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* JOHN COIrRNOS, A MODERN PLUTARCH 27 (1928). I. Advocacy groups such as the National Coalition on the Homeless and the Committee for Creative Non-Violence estimate the homeless population to be as high as 3,000,000 people nationwide. Robert C. Coates, Legal Rights of Homeless Americans, 24 U.S.F. L. REV. 297, 298 (1990); Kathleen Peroff, Who Are the Homeless and How Many Are There?, in THE HOMELEss IN CONTEMPORARY SOCIETY 42 (Richard D. Bingham et al. eds., 1987) [hereinafter CONTEMPORARY SOCIETY]. By contrast, the recent census report estimates the homeless population to be approximately 230,000 nationwide. Dennis Hevesi, Census Count of Homeless is Disputed, N.Y. TIMEs, Apr. 13, 1991, at A26. 2. ComerrIEE ON HEALTH CARE FOR HOMELESs PEOPLE, HOMELESSNESS, HEALTH, AND HUMAN NEEDS 3 (1988) [hereinafter HEALTH CARE]; see also THE PARTNERSHIP FOR THE HOMELESS, INc., MOVING FORWARD: A NATIONAL AGENDA TO ADDRESS HOMELESsNESS IN 1990 AND BEYOND AND A STATUS

From Private Places to Private Activities: Toward a New Fourth Amendment House for the Shelterless