44.  Pursuant to Fed. R. Civ. P. 23(a) and 23(b)(2), the named Plaintiffs bring this  action individually and on behalf of all other persons similarly situated. The proposed  Plaintiff Class consists of   All unhoused persons who live outside within the City of Seattle, Washington and  who keep their belongings on public property.   45.  The requirements of Rule 23(a) are met because the members of the proposed  Plaintiff Class are so numerous that joinder is impracticable; there are questions of law and  fact common to all members of the proposed Plaintiff Class; the claims of the named  Plaintiffs are typical of those of the proposed class members; and the named Plaintiffs will  fairly and adequately protect the interests of the proposed Plaintiff Class.   A.  The City’s Homeless Population   Right to Be Secure From Unreasonable Seizures  Fourth Amendment of the U.S. Constitution  158.  Plaintiffs reallege and incorporate the allegations of the preceding paragraphs  as if fully set forth herein.   159.  Defendants’ policy, pattern, and/or custom of seizing the individual Plaintiffs’  property without a valid warrant or probable cause is unreasonable and contrary to the Fourth  Amendment of the U.S. Constitution, as applied to the states by the Fourteenth Amendment to  the U.S. Constitution and 42 U.S.C. § 1983.  Right to Due Process of Law  Fourteenth Amendment of the U.S. Constitution  162.  Plaintiffs reallege and incorporate the allegations of the preceding paragraphs  as if fully set forth herein.  163.  Defendants' policy, pattern, and/or custom of seizing and destroying the  individual Plaintiffs’ property without adequate notice and opportunity to be heard prior to  destruction of their property violates the individual Plaintiffs' right to due process of law  protected by the Fourteenth Amendment to the U.S. Constitution. 