Summary of Argument A broad coalition of medical, public-health, and harm-reduction organizations supports Safehouse’s plan to operate a medically supervised consumption site in Philadelphia because it is an evidence-based intervention that saves lives, reduces infectious disease, and connects people to treatment without increasing crime. Amid a lethal overdose crisis—worsened by fentanyl—Safehouse’s model would provide sterile equipment; supervised use with immediate overdose response; on-site health assessments, wound care, and initiation of medication-assisted treatment; and warm referrals to detox, treatment, housing, and primary care, while collecting data to evaluate outcomes. Decades of peer-reviewed research from ~120 sanctioned sites in 11 countries shows zero on-site overdose deaths, large numbers of reversals, reductions in risky injection practices and HIV/HCV transmission, increased entry into treatment, fewer publicly discarded syringes and episodes of public drug use, and no increase in crime; in several cities, nearby overdose deaths and ambulance calls declined after sites opened. These public-health benefits align with, not violate, federal law. Section 856 (“Crack House Statute”) was enacted to target places maintained for illicit drug use and profit—e.g., crack houses and rogue promoters—not legitimate health programs designed to reduce harm and demand. Legislative history and subsequent amendments confirm Congress sought law-enforcement tools alongside “innovative proposals for reducing demand,” and courts have recognized that §856 does not reach actors whose purpose is to curb, not facilitate, drug use. More broadly, the Controlled Substances Act emphasizes prevention, treatment, and rehabilitation as core objectives in protecting public health. Supervised consumption sites advance those goals by preventing avoidable deaths and disease and by linking marginalized people to care, all while improving public order. The Court should therefore affirm the district court’s declaration that Safehouse’s proposed operations are lawful.

Summary of Argument

A comprehensive alliance of medical, public health, and harm reduction entities endorses Safehouse's proposal to establish a medically supervised consumption site in Philadelphia. This initiative is recognized as an evidence-based intervention demonstrably effective in preserving lives, mitigating infectious disease transmission, and facilitating access to treatment services, all without contributing to an increase in crime rates. In the context of a severe overdose epidemic, exacerbated by the presence of fentanyl, Safehouse's operational model would furnish sterile consumption equipment and provide supervised usage environments that include immediate overdose response. Furthermore, the site would offer on-site health assessments, wound care, and the initiation of medication-assisted treatment, alongside structured referrals to detoxification programs, comprehensive treatment, housing assistance, and primary care. An integral component of this model involves data collection for outcome evaluation. Decades of peer-reviewed research from approximately 120 sanctioned sites across 11 nations consistently report zero on-site overdose fatalities, a high volume of overdose reversals, significant reductions in risky injection practices and the transmission of HIV/HCV, increased enrollment in treatment programs, decreased prevalence of publicly discarded syringes and instances of public drug consumption, and no documented rise in crime. Moreover, in several urban centers, a decline in proximate overdose deaths and emergency medical service calls has been observed following the establishment of such sites.

These public health advantages are in alignment with, rather than in violation of, federal statutes. Section 856 of the United States Code, commonly known as the "Crack House Statute," was enacted with the intention of targeting premises maintained for illicit drug use and commercial profit, such as crack houses or rogue drug promoters. It was not designed to encompass legitimate public health programs focused on harm reduction and demand reduction. An examination of the legislative history and subsequent amendments confirms Congress's objective to provide law enforcement with tools while also supporting "innovative proposals for reducing demand." Judicial interpretations have similarly acknowledged that Section 856 does not apply to actors whose primary purpose is to curb, not facilitate, drug use. More broadly, the Controlled Substances Act emphasizes prevention, treatment, and rehabilitation as fundamental objectives in safeguarding public health. Supervised consumption sites advance these objectives by preventing avoidable mortalities and diseases and by connecting marginalized individuals to essential care, thereby simultaneously enhancing public order. Consequently, the Court should uphold the district court's declaration affirming the legality of Safehouse's proposed operations.

Summary

Many medical, public health, and harm reduction organizations support Safehouse's proposal to operate a medically supervised consumption site in Philadelphia. This support stems from the understanding that such sites are a proven strategy that saves lives, reduces infectious diseases, and connects individuals to treatment without increasing crime. Amidst a deadly overdose crisis, made worse by fentanyl, Safehouse's model would provide sterile equipment, supervised drug use with immediate overdose response, on-site health assessments, wound care, and initiation of medication-assisted treatment. It would also offer direct referrals to detox programs, treatment, housing, and primary care, while systematically collecting data to evaluate outcomes. Decades of peer-reviewed research from approximately 120 sanctioned sites in 11 countries show no overdose deaths have occurred on site. These studies also demonstrate large numbers of overdose reversals, fewer risky injection practices, reduced transmission of HIV and Hepatitis C, more individuals entering treatment programs, a decrease in publicly discarded syringes and instances of public drug use, and no rise in crime rates. In some cities, nearby overdose deaths and ambulance calls declined after these sites began operating.

The public health advantages of these sites align with, rather than violate, federal law. Section 856, known as the "Crack House Statute," was created to target locations maintained for illegal drug use and profit, such as crack houses or unscrupulous promoters. It was not intended to apply to legitimate health initiatives that aim to reduce harm and drug demand. Historical legislative records and later amendments show that Congress sought to provide law enforcement with tools while also supporting "innovative proposals for reducing demand." Courts have similarly recognized that Section 856 does not apply to organizations whose goal is to curb drug use, not facilitate it. On a broader scale, the Controlled Substances Act highlights prevention, treatment, and rehabilitation as central goals for safeguarding public health. Supervised consumption sites support these objectives by preventing preventable deaths and diseases, connecting vulnerable individuals to care, and enhancing public order. Therefore, the Court should uphold the district court's decision that Safehouse's planned operations are lawful.

Summary of Argument

Many medical and public health groups, along with organizations focused on reducing harm from drug use, support Safehouse's plan to open a medically supervised drug consumption site in Philadelphia. They believe this approach is a proven method that saves lives, lowers the risk of infectious diseases, and helps people access treatment, all without increasing crime. Amid a deadly overdose crisis, made worse by fentanyl, Safehouse's model would offer clean equipment, supervised drug use with immediate help for overdoses, on-site health checks, wound care, and a start to addiction treatment with medicine. The site would also help connect people to detox programs, treatment, housing, and primary medical care, while collecting data to see how well it works.

Studies from over 120 approved sites in 11 countries, conducted over decades, show that no one has died from an overdose at these sites. They have reversed many overdoses, led to less dangerous ways of injecting drugs, reduced the spread of diseases like HIV and Hepatitis C, and helped more people enter treatment. These sites also resulted in fewer syringes thrown away in public and less public drug use, with no increase in crime. In some cities, nearby overdose deaths and ambulance calls decreased after these sites opened.

The health benefits of these sites fit with, rather than break, federal law. Section 856, known as the "Crack House Statute," was created to target places that promote illegal drug use and profit, like crack houses or dishonest promoters. It was not meant for proper health programs designed to reduce harm and demand for drugs. Historical records and later changes to the law confirm that Congress wanted both law enforcement tools and new ideas for reducing drug demand. Courts have also recognized that Section 856 does not apply to groups whose goal is to reduce, not encourage, drug use.

More broadly, the Controlled Substances Act focuses on preventing drug use, providing treatment, and rehabilitation as key goals for protecting public health. Supervised consumption sites help achieve these goals by preventing avoidable deaths and diseases and by connecting people who are often left out to care. This also helps improve public order. Therefore, the Court should agree with the district court's decision that Safehouse's proposed operations are legal.

Summary of Argument

Many groups, including doctors, health experts, and organizations that help reduce harm from drug use, support Safehouse’s plan. Safehouse wants to open a site in Philadelphia where people can use drugs under medical watch. These groups support the plan because it is proven to save lives, stop the spread of sickness, and help people get treatment. It does all this without causing more crime. Many people are dying from drug overdoses, especially from fentanyl. Safehouse’s site would offer clean supplies, and staff would watch people as they use drugs. If someone overdoses, staff can help right away. The site would also offer health checks, care for wounds, and start people on medicine for addiction. Staff would help people find drug treatment, housing, and doctors. They would also gather facts to see how well the site works. For many years, about 120 similar sites in 11 countries have been studied. These studies show that no one has died from an overdose at these sites. Many overdoses have been stopped. People are less likely to share needles or get diseases like HIV. More people go into drug treatment. Fewer needles are left on streets, and less drug use happens in public. Crime has not gone up. In some cities, fewer people died from overdoses nearby, and fewer ambulance calls were made after these sites opened.

These health benefits fit with federal law and do not break it. Federal law Section 856, also called the “Crack House Statute,” was made to stop places where drugs were sold and used for money, like crack houses. It was not meant for real health programs that aim to reduce harm and lower the need for drugs. Old records and changes to the law show that Congress wanted ways to stop drug crime and new ideas to lower drug use. Courts have said that this law does not apply to groups whose main goal is to stop drug use, not help it. A larger law, the Controlled Substances Act, states that stopping drug use, treating people, and helping them get better are key goals for keeping people healthy. Supervised drug use sites help with these goals. They stop deaths and sickness that can be avoided. They connect people who need help to care. They also make public places safer and more orderly. Therefore, the Court should agree with the first court’s decision that Safehouse’s plan is legal.