After 22 administrative-penalty cycles at $1,000, the City’s 23rd cycle doubled to $2,000 with no rate-change record in the produced file.
When a city fines someone over and over for the same unresolved problem, each round is supposed to follow a written rule, and any change in the dollar amount is supposed to be written down. Here the city billed this property in numbered rounds. The first twenty-two rounds were each set at $1,000. M009 M146 On the twenty-third round the city’s own paperwork — both the internal instruction to “send” the penalty M010 and the formal order to the owner M585 — switched to $2,000, double the prior amount. The city code puts this kind of penalty in a band that runs from $1,000 up to about $2,500, SCC §1.28.010 but it does not contain any automatic step that doubles the figure after a certain time, so moving from $1,000 to $2,000 was a choice someone made. The file the city later closed as complete R.26-1965 does not contain a single page recording that choice — no hearing, no supervisor approval, no fee-schedule change, no council vote, and nothing on the order pointing to one. M001–M631 That gap only became visible after the owner’s representative forced the full record out and lined up the numbered rounds side by side, where the jump from $1,000 to $2,000 stands alone with nothing behind it.
Bottom line: the city’s own records show the per-round fine doubling from $1,000 to $2,000, and the same records — which the city called complete — hold no document deciding or authorizing that increase.The City’s own activity log assesses the administrative penalty on this case in numbered cycles. Cycles 1 through 22 each direct staff to send a penalty of $1,000 M009. The 23rd cycle is the first in the produced record at the doubled figure: the activity-log directive reads “Please send 23rd HSG Admin penalty of $2,000” M010, and the matching Order Imposing Administrative Penalty orders the owner to pay $2,000.00. M585 The directive’s figure and the dollar amount on the issued order agree with each other. No hearing decision, supervisor authorization, City Council action, or amended fee-schedule entry establishing the move from $1,000 to $2,000 per cycle appears anywhere in the produced file for this case. M001–M631
The penalty is imposed as Level C under SCC §1.28.010, which sets a Level C range of $1,000.00 to $2,499.99 and defines no automatic, duration-based escalation schedule — code text verified against the cited section. The full range clause reads: “Level C violations shall be subject to an administrative penalty of one thousand dollars ($1,000.00) to two thousand four hundred ninety-nine dollars and ninety-nine cents ($2,499.99).” The $2,000 figure sits within that range; moving from $1,000 to $2,000 required someone to choose the higher amount. The produced file does not record who made that choice, when, or why.
When a city fines a property in numbered penalty rounds, each round is supposed to follow a written rule, and any change in the dollar amount is supposed to be written down. The first twenty-two rounds were each set at $1,000. M146 M009 On the twenty-third round, the City’s own paperwork — both the internal instruction to “send” the penalty M010 and the formal order to the owner M585 — switched to $2,000, double the prior amount. The city code SCC §1.28.010 contains no automatic step that doubles the figure after a certain time, so moving from $1,000 to $2,000 was a discretionary choice someone made. The file the City later closed as complete R.26-1965 does not contain a single page recording that choice — no hearing, no supervisor approval, no fee-schedule change, no council vote, and nothing on the order pointing to one. That gap only became visible after the owner’s representative forced the full record out and lined up the numbered rounds side by side, where the jump from $1,000 to $2,000 stands alone with nothing behind it.
Each numbered directive from the 1st through the 22nd cycle states a $1,000 per-cycle amount, the last of them on 07/24/2025. M009 The orders themselves carry the matching $1,000.00 face figure, beginning with the 1st-cycle order dated 06/29/2023. M146 The penalty is imposed under Level C of SCC §1.28.010 — the same Level C noncompliance catch-all that appears on every penalty order in this case. Card 12
The activity-log directive M010 and the issued $2,000 order M585 are internally consistent — the directive’s figure matches the dollar amount on the order, both dated 10/17/2025.
“Please send 23rd HSG Admin penalty of $2,000.” M010 — Activity-log directive, 10/17/2025
“Penalty Amount: $2,000.00 … YOU ARE HEREBY ORDERED TO PAY to the City of Sacramento an administrative penalty in the amount of $2,000.00,” Penalty Category C, payment deadline 11/07/2025. M585 — 23rd-cycle Order Imposing Administrative Penalty, 10/17/2025
The produced file contains no hearing decision, no supervisor sign-off, no fee-schedule amendment, no Council action, and no reference in the order itself to the instrument that doubled the per-cycle amount. M001–M631 SCC §1.28.010(D)(3)(c) sets a Level C range of $1,000.00 to $2,499.99 and recites no automatic, duration-based escalation or doubling trigger anywhere in Chapter 1.28 — verified against the code text. A move from $1,000 to $2,000 within that range is therefore a discretionary rate determination requiring a documented decision; the produced file shows the order at the doubled rate and no record of that determination. M585
The 100% increase appears on the face of the City’s own order. M585 The document that would authorize it does not appear in a file the City has declared complete. R.26-1965 Card 47 Where the same supervisor signature block validates every penalty cycle, that undocumented discretion also touches the signature-chain card. Card 12
The per-cycle penalty printed on the City’s own Orders Imposing Administrative Penalty doubled between the 22nd and 23rd cycle. M009 M585 The activity-log directive and the issued order agree on the new $2,000 figure. M010 M585 The produced file — declared complete — contains no document authorizing the increase. R.26-1965 Card 47 On the City’s own record, declared complete, the rate doubled mid-case with no documented authorization in the produced file.
The City’s strongest realistic response is that the escalation from $1,000 to $2,000 is automatic under duration-of-noncompliance tiers in the Sacramento City Code administrative-penalty schedule, so no case-specific authorization needs to appear in the file. There is no such schedule. SCC §1.28.010(D)(3)(c) sets a Level C range of $1,000.00 to $2,499.99 and defines no automatic, duration-based escalation or doubling trigger anywhere in Chapter 1.28 or the rest of the code — verified against the code text. The order itself recites only the Level C definition and the $2,000.00 figure, not any tier that produced it. M585 A move from $1,000 to $2,000 within that range is therefore a discretionary rate determination — and a rate determination is exactly what the file must document: the decision, who made it, and the date it took effect. The produced file shows the order at the doubled rate and no record of that determination. The “automatic tier” defense is unavailable because the code contains no tier to trigger. SCC §1.28.010 Where the same supervisor signature block validates every cycle, that undocumented discretion also touches the signature-chain card. Card 12