The binding Notice and Order names an authorized official but is signed by an inspector the code does not list, with no produced delegation or approval record bridging that signature.
The City’s municipal code limits the authority to issue building orders to the Chief Building Official and four specific assistant titles. Although the April 2023 Notice and Order identifies Bo Cosley, a Principal Building Inspector, in its heading, the document was signed by Paul Lovato, a Building Inspector III whose title is not on the authorized list. This pattern repeated in September 2025 when the order was reissued under Willie Harris but again signed by Lovato. While the City correctly used an authorized official for a companion notice in this same case, the produced 631-page file contains no record of delegation or approval that would empower Lovato to sign for the building official. Without a record bridging this gap in authority, the City must either produce the missing authorization or correct the enforcement actions that rely on these signatures.
The April 12, 2023 Notice and Order face page M124 recites that the Chief Building Official "has caused to be inspected and has determined" the building substandard and/or dangerous, then orders repair or demolition under the City's Notice-and-Order procedure SCC § 8.100.720. The City's code fixes who may act as that official: SCC.8.96.105 ties the order-issuing "building official" to the Chief Building Official and the assistants described in SCC.15.04.100. SCC.15.04.100 lists those assistant titles: Deputy Chief Building Official, Principal Building Inspector, Supervising Engineer, and Code and Housing Enforcement Chief. The order's date line names Bo Cosley, Principal Building Inspector CITY.CodeEnforcementContacts, which is a listed title; the "By" signature beneath it is Paul Lovato, Building Inspector III, which is not. That is the procedural gap: if the City says Lovato could sign anyway, the City needs the authority bridge, and the produced file does not contain one.
SCC.8.96.105 defines the "building official" for this article to include the Chief Building Official and "his or her assistants as described in Section 15.04.100." SCC.15.04.100 lists the assistant titles in full: Deputy Chief Building Official, Principal Building Inspector, Supervising Engineer, and Code and Housing Enforcement Chief. The Chief Building Official class specification JOB.CBO.SacCity.33229 further defines the role. Building Inspector III and Building Inspector IV are not on that list.
The April 12, 2023 Notice and Order face page M124 is dated under "Bo Cosley, Principal Building Inspector," a title on the SCC.15.04.100 list. The signature line below it, after "By," is Paul Lovato, Building Inspector III, a title that does not appear in the authority list.
The recorded companion notice was signed by Peter Lemos, Code and Housing Enforcement Chief, another SCC.15.04.100 listed title (see C14). That matters because the record shows the City knew how to place a listed official behind this enforcement matter.
The closed-as-complete productions R.25-3549 R.26-1549 R.26-1965 contain no standing delegation, written designation, case-specific authorization, review note, approval email, task entry, or other record placing Lovato within the SCC.15.04.100 authority chain or empowering him to sign "By" for Cosley. A full-text search of the 631-page May 2026 production returns zero instances of "delegat," "designee," or "authorized representative" M001–M631.
This card does not depend on claiming that every "By" signature is automatically invalid. The narrower point is record-based: the City's own code identifies the official chain for the Notice-and-Order authority SCC § 8.96.105 SCC § 15.04.100, the April 2023 order's only signature line is by a title outside that chain M124, the same unbridged structure appears again in 2025 M543 M554, and the produced file contains no delegation, designation, routing, or approval record connecting Lovato to the listed official's authority M001–M631.
Anticipated City defense: The strongest City answer is that this was Cosley's order and Lovato merely executed it as routine practice.
Answer: Routine practice is not the missing record. If that signature path was authorized, the City should be able to produce the date-effective authority bridge, identify its scope, and explain why it was absent from the produced enforcement file. The corrective question is not "trust us"; it is production of the authority record or correction of the enforcement consequences that depend on it.
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