“The trauma of homelessness can lead people to shun social interactions such as participating in a background investigation or make it difficult or impossible for them to collect documents.”

“The Procedure establishes, for the first time, a policy that homeless women and men seeking shelter in the City’s single adult system must go through an access control procedure before receiving help. R.41. The screening involves an onerous procedure—also wholly new, and mandatory—in which a homeless woman or man will be required to prove her or his circumstances by “clear and convincing evidence.” R.43. Shelter officials will conduct extensive background investigations, including interviews with former landlords and reviews of financial records. R.42.”

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