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:18-cv-00155-DOC-JDE Document 158 Filed 04/26/18 Page 14 of 27 Page ID <br />#:2492 <br />l <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />SECOND CAUSE OF ACTION <br />Violation of Fourteenth Amendment: Equal Protection (42 U.S.C. §1983) <br />(Against All Cross -Defendants) <br />75. Defendant and Cross -Complainant City of Santa Ana incorporates by <br />reference and realleges Paragraphs 1 through 74 as if fully set forth herein. <br />76. The population of Santa Ana is approximately 341,000, 78% of which <br />is Hispanic. No other city in Orange County has a higher Hispanic population. <br />77. Santa Ana's median household income is also near the lowest of all <br />cities in Orange County. <br />78. These ethnicity and income demographics are well-known to Cross - <br />Defendants. <br />79. On account of these demographics, Cross -Defendants have either <br />established, encouraged, or been content with the provision of homeless shelters <br />and services almost exclusively within the borders of Santa Ana instead of their <br />own jurisdictions. <br />80. This practice has continued unabated for years. Santa Ana hosts the <br />only true low barrier emergency shelter in Orange County and by far the highest <br />measure of social and other services targeted at homeless individuals. <br />81. Based on Cross -Defendants' acts and omissions, Santa Ana and its <br />residents have suffered a denial of the equal protection of the laws, as guaranteed <br />by the Fourteenth Amendment of the United States Constitution. <br />THIRD CAUSE OF ACTION <br />Violation of Fourteenth Amendment: Due Process (42 U.S.C. §1983) <br />(Against All Cross -Defendants) <br />82. Defendant and Cross -Complainant City of Santa Ana incorporates by <br />reference and realleges Paragraphs 1 through 81 as if fully set forth herein. <br />83. Santa Ana has a significant liberty interest in administering an efficient <br />ind effective government for the benefit of its citizens. <br />