One supervisor signature block validated 23 penalty orders that each recite the same two-prong Level C definition without specifying which prong — or any underlying facts — against violations the City never reduced to property-specific findings.
When a city decides a building is unsafe, it is supposed to write down exactly what is wrong before it starts charging the owner money. Here the city’s binding order never listed specific problems — it pointed to general code chapters M124 — yet the city then mailed the owner a penalty bill about once a month for more than two years. M146–M615 R.26-1965 Each of those 23 bills recites the very same rule, and that rule lists two different alternatives — either the property is causing harm, or the owner is repeatedly not complying with an earlier order — but the bill never says which one applies or gives any facts to back either. It recites a menu and supplies no findings: nothing about harm at this house, and no earlier order spelled out enough to be “not complied with.” M146
Every one of those bills carries the same supervisor’s signature block — the Principal Building Inspector M147 — stamped on top as the approval. The signature is the identical image each time, not a fresh hand-signed name, which only became visible after the owner’s representative forced the full set of mailed orders out of the city through public-records requests R.25-3549 R.26-1549 R.26-1965 and they could be lined up side by side. The supervisor holds a real, authorized job; the problem is that his approval block kept validating penalty after penalty built on a violation the city never actually spelled out. Card 9
Bottom line: the city’s own file shows 23 penalty orders — each approved under the same supervisor’s signature block and each reciting the same two-part rule without ever saying which part applies or giving any facts — stacked on top of violations it never specified, a pattern that only became clear once the full set of mailed orders was pried loose through records requests. R.25-3549 R.26-1549The May production the City closed as complete carries 23 distinct Order Imposing Administrative Penalty documents for Case 23-009185 M146–M615, running monthly from the first order to the last. Each order recites the same subsection — the full two-prong Level C definition under SCC 1.28.010 D3(c) (either “harm to public or private property” or “repeated or continuous noncompliance with … a hearing examiner’s order … or notices of violation”), with no prong selected and no underlying facts supplied M146 — and each carries the “Bo Cosley / Principal Building Inspector” signature block on its signing page. M147 M615 Twenty-one orders impose $1,000.00; two impose $2,000.00. M585 M615 Cosley holds an authorized position SCC 15.04.100; this is the supervisor-branded approval point applied month after month to a predicate the City never reduced to property-specific findings. Card 9 The mailed-corpus review Card 54 reads the recurring “Bo Cosley” cursive as a repeated templated digital signature image, not per-order wet ink.
When a city decides a building is unsafe, it is supposed to write down exactly what is wrong before it starts charging the owner money. Here the city’s binding order never listed specific problems — it pointed to general code chapters — yet the city then mailed the owner a penalty bill about once a month for more than two years. Each of those 23 bills recites the very same rule, and that rule lists two different alternatives — either the property is causing harm, or the owner is repeatedly not complying with an earlier order — but the bill never says which one applies or gives any facts to back either. The supervisor holds a real, authorized job; the problem is that the identical signature image validated penalty after penalty built on a violation the city never spelled out.
The binding Notice and Order recites that the property is in “sub-standard and/or dangerous condition under … Chapter 8.96 and/or Chapter 8.100” M124 and is signed for Cosley on its face; no produced record reduces that to a property-specific finding before the 08/29/2025 violation-list expansion. M012 M013
Administrative penalties ran from 06/29/2023 through the 11/18/2025 cycle, itemized in the master ledger. Card 13
The May file holds the Order Imposing Administrative Penalty documents for 23 distinct penalty dates, each headed “ORDER IMPOSING ADMINISTRATIVE PENALTY (Sacramento City Code 1.28.010).”
The orders recite SCC 1.28.010 D3(c) in full — Level C violations are those that “either: (1) are likely to cause … harm to public or private property; or (2) show repeated or continuous noncompliance with … a hearing examiner’s order … or notices of violation” — and select neither prong with any property-specific finding.
“SCC 1.28.010 D3 (c) - Level C violations are violations that present circumstances that either: (1) are likely to cause and/or do cause harm to public or private property; or (2) show repeated or continuous noncompliance with: (i) a hearing examiner’s order or orders, or (ii) orders or notices of violation issued by any agency or commission authorized to issue such orders or notices.” M146 — First Order Imposing Administrative Penalty, 06/29/2023
The mailed-corpus review reads the same stroke pattern, slant, and trailing flourish recurring across the orders — supervisor-branded validation rather than per-order wet ink.
The underlying violations were never reduced to property-specific findings M124 Card 9; the City ran a monthly penalty stream against that predicate Card 13; 23 of those orders each carry the Principal Building Inspector signature block M147 M615 and the same two-prong Level C definition without selecting a prong or supplying facts M146 SCC 1.28.010; and the signature itself is a repeated templated image Card 54. On the City’s own record, the supervisor-branded penalty machinery validated an unspecified predicate month after month.
The strongest realistic City response is that the signature block reflects routine supervisor review of a properly cited Level C violation; that prong (2) is valid for continuing noncompliance with an unappealed Notice and Order; and that any imprecision in the underlying violations was the owner’s burden to challenge on appeal. That response fails for three reasons. First, routine supervisor review presupposes a record to review — and the file shows no factually specified findings and no documented amendment of the Notice and Order. M124 Card 9 Second, reciting the two-prong Level C definition cannot stand in for findings: neither prong is selected, and prong (2)’s “repeated … noncompliance” requires a specified order to be noncompliant with, while prong (1) requires a finding of harm to property the record never makes. Third, Cosley holds an authorized position — that is not the point; the point is that the same block validated 23 penalty orders on an unspecified predicate, with the signature applied as a templated image. Card 54 R.25-3549 R.26-1549 Card 47