Dallas PD told not to enforce controversial prostitution ordinance even after revisions

The Dallas Police Department was instructed to stop enforcing the city’s controversial prostitution ordinance after a municipal judge declared it unconstitutional, according to an internal notice to officers obtained by The Dallas Morning News.

The Saturday directive came more than a year after the city slightly revised its law that allows law enforcement to arrest or cite someone suspected of prostitution for attempting to stop a erby.

In the more recent ruling May 21, Judge Jay Robinson said the latest version of the “manifesting the purpose of engaging in prostitution” ordinance is unconstitutionally vague and overbroad. The problem with the law, he wrote, is the manner in which the courts or police can find a violation under it.

“The Ordinance, by potentially applying to such conduct as talking and waving to other people, clearly implicates protected freedoms,” Robinson said in the ruling.

Dallas police spokesperson Corbin Rubinson confirmed the department’s temporary pause on enforcement. He said the department “remains committed to enforcing all laws, and this ruling does not restrict officers from other methods of investigating and enforcing prostitution and trafficking crimes in the City of Dallas.”

A city of Dallas spokesperson declined to comment. In the memorandum instructing officers not to enforce the ordinance, police officials said the city is reviewing its options and determining next steps.

“We are pleased that the court agreed with our assessment of the unjust and overbroad nature of this law,” said Wesley Sackrule, an attorney with the Palmer Perlstein law firm who represents the two defendants in the case. “We believe past enforcement has been arbitrary and has criminalized innocent behaviors.

“We look forward to defending this ruling as the case moves forward.”

The ordinance allows police to issue citations if a person is a known prostitute, repeatedly beckons to others or tries to engage them in conversation, or attempts to stop a vehicle by waving, hailing “or any other bodily gesture.” Police cannot arrest people unless officers give them an opportunity to explain their conduct.

Dallas police tallied at least 403 prostitution-related offenses in 2024, which includes prostitution, purchasing prostitution and assisting or promoting prostitution, according to the city’s crime dashboard.

So far in 2025, police have reported 105 such offenses. It’s unclear how many violations of the manifestation ordinance the department has tallied; a police spokesperson referred a reporter to file an open records request for the data.

City and police officials have said the ordinance is a necessary tool to tamp down prostitution and sex trafficking. Critics have argued the ordinance seeks a legal shortcut to fight crime or essentially criminalize “talking while walking.”

The ordinance has long been subject to scrutiny for the leeway it affords officers. In 2022, a man was cited with a Class C misdemeanor after he was accused of loitering with the purpose of engaging in prostitution in the 11100 block of Shady Trail. Robinson called the ordinance unconstitutional at the time, a ruling which was affirmed by a Dallas appeals court judge and spurred the city to revise the ordinance.

Much of the original ordinance remained even after the city’s revisions in 2023. The city added definitions to various and required “intent” for a violation. Officers must also consider if potential violators are interfering with the “free age” of others or are in a “location frequented by persons who engage in prostitution.”

The latest ruling stemmed from a case involving two women — Sabrina Gabriella German and Journi Randolph. Around Dec. 19, court records state, German and Randolph were accused of violating the manifestation ordinance in the 10200 block of Shady Trail. They have been accused of solicitation and the manifestation ordinance in the past, which were dismissed, court records show.

Police officials have regularly ramped up enforcement efforts in the department’s Northwest Patrol Division to crack down on prostitution. The division includes Harry Hines Boulevard, Walnut Hill Lane and Shady Trail — long regarded by police as the city’s main corridor for sex work.

While the actions specified by the ordinance could be indicative of manifesting prostitution, Robinson wrote, they could also be innocent behaviors. As an example, he said, a man responding to a request from women for money to buy food, or a man asking women for directions, could be seen as violations if those actions occurred in an area known for prostitution, such as the Shady Trail area.

“Hailing a cab or waving to a friend or er-by or chatting with a friend or even a stranger on a public street are time-honored pastimes in our State and in our Country,” Robinson wrote, “and are clearly protected under both federal law and the Texas Constitution.”

Texas law already penalizes solicitation of prostitution, which requires police to meet a higher standard than the ordinance. Police officials previously said the state statute is typically investigated by undercover detectives in larger-scale operations, while the ordinance — a misdemeanor that carries a fine of up to $500 — allows patrol to address complaints if specialized investigators are unavailable.

Under the new ordinance, “manifest” is not defined, and an involved officer is not required to accept a person’s explanation for his or her conduct, Robinson wrote in his ruling. The ordinance does not give Dallas police officers “any standards by which to evaluate the explanation,” he said.

Someone might not say one word about soliciting prostitution but could still be in violation of the ordinance as written, the judge said.

The ordinance, he wrote in his latest ruling, allows for arrest “based upon speculation and suspicion, and we do not allow arrest based on suspicion.”