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.
The City issued 23 monthly penalty orders against this property for violations it never specifically described or reduced to factual findings. Each order recites a general rule that lists two different possibilities—either the property is causing harm or the owner is failing to comply with a previous notice—but the City never selected which prong applied or provided facts to support either one. While the orders carry the signature block of the Principal Building Inspector, this signature appears to be a repeated digital image applied to each document month after month. The fines began based on an initial notice that only cited broad chapters of the city code without identifying specific problems at the house. These monthly penalties, which totaled 23 orders over more than two years, cost the owner $1,000 per month before doubling to $2,000 for the final two cycles. This created a process where a supervisor’s stamp validated a series of recurring fines for unspecified violations that the City’s own records never clearly defined.
The 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 C09. The mailed-corpus review C54 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. 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." Every one of those bills carries the same supervisor's signature block — the Principal Building Inspector — stamped on top as the approval. 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 M124; no produced record reduces that to a property-specific finding before the 08/29/2025 violation-list expansion M012–M013. The pre-access fee theory is C09.
Administrative penalties ran from 06/29/2023 through the 11/18/2025 cycle, itemized in the master ledger C13.
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" M146 — and select neither prong with any property-specific finding: the order supplies no facts showing harm to property under prong (1), and none identifying the order or notice the noncompliance under prong (2) runs against.
The mailed-corpus review C54 reads the same stroke pattern, slant, and trailing flourish recurring across the orders — supervisor-branded validation rather than per-order wet ink.
The following records, if they exist, would bear directly on this card. The produced set — closed as complete under R.25-3549 and R.26-1549 — contains none of them:
The underlying violations were never reduced to property-specific findings M124 C09; the City nonetheless ran a monthly penalty stream against that predicate C13; 23 of those orders each carry the Principal Building Inspector signature block M147 M615 and the same two-prong Level C definition recited without selecting a prong or supplying facts M146; and the signature itself is a repeated templated image C54. On the City's own record, the supervisor-branded penalty machinery validated an unspecified predicate month after month.
Anticipated City defense: 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, not a defect of the penalty cycle.
Answer: That response fails for three reasons. First, routine supervisor review presupposes a record to review — and the file the City closed as complete shows no factually specified findings underlying the orders M124 C09 and no documented amendment of the Notice and Order M124. Second, reciting the two-prong Level C definition cannot stand in for findings the record does not contain: 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 C54. The N&O delegation-execution question — the inspector signing the order itself — is a separate authority theory carried by C04.
The penalty category and prong-selection problem is anchored in SCC § 1.28.010. ---