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B T AND r OR J us I I cc problematic. There is, however, no indication that the distribution of food and other items is a significant contributor to litter if it is at all. "[P]reventing a marginal quantity of litter is not a sufficiently significant interest to restrict [expressive activity]. Discarded paper, coffee cups and food wrappers can [] add to litter, but we remain free to carry beverages and candy bars on public streets... the City must show not only that [expressive activity] can create litter, but that it creates an abundance of litter significantly beyond the amount the City already manages to clean up." Klein v. City of San Clemente, 584 F.3d 1196, 1203 (9th Cir. 2009) Even if food waste and packaging did contribute to litter, there are already laws against littering and well placed additional trash receptacles could help ameliorate the problem; "where there are easily available alternative modes of regulation that both satisfy the government's substantial, legitimate concerns and affect considerably less speech than the mode chosen, [courts] are likely to conclude... that the governmental restriction sweeps in substantially more speech than is necessary to meet the government's concerns. Santa Monica Food Not Bombs, 450 F.3d at 1041. In addition, to the extent that food or other refuse may end up as litter, that is no fault of the individuals who distributed it. Moreover, the Catholic Worker does not distribute from a centralized location at all, but rather from a mobile cart that is wheeled throughout the Civic Center; "a set-up and clean-up plan" would, therefore, have no application to them or others with such a distribution scheme. The ordinance is constitutionally defective in yet another way—by vesting seemingly unfettered discretion over the permit approval process in the City Manager. If an ordinance subjects the exercise of First Amendment freedoms to a permit requirement, it must contain "narrow, objective, and definite standards to guide the licensing authority." Shuttlesworth v. City of Birmingham, Ala., 394 U.S. 147, 151 (1969); Niemotko v. State of Md., 340 U.S. 268, 271 (1951). "Unfettered discretion to license speech cannot be left to administrative bodies. Such discretion grants officials the power to discriminate and raises the spectre of selective enforcement on the basis of the content of speech." Richmond, 743 F.2d at 1357 (internal citations omitted). The ordinance as drafted, however, provides no standards whatsoever on which the City Manager can base their decision. An assessment of whether or not an applicant will ensure the organized distribution of food, the requisite licensing requirements, credentials, and experience, and the adequacy of the set-up and clean-up plan all impermissibly rest within the sole discretion of the City Manager or their designee. Unfortunately, the City of Santa Ana has a history of violating the rights of its most economically disadvantaged residents. For decades, the City has engaged in a policy and practice of citing homeless individuals for sleeping, laying, or resting outdoors in public spaces. These actions are unconstitutional under the Eighth Amendment to the United States Constitution, which is applicable to the states through the Fourteenth Amendment. The Eighth Amendment proscribes the infliction of cruel and unusual punishment. In addition to " limit[ing] the kinds of punishments that can be imposed on those convicted of crimes," the Eighth Amendment "imposes substantive limits on what can be made criminal and punished as such ...." Ingraham v. Wright, 430 U.S. 651, 667 (1977). The homeless people living in Santa Ana are in large part chronically homeless — those with mental or physical disabilities who experience long-term or repeated homelessness. The City cannot criminalize