Michigan Law Review Volume 117 Issue 7 2019 Putting Accessible Expression to Bed Jamila A. Odeh University of Michigan Law School Follow this and additional works at: https://repository.law.umich.edu/mlr Part of the First Amendment Commons, Law and Society Commons, and the State and Local Government Law Commons Recommended Citation Jamila A. Odeh, Putting Accessible Expression to Bed, 117 MICH. L. REV. 1507 (2019). Available at: https://repository.law.umich.edu/mlr/vol117/iss7/6 https://doi.org/10.36644/mlr.117.7.putting This Comment is brought to you for free and open access by the Michigan Law Review at University of Michigan Law School Scholarship Repository. It has been accepted for inclusion in Michigan Law Review by an authorized editor of University of Michigan Law School Scholarship Repository. For more information, please contact
[email protected]. COMMENT PUTTING ACCESSIBLE EXPRESSION TO BED Jamila A. Odeh* In 2011, the Occupy movement began. Occupiers seized space in dozens of public parks and in the American imagination, providing a compelling illus- tration of an inclusive format of political expression. In the courtroom, pro- testers sought injunctive relief on First Amendment grounds to protect the tent encampments where Occupiers slept. In 2017, the last of the Occupy liti- gation ended; but the ramifications the Occupy cases hold for the First Amendment and expressive conduct remain unexamined. This Comment takes an in-depth look at the adjudication of Occupiers’ First Amendment interest in sleeping in public parks. It analyzes the adjudication of the Occupy cases and contends that the pattern of judicial enforcement re- sults from a desire to remove the appearance of disorder associated with houselessness.