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.
The City doubled a recurring fine from $1,000 to $2,000 without including any documentation in the case file to explain why or who authorized the change. After twenty-two penalty rounds at $1,000 each, the City’s own internal instructions and the formal order for the twenty-third round both switched to $2,000. While city code allows for fines in this range, it does not contain a rule that automatically increases the amount based on how much time has passed. This means the increase was a specific choice, yet the official record contains no hearing results, supervisor approvals, or fee-schedule changes to support the move. Even though the City declared the case file to be complete, the paperwork shows the higher rate began with no recorded authorization behind it.
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.
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. On the twenty-third round, the City's own paperwork — both the internal instruction to "send" the penalty and the formal order to the owner — switched to $2,000, double the prior amount. The city code puts this kind of penalty in a band that runs from $1,000 to about $2,500, but it 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 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.
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.
The 100% increase appears on the face of the City's own order; the document that would authorize it does not appear in a file the City has declared complete C47.
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 C47. On the City's own record — declared complete under C47 — the rate doubled mid-case with no documented authorization in the produced file.
Anticipated City defense: 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.
Answer: 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. A move from $1,000 to $2,000 within that range is therefore a discretionary rate determination, and a discretionary 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. Where the same supervisor signature block validates every cycle, that undocumented discretion also touches C12.
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