In Papachristou v. Jacksonville (1972), 405 U.S. 156, 92 S.Ct. 839, 31 L.Ed.2d, 110, the Court considered a vagrancy law that penalized "rogues and vagabonds," "dissolute persons who go about begging, common gamblers, persons who use juggling or unlawful games or plays, common drunkards, persons wandering or strolling around from place to place without any lawful purpose or object, and habitual loafers." Id., at 156-157. Determining that the ordinance was vague, the Court held that enforcement of the ordinance violated due process. Specifically, the Court held that the Jacksonville ordinance, "makes criminal activities which by modern standards are normally innocent." Id., at 163. The court determined that the ordinance was vague because it did not give ordinary people notice of what conduct was prohibited and because it gave the police unfettered discretion to make arrests. A decade later, the U.S. Supreme Court reaffirmed its holding in Papachristou. See Kolender v. Lawson (1983), 461 U.S. 352, 103 S.Ct. 1855, 75 L.Ed.2d 903.