The alternative is housing in a specialized correctional facility. The money will be confiscated in any case. This law is enforced, with a police division dedicated solely for that purpose. Law 61 of 1991 forbids the persistent call for the mercy of the public, by a person who is able to work. US State Department Human Rights reports note a pattern of Roma children registered for "vagrancy and begging". In parts of San Francisco, California, aggressive panhandling is prohibited. In May 2010, police in the city of Boston started cracking down on panhandling in the streets in downtown, and were conducting an educational outreach to residents advising them not to give to panhandlers. The Boston police distinguished active solicitation, or aggressive panhandling, versus passive panhandling of which an example is opening doors at a store with a cup in hand but saying nothing. Courts have repeatedly ruled that begging is protected by the First Amendment's free speech provisions. On August 14, 2013, the U. S. Court of Appeals struck down a Grand Rapids, Michigan anti-begging law on free speech grounds. An Arcata, California law banning panhandling within twenty feet of stores was struck down on similar grounds in 2012. A 2002 study of 54 panhandlers in Toronto reported that of a median monthly income of $638 Canadian dollars (CAD) – those interviewed spent a median of $200 on food and $192 on alcohol, tobacco and illegal drugs. The Fraser Institute criticized this study, citing problems with potential exclusion of lucrative forms of begging and the unreliability of reports from the panhandlers who were polled in the study. In North America, panhandling money is widely reported to support substance abuse and other addictions. For example, outreach workers in downtown Winnipeg, Manitoba, Canada, surveyed that city's panhandling community and determined that approximately three-quarters use some of the donated money to buy tobacco products, while two-thirds buy solvents or alcohol. In Midtown Manhattan, one outreach worker anecdotally commented to the New York Times that substance abuse accounts for 90 percent of panhandling funds. This, too, may not be representative since outreach workers work with those with abuse problems. Because of concerns that people begging on the street may use the money to support alcohol or drug abuse, some advise those wishing to give to beggars to give gift cards or vouchers for food or services, and not cash. Some shelters also offer business cards with information on the shelter's location and services, which can be given in lieu of cash.