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No Vacancies, Evict the Speculators

Expropriation as Tactic, Strategy, and History in the Struggle for Housing

May 18, 2020

Contending for Rooms

In early April, it seemed that home reclamations by the homeless might spread as a response to the vastly insufficient provision of shelter, provoked by heightened need in the face of pandemic. Then, the center of gravity in this struggle shifted toward limiting exposure to the virus through government action. Where homeless populations are highest throughout the US, tenants’ movement groups are contending over efforts for city, county, and state governments to lease hotels to individually house the unhoused. Mass hotel leasing has become financially possible due to FEMA funds unleashed by federal emergency declarations. The public health crisis has made it untenable for officials to completely ignore the severe living conditions forced on the homeless, even though it’s structurally impossible for them to address the problem in terms of its roots in landlordism. While home reclamations challenge both government and capitalist landlordism by putting care for the homeless under independent community control, the more swiftly scalable proposals preserve landownership in emergency form, under combined management of government, nonprofits, and capitalist landlords, especially hoteliers. 

According to the main public health paper circulated by agencies, last updated in April by a team fronted by Dennis Culhane at the University of Pennsylvania, “inadequate access to hygiene” and “isolation from health care,” as well as “high susceptibility to symptomatic infection, hospitalization, and fatality” (because of the diminished health and advanced age of many homeless), make it necessary to immediately provide about 300,000 beds across the US to the unsheltered homeless. To meet CDC social distancing guidelines for space per bed, traditional-style group, or “congregate,” shelters would need to substantially reduce beds and open new buildings, merely to maintain the current number of beds, let alone increase it. “The ideal scenario would involve private accommodations for all clients. Private accommodations would dramatically reduce the likely transmission of disease relative to congregate shelters,” the researchers write. “This approach may offer a more scalable alternative to constructing shelters.”

The largest efforts to provide hotel rooms are underway in California, home to more than one-fifth of homeless people nationwide, most of whom are unsheltered. In the earliest significant hotel provisioning by a city, the San Francisco Board of Supervisors outflanked Mayor London Breed to begin leasing 7,000 rooms for any homeless person, whether or not they were known to have been exposed to coronavirus. In the East Bay, Alameda County has moved to provide 4,750 hotel rooms, but as of April 19, independent reporter Jaime Omar Yassin has found the county unable to secure the rooms and unable to begin housing people. 

According to Cal Matters’ Matt Levin, statewide “the logistics have proved daunting” to implement Governor Gavin Newsom’s plan to make 15,000 rooms available on a need-tested basis, for those at high risk of exposure or already showing symptoms. Needs-testing is common among similar hotel room plans nationwide, despite public health recommendations. Levin explains the delay: ”Arranging physicians, nurses, caseworkers, food delivery, security, cleaning and other services has been more of a hurdle than actually acquiring the hotels. For hotels isolating those who are symptomatic, personal protective equipment is needed for county, nonprofit and hotel staff. Transportation has also proved a challenging issue as counties grapple with how to safely move symptomatic homeless people with pets and belongings while protecting transit workers.” Yassin identifies another obstacle—stringent behavioral regulations for residents, limiting the appeal of the hotels and excluding those allegedly not following regulations. With hoteliers charging their highest rates for rooms that are slow to fill, as Yassiin also documents, these policies may function mainly as a partial bailout for the flailing hospitality industry. 

But ineffective hotel requisitions may be better than congregate shelters, which many regions continue to expand, and which, even with social distancing in place, serve as hotbeds of viral exposure. An April 17th report in Citylab by Sarah Holder and Kriston Capps shows that the leader of the Federal COVID-19 Homelessness Workgroup, Robert Marbut Jr, has circulated a letter among a prominent network of Christian homeless shelters, Citygate, endorsing their operations as “a critical strategy in order to help protect the overall medical system.” Citygate has encouraged shelters to deploy Marbut’s letter to secure emergency funding and to intervene against the hotel housing measures. 

In their inaugural tweet, the new group Moms 4 Housing announced that “Homeless moms are taking vacant properties back from real estate speculators TODAY in West Oakland."

Homes Not Hotels

In mid-March, as the contest between hoteliers and Christian ministries was prenatal, in the El Sereno neighborhood of East Los Angeles, where the California Department of Transportation, Caltrans, owns 163 vacant homes, thirteen expropriations by the new homeless peoples’ group Reclaiming Our Homes began putting landownership in jeopardy. The first occurred the weekend before L.A.’s shelter in place order, with more emerging in the days up to the March 19th order. Starting the 19th, California Highway Police were posted nightly to prevent further reclamations; Captain Denis Ford told Liam Dillion, according to a Twitter post, “The CHP has been directed at the highest levels to assist Caltrans with ensuring that the houses that are state owned by Caltrans and are vacant remain vacant.”

The timing, between the pandemic entering into broader awareness and the strict enforcement of shelter in place, was perfect. One of the Reclaimers, Martha Escudero, told Sarah Jaffe for Dissent, that “[w]hen she heard about Moms4Housing this winter, she began talking to friends about whether something like that would be possible in L.A.” Another Reclaimer Jaffe spoke with, Benito Flores, remarked on his group’s response to the pandemic, “if we were going to do something, it had to be now.” Escudero’s friends had connected her with Eastside Cafe and the statewide community organization Alliance of Californians for Community Empowerment (ACCE), who introduced her to fellow Reclaimer Ruby Gordillo and Flores, the latter of whom had been organizing with both the Los Angeles Center for Community Law and Action and the United Caltrans Tenants—whose members had been active for decades in housing struggles impacted by the 710 freeway corridor project running through El Sereno. Those groups and others, including LA and Pasadena Tenants Unions and DSA Los Angeles, coordinated support for the Reclaimers in advance of their first occupation, with each showing up with groups of members the day of. ”We’ve been seeing a lot of support from the neighbors,” Escudero told Jaffe.

Since then, homeless people organizing with Red Braid Alliance for Decolonial Socialism in the Vancouver, Canada metro area have occupied two vacant public buildings, with reference to COVID-19. Police evicted them from the first, a former Rec Center, the same day. The second, a former school building, remained in squatter’s possession from April 18th to 19th. Fourteen people were arrested when the police shut the action down. In Chicago, IL, “[o]n April 1st, a group of rent strikers, residents of tent cities and community members reclaimed a building owned by Deutsche Bank,” according to a report on It’s Going Down. Anonymous authors explain the logic of the action, saying, “rent strikes unmask the fundamental violence of rent, building occupations become acts of self-determination that shatter the illusion of private property.” 

Moms House

Like the first known case of COVID-19, we can track the latest current of homeless tenants militancy back to a campaign begun in November. One Monday morning, word came through that an event publicized as the “Moms for Housing Breakfast & Toy Drive,” one of a dozen acts in the East Bay Housing Justice Week of Action, was a pretense. The invitation for the November 18th, 2019 toy drive had asked attendees to “[b]ring a toy, bring a friend, and show unhoused and marginally housed women and children some love and solidarity,” but in their inaugural tweet, the new group Moms 4 Housing announced that “Homeless moms are taking vacant properties back from real estate speculators TODAY in West Oakland.” By now, almost anyone who has heard of the Moms has also, thanks to them, heard that in Oakland there are four vacant homes for every homeless person. Many also now know that, according to conservative estimates, between 2017 and 2019 Oakland’s homeless population grew 47 percent to at least 4071 people, 70 percent of whom are black.

The Moms House door was battered through almost two months later, Tuesday, January 14, around 5:30am. Armed and armored Alameda County Sheriff’s brought out two of the Moms, Misty Cross and Tolani King, handcuffed. Sherrifs also arrested two supporters, Jesse Turner and Walter Baker. In a mass text, the Moms reassured supporters that they had relocated their children when they got word that “the Sheriff was moving in.” The Friday before, a judge ruled to evict Moms 4 Housing on behalf of corporate house flipper Wedgewood Properties, who had refused demands to sell while the home occupation continued. 

Preparing for eviction, the Moms’ House Solidarity Committee arranged defense shifts 6am to 6pm on Monday the 13th, assuming that the sheriffs would evict during their regular hours. In the morning, more than a dozen supporters physically blocked entry, others served food and drink, and many came just to warm the atmosphere, bringing the crowd to around 100. At 7pm that evening, supporters were texted “URGENT get to 2928 NOW sheriffs are in their way.” Within half an hour people again crowded, numbers soon swelling beyond 300. The Sheriff’s evicted before the next defense shift. 

On Martin Luther King Day a week later, Moms 4 Housing made the surprise announcement that they’d begun negotiations with Wedgewood to buy the home through Oakland Community Land Trust. 

Between expropriation and eviction, the campaign gathered immense popularity. It’s message is best summarized not by the more common #HousingIsAHumanRight but by #EvicttheSpeculators. Iit’s the way the Moms lived the latter that got them so far, earning their reputation for beginning a new movement, or, as we tend to think, a new wave of an old movement. 

Homeless tenants evicting capitalist landlords was the revitalizing ingredient catered to the palate of the moment. The Moms took further, from outdoor to indoor, from public to private, the land occupation tactic of the already well regarded Oakland-based campaign led by and for BIPOC homeless Oakland mothers, The Village (written about by one of us in “Rent and Its Discontents” for the rightfully dissolved Commune). Momentum behind The Village bridged into Moms 4 Housing directly.  The morning of the 24th, The Village staked camp in front of City Hall, to protest homeless encampment sweeps. More than 75 people defended people in 15 tents. Early on the 25th, around 50 cops tore through tents, arresting 19.  

Moms channelled popularity not only because of their message, the moment, or the momentum. Their campaign was waged by a sufficiently powerful articulation of social forces. This articulation helps explain their success and the difficulty of repeating it—except through comparable or larger scale coordination, such as that by Reclaiming Our Homes. The Moms House Solidarity Committee was coordinated by ACCE staff. An ACCE attorney, Leah Simon-Weisberg, represented the Moms in court. And from the start the Moms had support from  “progressive” and social democratic forces such as  City Council President Rebecca Kaplan and Councilperson Nikki Fortunato Bas, plus other influential community leaders and organizations, like former-Mayoral candidate, Cat Brooks, and Community Ready Corps for Self Determination.  

In this situation,  the Moms widened their target from real estate capitalists, like Wedgewood, to politicians who aid them by promoting market-rate housing development, including Oakland Mayor Libby Schaaf, State Senator Scott Weiner, and Governor Gavin Newsom. Schaaf and Newsom ultimately brokered between the Moms and Wedgewood, but only after the Moms disrupted a January 7th press conference for the pro-development legislation SB50, and after the Sheriff’s eviction of the Moms brought public indignation toward Wedgewood, county police, and the political establishment to a fever pitch. 

With the moment still warm from this fever, pandemic struck. Then so did L.A.’s Reclaimers, who, once in physical possession of the state-owned properties, could not be removed, apparently because of the social coordination and public legitimacy of their actions and the fact that no private interest was involved. It’s unclear what role L.A. County court closures played. By contrast, three homeless occupiers in Sacramento, members of the Sacramento Homeless Union, who’d taken over another Wedgewood property, were unceremoniously removed by police for allegedly trespassing on March 29th. Neighbors called the cops on them, not having been won to their side.

Moms 4 Housing’s example is not easily followed. Few among the homeless have access to the spectrum of campaign resources that ACCE or the Reclaimers’ coalition brought to the table. But not every home reclamation needs to be fought so intensively. The Moms’ and Reclaimers’ fights have been deliberately calibrated to apply policy pressure. To expropriate housing for all the homeless, for each highly visible reclamation neighborhoods must support many more less visible. Such support is difficult to organize while sheltering in place. Few regions have networks of tenants’ solidarity as dense or integrated as in Los Angeles and the Bay, though the present wave of housed tenants’ council organizing and rent strikes may be changing that.


Moms channelled popularity not only because of their message, the moment, or the momentum. Their campaign was waged by a sufficiently powerful articulation of social forces.

A Historical Interlude: Occupying Then

This recent wave of struggle recalls previous  housing expropriation campaign after  the liberalization of cities in the postwar era, particularly the events that transpired in the New York City of the 1970s and 1980s. Spearheaded by black and Latinx radicals who were influenced by mass social movements of the previous decade, tactics like squatting began to flourish in New York in the early 1970s. With over 11,000 city-owned buildings abandoned by government disinvestment, hundreds of dilapidated units were reclaimed and restored to provide shelter for those who could not afford those let at market rates. These do-it-yourself approaches encouraged communities to empower themselves through sweat equity and established secure environments somewhat obscured from law enforcement. However, the variety of ways people approached expropriation revealed conflicting expectations of these types of self-management. Founded in 1973, the Urban Homesteading Assistance Board—alongside similar groups who received government contracts—sought “homesteaders” to create housing co-operatives through political education initiatives and models of collective ownership. (About 1,300 occupy homesteads that still exist throughout New York City.)

Headlines from New York Times stories that covered these projects condescendingly blared “Experiment to Curb Blight: Let Tenants Run Buildings” and “Gang Turning Slum Housing into Co-Op.” Pivoting away from finger-wagging against landlords, media attention focused on the affirmative aspects of communal living and building that were palatable for most audiences.

This appeal to hard work and social acceptance was tied to assurances that neglected city-owned property could collectively become theirs through systematic instruction, hard labor, and self-management, ultimately spreading the ideology of homeownership to some previously excluded. Homesteading was federally promoted by the Housing and Community Development Act of 1974 for exactly this civic purpose. There was success in this model for those that pursued it, but it stagnated over the years as people spent up to a painstaking decade rehabilitating buildings through the promise of sweat-equity ownership—and as homesteaders, they could not technically occupy these units during a construction. UHAB participants eschewed the term “squatting”—seeing themselves instead as shareholders in the ownership of a cooperative.  

In the early 1980s, squatters in Manhattan’s Lower East Side followed a trend like that of the  widespread squatters’ movements in Europe—occupying buildings without official sanction. Sociologist Hans Pruijt, argues that the arrival of experienced European squatters in New York helped seed the proliferation. Writer Hannah Dobbz, suggests that the squatters movement grew in response to the practical and ideological limitations of homesteading, which kept a great deal of vacant homes unused for shelter. The latter theory appears to be endorsed by one of the most notorious squatting campaigns of the decade—the 1985 takeover of twenty-five buildings in Brooklyn organized by the Association of Community Organizations for Reform Now (ACORN), part of a national ACORN campaign in support of squatters. 

Substantial squatting continued in New York until the end of the century without becoming permanently incorporated into nonprofit campaigns, until the expansive possibilities of space reclamation in New York dissipated in the early 2000s, as blighted buildings were turned over to private investment. Fewer spaces were available to occupy, while aggressive redevelopment continued to raise rents and push low-income people out.

The Failure of Neoliberal Social Housing Models

Federal, state, and city governments in the United States became the biggest landlords as they invested in infrastructure and welfare during and after World War II. Consequently, the destinies of those housed under these authorities would be bound to complex bureaucracies which later became mass evictors. Since the seventies, these entities have increasingly looked to converting from public to private ownership, shrugging off enormous neglect that has made the conditions unlivable.

Over one million public housing units nationwide need $49 billion in repairs, and the Rental Assistance Demonstration (RAD) program, administered by the Department of Housing and Urban Development, has—on the advice of consultants—facilitated the transformation of these buildings into mixed-income properties, where tenants pay rent subsidized by voucher programs such as Section 8 to private management companies or private landlords. For example, by the end of 2020, 9 percent of the New York City Housing Authority’s (NYCHA) units—approximately 15,000—will be under private operation.

Corporations and the state have exhibited their willingness to do business, and together they are effective in stamping out hopes of a universal housing guarantee. As residents become destabilized by private money operating in the public interest, as well as finding their networks of care and support fractured, social housing continues to transfer to corporate landlords. In the United Kingdom, where budgets for social welfare have decreased with the onslaught of austerity measures that have been enacted since the 1970s to encourage home ownership, rent protections have been lifted and public housing programs have also been gradually turned over to private spheres.

Like Moms 4 Housing, Focus E15 in London comprises a group of young mothers who have used direct action to successfully protest the threat of displacement. In September 2013, the housing charity East Thames Housing Association began evicting families out of their homes in the London borough of Newham (which saw waves of displacement and gentrification after the construction of 2012 London Olympics Stadium).

When the mothers protested, they were offered the chance to temporarily relocate from public housing and accept accomodation in privately managed rentals in cities hundreds of miles away from London. In early 2014, finding this concession unacceptable, the mothers organized the occupation of the charity’s offices and Newham council’s offices as well as other direct actions that shamed local politicians. In the fall of that year, they occupied unused council apartments in Stratford, East London, setting up a two-week social center to educate, entertain, and provide a space for their community to gather. Advocating for more rent protections in one of the world’s most expensive cities, they have rallied around the slogan, “Social Housing, Not Social Cleansing.” In April Focus E15 and Moms 4 Housing organized a joint presentation to highlight their shared strategies and goals in the light of the COVID-19 crisis.

Others have targeted the definition of bogus market-rate “affordability” in metropolitan areas by reversing tactics of expropriation used by governments. Led by the Chinatown Community for Equitable Development and the Los Angeles Tenants Union, the Hillside Villa Tenants Association was formed after a thirty-year affordability covenant expired and threatened to raise the rents to market rate for the fifty-plus residents of the mixed-income building. The landlord, Tom Botz, reneged on an agreement negotiated by Councilman Gil Cedillo to extend the covenant for an additional ten years in February 2019. Now the tenants have suggested reappropriating the method used by the city to gut the nearby Chavez Ravine and Bunker Hill in the 1950s and ’60s as well as by Caltrans to seize the homes occupied in El Sereno: eminent domain

The way to guarantee homes for all will be through the burgeoning tenants movement setting its sights on abolishing rent through mass direct action against landlordism.

New Orleans, Miami, Occupy Our Homes

The short-term affordability covenant that had failed the Hillside Villas is an example of the kind of neoliberal social housing program that combines housing vouchers and units let at market rates. In the wake of Hurricane Katrina, which paved the way for all kinds of dubious “reform,”  these models were implemented in new developments intended to replace the decimated public housing stock in New Orleans. The overall number of public housing units fell, and despite the growing needs of residents who returned to the city, the state could not guarantee shelter or resources for those who had been displaced. Activists organized around the lack of governmental response and the precariously housed squatted in dilapidated homes, but these efforts were defeated in part becuase of the limits imposed by a housing market wide-open for speculation. Groups like Common Ground Collective,founded upon radical roots in mutual aid met the same fate as ACORN before them: the bloated nonprofit structure deflated the movement momentum that founded it . 

Though 19 percent of housing units were vacant in New Orleans in 2018, home property values have continued to rise since 2005—while wages in income declined.  Tourism, climate change and AirBnB and other short-term rentals  have accelerated the process of displacement. As the number of visitors has surged, the market has dictated a demand for houses in particular— supply is inaccessible to most permanent residents. To combat this, initiatives such as Jane Place are looking at the community land trust model to fight the lack of affordable housing in New Orleans for communities of color and to combat homelessness. Like many self-help housing projects, Jane Place began as a local  mutual aid effort.

Soon after Katrina, amid the mortgage crisis, homeless black families in Miami began moving into and renovating empty government-owned and foreclosed homes, spearheaded by Take Back the Land. In October 2006, organizers established the Umoja Village on a vacant lot in Liberty City. In addition to providing resources for its 150 residents, the group organized eviction-defense blockades to stop police from turning people out of their homes. It lasted for six months before a mysterious fire destroyed the encampment and a barbed-wire fence was constructed around the site in the days following.

The principal organizer Max Rameau would attempt to broker a deal with both the city of Miami and real estate players—which of course fell through the cracks and never materialized. Starting in 2007, Take Back the Land began opening foreclosed homes as shelter for the homeless, and by 2009 at least twenty families had moved into reclaimed, renovated, and furnished houses. The group formed a national network, which became a key ally of the later Occupy Our Homes foreclosure defense network at the peak of Occupy. 

Today there are multiple trajectories at work for the homeless branch of the movement with organizers working with a variety of organizational histories and in diverse local economic conditions. The mortgage crisis marked that the immediate targets of homeless struggle have shifted largely from state housing owners to private housing owners. Yet, the course of homeless tenants’ movement development seems to be repeating itself—the initial struggles of thirty or forty years ago resonate with the initial struggles today.

Reclamation Beyond the Pandemic

Prior to pandemic, the response to Moms 4 Housing suggested that the prediction that “removing property from the housing market by direct action” would be “the most promising horizon for building a tenants’ movement that unites renter and homeless organizing”—made in “Rent and Its Discontents”—and based partly on the popularity of The Village, wasn’t far from the mark. From the heartland to the coasts and across oceans, from the member meetings of nonprofits to the study groups of anarchist social centers and the dinner tables of neighborhood committees, the Moms’ occupation campaign, like Miami’s Take Back the Land a decade ago, lit a new day in the movement. 

Coronavirus and the Reclaimers showed us that the day might not look as it did in first light. While speculators, as profiteers of misery,  may seem the more politically desirable target, government landowners may be more feasible, as in decades past. Whether by removing homes from the market or from the unused stock of government agencies, direct home reclamations by and for the homeless now show promise as a front of militant action uniting the growing forces of tenants. But as the urgency of sheltering unsheltered homeless tenants becomes a more agreed upon matter of public health, political feasibility has become even more significant, judged by the public deeds of those in the movement.

The California-wide coalition No Vacancy! has formed to demand rooms now and dignified treatment for the homeless moving into them. Activists in Los Angeles, the Bay Area, and elsewhere have mobilized drive-by demonstrations to pressure elected officials to immediately make hotel rooms available. Consider only some actions last month. On April 11, Moms 4 Housing and the Black Housing Union led a “Vehicle March” through Oakland, demanding rooms and highlighting the disproportionate impact of the virus on Black residents.

Nationally, Black and Indigenous Americans are overrepresented among the homeless by three times their respective fractions of the total population, with Black people making up 40 percent overall. On April 13, the day before San Francisco’s Board of Supervisors vote, the Coalition on Homelessness coordinated a car protes behind the message #HotelsNotHospitalBeds in advance of a press conference by the Mayor. And on April 19, a coalition of groups held the first of an ongoing series of People’s City Council car rallies outside LA Mayor Garcetti’s home demanding use of vacant hotels, along with rent cancellation and stronger emergency eviction protections for housed tenants. Police disrupted the protest by making arrests and issuing traffic citations. One sign on the scene read “Homes Not Hotels.”

It’s useful to scrutinize the fear that players in the congregate shelter business, like Citygate, project onto the hotel rooms policies. Do they only fear the near-term implications of the plans for their current access to funding, or something else entirely? Some professional homeless advocates hope the emergency response could initiate a sea change. Holder and Capps in CityLab quote Jenny Friedenbach, director of San Francisco’s Coalition on Homelessness, a political proponent of permanent housing solutions for homelessness, “One of the questions is, once coronavirus peaks, will these rooms still be available to the people who need them, or will they come and say everything’s back the way it was and you’ll have to go to the streets again?” 

The policy trajectories highlighted by Moms 4 Housing and the development of any call for a civil right to housing, are illuminating. When Bernie Sanders remained a presidential hopeful, the national campaign for a Homes Guarantee seemed at least a possility as he endorsed the campaign for a broad policy platform to guarantee a home for US residents. But with a potential Joe Biden presidency, or a continued Trump one,  likely to oppose even the most popular of Sanders’s proposals, a federal Homes Guarantee is even further out of reach. 

Locally, Moms 4 Housing has been consulted on proposals to officially establish a right to housing, perhaps through an amendment to the state constitution, and to discourage home flipping, by giving tenants and community organizations the first opportunity to buy a home put up for sale. As the broader tenants movement has only gained more power in this moment of rent strikes, and the landlord alliance weakened, it seems possible that these real estate dominated city councils and state legislatures of any party affiliation, may have little choice but to compromise. But it’s unclear how much a few more tenants and nonprofits buying homes will reduce homelessness; Washington, D.C., which has had such an ordinance for decades, has one of the highest rates of homelessness in the country. If a right to housing gets watered down into a right to shelter, such as in New York state, this won’t eliminate homelessness, only regulate it. 

We tend to think that the structural obstacles against policies that would house every person are too great to be achievable under racial capitalism, particularly under a growing socioeconomic depression administered by the ruling parties. After the first period of pandemic emergency subsides, temporary measures unevenly implemented will also tend to be reversed, unless militants intervene against government evictions to keep the homeless housed in hotels until permanent housing is provided or, better yet, secured by further reclamations.

The way to guarantee homes for all will be through the burgeoning tenants movement setting its sights on abolishing rent through mass direct action against landlordism. This means following the principle of the L.A. demonstrators and Chicago expropriators and, bridging the rent strike demand of rent cancellation for the housed into homes for all the homeless as well. Groups that preexisted the crisis will play a role, but resources they’ve concentrated cannot be stretched wide enough. The many new networks of mutual aid and tenant organization that have formed in the pandemic will need to mobilize wherever the militant actions of the homeless are found, whether in defense of emergency housing or future reclamations.



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