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That requires the jurisdiction to provide shelter, which is usually unpopular (both since it costs money and since it has to go somewhere and no one wants to live next to the bum tank).
The Court noted that, as regards to the actual participants in the case, there were available shelters that they declined because they had rules the homeless would rather not follow.
In other words, there's some game theory here. The services & shelters work best[1] when they can impose rules. The shelters' ability to impose rules is limited by the alternative choice of the homeless to live on the streets. Solve for the equilibrium.
[1] As an aside, the shelters working best becomes a sort of fractal pareto of a pareto where the bottom 20% of the homeless themselves drag down the rest. It is very hard for people to become clean in an environment where there are drugs and alcohol.
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Some neighborhoods are already crapholes and you can just build there. Sometimes local leaders need a bribe. But it's not impossible to do.
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