In City of Chicago v. Morales, 527 U.S. 41, 144 L. Ed. 2d 67, 119 S. Ct. 1849 (1999), the Court first noted that "the freedom to loiter for innocent purposes is part of the 'liberty' protected by the Due Process Clause of the Fourteenth Amendment," id. at 53, and that "it is difficult to imagine how any citizen of the city of Chicago standing in a public place with a group of people would know if he or she had an 'apparent purpose.'" Id. at 56-57. Additionally, the ordinance provided no advance notice to any "putative loiterer" to protect him from being ordered to disperse, and it provided no guidance as to how long a loiterer must remain away, how far away he must move or when he could regroup with the other loiterers before being asked to disperse once more without being subject to arrest. Id. at 59. In other words, the ordinance failed to give adequate notice of what was forbidden and what was permitted. Id. at 60. Also, as found by the Court in Morales, there were no guidelines for enforcement. Id. The police were given "absolute discretion" to determine what constituted loitering in violation of the ordinance. Id. at 61. "Presumably an officer would have discretion to treat some purposes -- perhaps a purpose to engage in idle conversation or simply to enjoy a cool breeze on a warm evening -- as too frivolous to be apparent if he suspected a different ulterior motive." Id. at 62. The Supreme Court found facially invalid an ordinance that provided that, if a police officer reasonably believed that at least one of two or more persons present in a public place was a member of a "criminal street gang" and that the persons were loitering by remaining in a place "with no apparent purpose," the officer must order all the persons to disperse "from the area."