability and could only do certain jobs. No one had

any issue helping the impotent poor, but they thought it wasteful and unnecessary to spend
8

money on people who had the ability to make their own. In 1834, the Reverend Charles Bur-

roughs, preaching in New Hampshire, also spoke of two distinct categories of poor people. He

distinguished between the poor and paupers, saying that poverty was an “unavoidable evil"

(Katz, 2013, p. 6) while pauperism was "the consequence of willful error, of shameful indolence,

of vicious habits” (Katz, 2013, p. 6). This notion that poverty is a result of moral failure has per-

sisted today.

British poor laws also allowed lenders to imprison people who owed them money. The

custom of debt imprisonment followed new Americans to the colonies (Monea, 2022). As

colonists amassed more wealth and credit, debtors’ prisons became more popular. A citizens'

group in Philadelphia stated that 3,001 people were imprisoned for nonpayment of debt between

1826 and 1830. Because people in prison had no way to pay their debts, they often stayed in

prison while their families on the outside suffered from the loss of income (Monea, 2022). Paral-

lels to these policies can still be seen today. While physical buildings of debtors' prisons are no

more, the concept is still embedded in American society “in the form of pre-trial confinement,

incarceration for court fees and fines, and excluding various forms of debt-such as alimony, di-

vorce, child support, and taxes-from constitutional protection" (Monea, 2022, p. 4). This shows

how historical principles and attitudes toward the poor have shaped modern-day policies. From

the distinction between poverty and pauperism, to debt imprisonment, to welfare monitoring, this

country has devised numerous ways to criminalize poverty (Gustafson, 2009). Turning perceived

moral failure into public policy denotes an attitude and class distinction that colors even modern

interpretations of the issue.

Modern Interpretations
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In more modern times, economic, political, and social systems continue to place undue

burdens on marginalized communities. This leads to the police finding justifications for their

over-policing and over-incarcerating of poor people (Kohler-Hausmann, 2007). Jails have

consequently become overcrowded homeless shelters. From 1980 to 1990, spending for

affordable housing decreased from $27 billion to $10 billion, while spending for corrections

increased from $7 billion to $26.1 billion (Herring et al., 2020). Incarceration only leads to

higher rates of homelessness. People with criminal records are routinely excluded from housing,

whether private or subsidized, and from gainful employment. They are also more likely to

commit crimes out of desperation or immediate need, leading to over-policing of neighborhoods

where homelessness is concentrated (Herring et al., 2020). As a result, police contact is

heightened over enforcement of restrictions on “standing, sitting, and resting in public spaces”

(Herring et al., 2020, p. 133) during the day, and restrictions on “sleeping, camping, and lodging,

including in vehicles; begging and panhandling; and food sharing” (p. 133).

The welfare reforms in the 1970s also extended the reach of the criminal justice systems

into the lives of poor people. The 1935 Social Security Act implemented ADC, or Aid to

Dependent Children (Kohler-Hausmann, 2007). Along with this program, however, came

monitoring, tightened eligibility requirements, and rules to publicly shame welfare recipients,

such as requiring them to pick up their checks at police stations or banks rather than mailing

them to individual homes (Kohler-Hausmann, 2007). Another invasive policy took place as late

as the 1960s. Welfare offices took to performing midnight raids on ADC recipients to see if the

unmarried women receiving benefits had men in the house; if so, welfare was revoked and the

men were considered “household breadwinners who had hidden their income support from the

aid office” (Gustafson, 2009, p. 649). The Supreme Court decision in King v. Smith (1968) lifted
10

this designation from the men, but that only served to shift all stigma and blame to women.

Americans continued to see welfare recipients as lazy and entitled, and officials, wanting to be

tough on the issue, increased prosecutions for welfare fraud. Investigations of overpayment were

shifted from social service agencies to district attorneys. In 1996, the Personal Responsibility and

Work Opportunity Reconciliation Act ended the ADC program and cash aid. Replacing ADC

benefits were state block grant programs called Temporary Assistance for Needy Families

(TANF). People who were not aware of how the new system worked could receive a sanction for

something as little as missing an appointment, which resulted in the loss of aid. The

administration of TANF programs was also left up to the states, as opposed to the federally

administered ADC program (Desmond, 2023). This means states can decide how they use the

money, and not every state has used it for poor people. For example, Arizona has used TANF

money to fund abstinence-only sex education, Pennsylvania has used it for anti-abortion

pregnancy centers, and Maine has used it to fund a Christian summer camp. In 2020, for every

dollar allotted to TANF, “poor families directly received just 22 cents” (Desmond, 2023, p. 4).

Ironically, money is withheld in this way from people who need it the most, but in other

places they become the ones exploited the most. Imposition of court fees and fines has trapped

low-income people in cycles they are unable to escape, through no fault of their own. During

Ronald Reagan’s administration, governments at every level were looking for ways to implement

budget cuts and increase revenue (Edelman, 2019). Part of the mobilization of these goals was to

impose fines and fees for every part of a person’s involvement with the criminal justice system,

with driver’s license suspensions being a particularly lucrative option. There are states that

suspend driver's licenses for unpaid student loans, public drunkenness (even if a car is nowhere

in sight), bad checks, graffiti, and littering. This works because it is almost certain a person will
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be caught driving after suspension, since they need to be able to get to work, get their kids to

school, and do groceries and other errands. In California, the majority of the $11 billion in

outstanding court debt is due to license suspensions (Edelman, 2019).

These policies disproportionately affect low-income people. A Georgia man, Adel

Edwards, was arrested for burning leaves without a permit. Edwards has a "significant

intellectual disability and cannot read or write" (Edelman, 2019, p. 214). After conviction, he

was given a $500 fine and was also ordered to pay $528 for probation. When he could not pay

the $500 fine, he was put on probation for a year, and the probation company added an instant

payment of $250. Edwards then went to jail until a friend could scrape together the money. Not

insignificantly, Edwards is also black (Edelman, 2019).

Another case brought the exploitation of low-income people to the forefront when the

Obama administration conducted a report on Ferguson, Missouri, police department after the

2014 killing of Michael Brown (Edelman, 2019). In 2010, the population of Ferguson was 67%

black, and between 2009-2013, 25% of the city was below the federal poverty level (Civil Rights

Division [CDR], 2015). According to the investigative report, Ferguson's city officials did not

see the police’s duty as enforcement of the law, but rather collection of revenue. In 2013, the city

budget for fines and fees was projected to be $2.11 million; the actual amount collected was

$2.46 million. In 2010, the city finance director emailed the police chief, saying that "unless

ticket writing ramps up significantly before the end of the year, it will be hard to significantly

raise collections next year" (CDR, 2015, p. 10). The city regularly pressured its officers to write

as many citations as possible, leading to some officers writing up to fourteen citations for one

encounter. For example, for a single DUI stop, an officer might also write citations for

"speeding, failure to maintain a single lane, no insurance, and no seat belt, etc." (CDR, 2015, p.
12

11). In 2014, the finance director asked the police chief to pay five officers overtime to patrol the

highway seven days a week. The city told the police department that the reason for this was "to

produce traffic tickets, not provide easy OT" (CDR, 2015, p. 14). The city of Ferguson also

charged a $50 fee just for having a pending warrant cleared, among other arbitrary practices;

none of these practices considered a person's ability to pay. Ferguson's policies demonstrate how

the upper class exploits the poor for their own benefit.

The resulting debt from inevitable nonpayment of these fees and fines is one road to

criminalization, and, therefore, mass incarceration (Ehrenreich, 2011). In New York City in

2006, it was found that up to 23% of homeless people in shelters had been incarcerated within

the previous two years (Herring et al., 2020). In another national survey, 49% of homeless

people said they had been incarcerated during their lives, and 18% had spent time in a state

facility, compared to just 5% of the public. In San Francisco alone in 2013, between 10 and 24%

of the jail population was homeless at the time of arrest (Herring et al., 2020).

Other practices increase mass incarceration by providing the police with justification for

their actions. For example, "broken window" (Edelman, 2019, p. 216) policing, in which police

conduct mass arrests for small offenses, was marketed as a way to keep order in the community.

This policy is also known as "rabble management" (Herring et al., 2020, p. 133). The only true

achievement was that it overcrowded the jails with poor people unable to make bail (Edelman,

2019). There are up to 700,000 people in jail nationwide daily, of which 450,000 have never

been adjudicated guilty of anything; "they are simply poor people waiting for a trial" (Edelman,

2019, p. 221). These poor people end up with stories like Kalief Browder, who spent three years

incarcerated at Rikers Island without ever being convicted for the alleged petty robbery that

landed him there. Browder’s mental health declined seriously due to his violent and traumatic
13

experiences in Rikers, and he committed suicide at the age of 22 (Gonnerman, 2015). Are we

still so sure debtors’ prisons no longer exist in these United States?

Social Changes

Along with Golden Door Advocacy’s work, there are other organizations on the front

lines of the fight to decriminalize poverty. One example is the #IAskForHelpBecause campaign,

started by the National Law Center on Homelessness and Poverty. This campaign began after the

Norton v. Springfield (2015) ruling established that most panhandling laws are unconstitutional

(National Law Center on Homelessness and Poverty [NLCHP], n.d.). According to NLCHP web-

site (n.d.), this campaign works with local advocacy groups “to repeal these unconstitutional or-

dinances and to promote more constructive approaches to addressing the hunger and homeless-

ness that creates the need for panhandling” (p. 1). Their belief is that people ask for help in the

forms of begging, panhandling, and solicitation, but when these acts are criminalized, it does

nothing but push them into the criminal justice system and cause even more problems. The

#IAskForHelpBecause campaign was launched in 2018 and at that time, it was estimated that

panhandling laws had increased up to 43% over the previous ten years (NLCHP, n.d).

Other examples of social change include legal reforms. A study conducted by Villanova

University found that heavy sentencing guidelines lead to mass incarceration, which increased

the poverty rate by approximately 20% (Tanner, 2021). Another study found that a family whose

father was jailed was 40% more likely to be living in poverty. This has huge implications nation-

wide considering that 1.5 million children in 2016 had an incarcerated parent (Tanner, 2021). It

is possible that the economic effects of incarceration can be lifelong; a PEW Research study

found that inmates released in 1986 were still in the bottom 20% of incomes as of 2006, a full

20 years after release (Tanner, 2021). To combat these statistics, some states are redefining how
14

they look at “crimes” of poverty. In 2014, California's Proposition 47 turned a variety of felony

offenses into misdemeanors, including low-level theft and drug offenses, forgery, and receiving

stolen property. The law also allowed the resentencing of people serving felony time for these

crimes, allowing sentences to be reduced under the new guidelines (Tanner, 2021).

Another area for reform involves the elimination of oppressive administrative court fees.

Research shows that these fees, along with over court-imposed crimes, contribute to the crimi-

nalization of poverty because they ensure that people become indebted to the criminal justice

system for extended periods of time (Pager et al., 2022). They may also “deepen economic disad-

vantage for defendants who are already poor, ”(Pager et al., 2022, p. 531) again perpetuating the

cycle of poverty. There is evidence of progress in this area. California is slowly eliminating these

fees, which are responsible for up to $16 billion in debt for Californians (Tanner, 2021). Other

states are also making progress towards eliminating fees, recognizing that they are most often

imposed upon people with the least ability to pay. More than 15 states have reduced their usage

of court fees since 2021 (Boardman, 2023). In 2023, New Mexico eliminated legal criminal fees

for the whole state. Arizona, Illinois, and Montana eliminated court fees for juveniles. Indiana is

working to limit fees for low-income citizens. Continued reforms in these areas will likely suc-

ceed, especially considering that “imposing increasingly onerous fines and fees results in less

revenue, not more” (Boardman, 2023, para. 28).

Sociological Theory

Karl Marx believed that the upper class marginalizes the lower in subtle ways through so-

cial institutions (Hagan & Shedd, 2005). For example, studies show that, both at the individual

and neighborhood levels, socioeconomic status is linked to satisfaction with police; "concen-

trated neighborhood disadvantage increases dissatisfaction with the police" (Hagan & Shedd,
15

2005, p. 261). Broken window policing and rabble management are examples of how over-polic-

ing can lead to mass incarceration, leaving low-income people vulnerable to an unavoidable cy-

cle. If unable to pay bail, they will be in jail until trial, which affects their jobs and rent pay-

ments. To get out of jail, they must plead guilty at trial and receive even more fines. If they are

not able to adhere to a payment plan, they will become even more behind, which restarts the cy-

cle. This vulnerability encompasses every aspect of a person's life, limiting their access to re-

sources such as housing, education, job training, proper nutrition, social capital, and even their

dignity (Mayer & Fungfeld, 2005).

Unfortunately, this system affects juveniles as well as adults. A 2016 study by the Juve-

nile Law Center of Philadelphia found that many states charge for "probation, supervision, diver-

sion, drug tests when there is no history of drug abuse, cost of care (room and board), and on and

on" (Edelman, 2019, p. 219). When their families cannot pay, this debt transitions to adulthood

along with the juvenile, affecting future opportunities for employment, credit, housing, and fi-

nancial aid for college, among others (Edelman, 2019).

This leads to the intergenerational transmission of poverty (Najman et al., 2018). The

class stratification described in Marx's conflict theory is then perpetuated because children from

poor homes have a higher risk of mental and physical health, high mortality rates, developmental

delay, and general life stress (Namjan et al., 2018). Studies have shown that these deficiencies

persist into adulthood, leaving children and grandchildren vulnerable to the same hardship.

Conclusion

Conflict theory, the separation of Americans into bourgeoisie and proletariat classes,

where one’s worth and opportunities are measured (or not) by their bank accounts, has lifelong

implications for success and quality of life. Karl Marx believed that poverty results from the con-
16

flict of two classes over resources and power (Nickerson, 2023). The criminalization of poverty

has shut low-income people out of accessing basic necessities. Horace Mann stated that educa-

tion "does better than to disarm the poor of their hostility towards the rich: it prevents being

poor" (as cited in Ford, 2020). In a society where the poor are at an educational disadvantage

from birth, who does that really help? Pulitzer prize-winning sociologist Matthew Desmond

(2023) explains the criminalization of poverty and exploitation of the poor in this simple yet pro-

found way: “Poverty isn’t simply the condition of not having enough money. It’s the condition of

not having enough choice and being taken advantage of because of that” (p. 14).

In the United States, we have put men on the moon, mapped the human genome, found a

cure for polio, invented the internet, and apprehended criminals based on DNA, but we have yet

to care for our own. Samira Kawash (1998) says, “the homeless are forced into constant motion

not because they are going somewhere, but because they have nowhere to go” (p. 327). Golden

Door Advocacy is working to correct these injustices, so everyone has a safe place to be. The

first sight of America, the land of opportunity, for millions of poor, immigrant, and minority

populations was the Statue of Liberty (National Park Service, 2024a). The National Park Service

maintains her storied legacy; the words extend an invitation, welcoming all people, regardless of

race, gender, religion, or economic status:

“Keep, ancient lands, your storied pomp!” cries she

With silent lips. “Give me your tired, your poor,

Your huddled masses yearning to breathe free,

The wretched refuse of your teeming shore.

Send these, the homeless, tempest-tost to me,

I lift my lamp beside the golden door!” (2024b).


17

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