In 1979 a lawyer named Robert Hayes, brought a class action lawsuit in New York State Supreme Court against the City and State called Callahan v. Carey. Hayes argued a constitutional right to shelter existed in New York. In particular, the lawsuit pointed to Article XVII of the New York State Constitution –
[Public relief and care]
Section 1. The aid, care and support of the needy are public concerns and shall be provided by the state and by such of its subdivisions, and in such manner and by such means, as the legislature may from time to time determine.