Numerous protesters on both sides of the issues gathered at the Supreme Court building after the decision's announcement; and while they created a confrontational environment, they remained peaceful for the most part. However, clashes between police and protesters, resulting in tear gas being used, as well as arrests, have occurred in Phoenix, New York City, and Los Angeles.[217][218][219] Other protests have also taken place including in New York City, Chicago, and Los Angeles, as well as solidarity protests in London, Toronto, and Berlin,[220][221] and are planned to take place throughout the US over the days after the opinion was announced.[222] The Department of Homeland Security issued a memo to law enforcement agencies and first responders to be aware of potential domestic violence in the weeks following the Dobbs decision, particularly at federal and state government offices, abortion clinics and other health provides, and at faith-based organizations.[223]