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The Gang's All Here: Anti-Loitering Laws In The Face Of City Of Chicago V. Morales, Robert Delchin

Cleveland State Law Review

This Comment examines Morales and the Court's treatment of anti-gang loitering statutes under the vagueness doctrine. Part II examines the City of Chicago's attempt to tackle the problem of gangs terrorizing its citizens and how the Illinois courts dealt with the ordinance. Part III then examines the reasons for the United States Supreme Court invalidating the ordinance, with equal emphasis placed on all the Justice's opinions. Part IV then analyzes the implications of the Court's decision, criticizing the plurality's creation of a fimdamental right to loiter and demonstrating how the ordinance survives a vagueness challenge.