*Calista Heister
I. Introduction
The United States will be one of the host countries of the 2026 FIFA World Cup across eleven host cities.[1] During this global soccer tournament, host cities will follow a framework to accommodate the large crowds and ensure a safe event for all.[2] Human rights concerns repeatedly arise during the FIFA World Cup, as well as other sporting events such as the Olympics, when international laws coincide with the domestic laws of host States.[3] The United States needs to address the potential for human displacement that has occurred at previous events, such as the Paris Olympics.[4] For the first time, Federation International Football Association (FIFA), the soccer governing body, is implementing a human rights framework called the FWC26 Human Rights Framework that aims to combat the concerns of potential human rights violations, including the displacement of homeless people in American cities.[5] The United States Supreme Court recently decided, in City of Grants Pass v. Johnson, that governing encampments of homeless people does not constitute “cruel and unusual punishment” under the Eighth Amendment.[6] As the 2026 FIFA World Cup approaches, the Supreme Court’s encampment ordinances decision poses a concern for the safety and fair treatment of those experiencing homelessness who may be displaced.[7]
II. Relations Between Supreme Court Decisions and International Law
International law, including human rights, have gained significant attention during global sporting events.[8] FIFA aims to ensure that World Cup host countries do not interfere with, or violate, human rights of the community members.[9] The Supreme Court’s recent decision will potentially increase the criminalization of homelessness during a time when cities will likely attempt to prevent large encampments gathering near the event sites.[10] Encampments may exist in host cities near event sites as some people who experience homelessness prefer to avoid shelters and other living situations because they wish to remain near family and local connections.[11]
City of Grants Pass raises concerns about the implementation of criminalization tactics in cities, which some argue may “create a ‘revolving door that circulates individuals experiencing homelessness from the street to the criminal justice system.’”[12] If cities dismantle what they see as “dangerous” encampments and displace unhoused people,[13] conflict between United States law and international law emphasized within the FIFA Human Rights Framework may arise.[14] The decision in City of Grants Pass upholds the government’s broad authority to regulate and criminalize aspects of homelessness, as permitted under the Eighth Amendment.[15]
Human displacement is not an unprecedented problem in the United States during sporting events.[16] The 1996 Atlanta Olympics saw the arrests of more than 9,000 unhoused people.[17] A recurrence of displacement during the upcoming World Cup may occur as cities aim to eliminate homelessness.[18] Cities around the United States have ramped up enforcement against homelessness, including in California, where Governor Gavin Newsom called for bans on encampments, and in San Jose, where unhoused people can be arrested for trespassing if they reject offers from shelters three times.[19] Cities outside of Seattle, which will also be a host city at the World Cup, have also removed protections for homeless people when shelter beds are not available.[20] These examples of actions since City of Grants Pass demonstrate states’ willingness to criminalize homelessness.[21]
III. FIFA’s Framework to Mitigate Displacement
Following human rights violations during the 2022 World Cup in Qatar,[22] FIFA now requires host cities to develop action plans to mitigate recurrences and prevent violations at future events.[23] The FIFA Human Rights Framework includes a section, titled “Inclusion and Safeguarding,” which covers housing displacement and housing insecurity.[24] This section acknowledges potential impacts on housing insecurity due to the “staging and hosting of the FIFA World Cup 2026” that could guide targeted actions.[25] Another section of the framework, “The Welfare and Well-Being of Unsheltered Populations” section shows the intention to provide services and support networks to those affected.[26] However, the “plan is just a plan[, i]t’s not self-executing[:]” it needs enforcement to avoid human rights violations.[27] Host cities submitted bid plans that included plans to address varying concerns, including housing, property, and land rights.[28] Atlanta, for example, proposed an anti-displacement tax fund to address housing issues.[29] These proposals from host cities align with the standards outlined in the FIFA Human Rights Framework.[30] FIFA and local governments need to work together to ensure that the “commitment to upholding human rights” comes to fruition during the World Cup as planned.[31]
IV. Conclusion
While host cities submit plans to implement the foundations of the FIFA Human Rights Framework, there is no guarantee that local governments will adhere to the plans when the event arrives.[32] The City of Grants Pass decision may put vulnerable populations at risk through the city’s ability to implement criminal punishments through the ordinances.[33] The Supreme Court’s decision leaving broad authority regarding enforcing encampments, along with the heightened visibility of these sites due to the World Cup, creates a situation where local governments could displace many individuals.[34] The FIFA Human Rights Framework offers a foundation for protecting human rights, but the implementation and enforcement of the goals in the framework remain to be seen.[35]
*Calista Heister is a second-year student at the University of Baltimore School of Law and a Staff Editor on Law Review. She also is 2L representative for the International Law Society and UB Leads Mentor. Calista interned with Justice Booth of the Supreme Court of Maryland this past summer and has also participated in the Sports Law Arbitration Moot Competition through the Entertainment, Arts and Sports Law Society. She hopes to work in international business transactions to help companies align their trade and labor practices with human rights standards.
[1] FIFA, FWC26 Human Rights Framework, INSIDE FIFA (July 23, 2024), https://digitalhub.fifa.com/m/494d934f7de1bad/original/FWC26-Human-Rights-Framework_Final_EN_24-July-2024.pdf [hereinafter FWC26 Human Rights Framework]; FIFA, FIFA World Cup 26: Host Countries, Cities, Dates, Teams, Tickets, Qualifying and More (Oct. 13, 2025), https://www.fifa.com/en/tournaments/mens/worldcup/canadamexicousa2026/articles/fifa-world-cup-2026-hosts-cities-dates-usa-mexico-canada [hereinafter FIFA World Cup 26 Information] (listing all of the host cities in the United States for the World Cup: “Atlanta[,] Boston[,] Dallas[,] Houston[,] Kansas City[,] Los Angeles[,] Miami[,] New York[/]New Jersey[,] Philadelphia[,] San Francisco Bay Area [and] Seattle”).
[2] See id.
[3] Evan Hsiang, The Social Contract Between Human Rights and International Sports Tournaments, HARVARD POLITICAL REVIEW (Aug. 28, 2023), https://harvardpolitics.com/human-rights-sports/.
[4] Tom Nouvian, The Paris Olympics Displaced Nearly 20,000 People, Local Associations Say, Associated Press (Nov. 4, 2024, at 13:22 ET), https://apnews.com/article/paris-2024-summer-olympics-expulsions-bec056da16aa71722e4ce1c32ceac1de.
[5] FWC26 Human Rights Framework, supra note 1.
[6] City of Grants Pass v. Johnson, 603 U.S. 520, 543 (2024).
[7] FWC26 Human Rights Framework, supra note, 1 (showing the concern for people experiencing homelessness); Nouvian, supra note, 4 (exemplifying a previous example of a global sporting event that caused displacement).
[8] Press Release, U.S. Dep’t of State Off. of the Spokesperson, U.S. Achievements in Advancing Hum. Rts. Globally (Dec. 10, 2024); Hsiang, supra note 3 (“International sports competitions like the Olympics and World Cup help bring human rights issues to the forefront of the news”).
[9] FWC26 Human Rights Framework, supra note 1.
[10] Charlotte Kramon, FIFA Moves Ahead with New Human Rights Strategy for World Cup Games, but Advocates Are Skeptical, Associated Press (Aug. 12, 2025, at 12:07 ET), https://apnews.com/article/fifa-world-cup-2026-human-rights-61f42db2e53c5fd3f29267fa8ed848c4 (describing how Atlanta moved people from downtown before the 1996 Olympics, and “a plan to eliminate homelessness downtown before the World Cup worries advocates that unhoused people will be jailed again.”).
[11] City of Grants Pass, 603 U.S. at 532.
[12] Id. (quoting U.S. Interagency Council on Homelessness, Searching out Solutions: Constructive Alternatives to the Criminalization of Homelessness 6 (2012)).
[13] Id. at 533 (quoting Nat’l Park Serv., Record of Determination for Clearing the Unsheltered Encampment at McPherson Square and Temporary Park Closure for Rehabilitation (2013).
[14] Hsiang, supra note 3 (explaining that the focus should be on a transnational solution rather than addressing conflicts as one that may arise under either domestic or international law which FIFA’s FIFA Human Rights Framework aims to address).
[15] City of Grants Pass, 605 U.S. at 551 (explaining that the Eighth Amendment does not have language to restrict or guide the Court).
[16] Kramon, supra note, 10 (showing that large scale displacement of unhoused individuals happened in 1996 in Atlanta before the Olympic Games).
[17] Id.
[18] Id.
[19] Id.
[20] FIFA World Cup 26 Information, supra note, 1;Michael Lyle, Camping Bans, Penalties After Supreme Court Ruling Could Worsen Homelessness, Experts Say, GEORGIA RECORDER (Dec. 24, 2024, at 1:00 ET), https://georgiarecorder.com/2024/12/24/camping-bans-penalties-after-supreme-court-ruling-could-worsen-homelessness-experts-say/.
[21] Id.
[22] Juliana Kim, FIFA Should Pay Workers Harmed in Building World Cup Venues, Its Committee Report Says, NPR (Nov. 30, 2024, at 20:00 ET), https://www.npr.org/2024/11/30/nx-s1-5211297/soccer-qatar-world-cup-saudi-arabia-human-rights.
[23] Kramon, supra note 10.
[24] FWC26 Human Rights Framework, supra note 1.
[25] Id.
[26] Id.
[27] Kramon, supra note 10 (quoting “Jennifer Li, director of the O’Neill Institute’s Center for Community Health Innovation at Georgetown Law and national coordinator of the Dignity 2026 Coalition, which is working with FIFA on human rights.”).
[28] The Promise of a Positive Legacy: The FIFA World Cup 2026 Host City Candidates’ Human Rights Plans, The Ctr. for Sport & Hum. Rts. And Clifford Chance, https://www.cliffordchance.com/content/dam/cliffordchance/briefings/2022/03/the-promise-of-a-positive-legacy.pdf.
[29] Id.
[30] See FWC26 Human Rights Framework, supra note 1.
[31] Kramon, supra note 10.
[32] Id. (showing that FIFA leaves it up to local communities to ensure the implementation occurs, but the local organizers are unprepared).
[33] City of Grants Pass v. Johnson, 603 U.S. 520, 543 (2024).
[34] Id. at 551; see also Kramon, supra note 10 (showing that displacement has happened in Atlanta in 1996 when last faced with a major sporting event and visible homelessness near venue sites).
[35] Kramon, supra note 10 (explaining that FIFA may have a plan in place, but they are not enforcing it and are leaving it to the locals to enforce).
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