The served order’s only violations were two placeholder codes its own list called incomplete, naming no condition.
Before a city can declare a building substandard and start charging the owner, its written order is supposed to spell out what specifically is wrong — name the structure, the work, or the condition. SCC §8.100.720(A)(2) SCC §8.96.130(B)(2) Here the city’s first letter told the owner to call and schedule an inspection, so by its own words it had not inspected yet; M117 the letter attached a two-line list that said in plain print, “Neither interior nor exterior has been completely inspected.” M118 When the binding, fee-bearing order went out weeks later, it carried that exact same two-line list — word for word — instead of any real findings. M124 M125 One code just says “Other” with no description; the other says a permit is needed but names no structure or work. SCC §8.100.190 The owner then had thirty days to appeal an order that never said what to appeal, M130 while the city kept billing monthly penalties and monitoring fees for more than two years D.1 before it was ever let onto the property. M35 That the order still carried the placeholder list, and that the identical wording shows up in every later batch the city handed over, only became clear after the owner’s representative forced the records out through repeated public-records requests and lined the productions up side by side. R.25-3549 R.26-1549 R.26-1965
Bottom line: the city issued a binding, fee-bearing order whose only “violations” were two placeholder codes its own attached list called incomplete — naming no actual condition — and then ran the appeal clock and the billing against that undefined target for more than two years.The City’s substandard-building procedure treats the preliminary correction list as a placeholder pending the inspection the letter demands: the list is meant to be updated to the inspector’s actual findings, and the order issues from the updated list. That did not happen. The Buster Preliminary letter M117 attached a Correction List M118 with two entries — B31 “Other” and B59 “Permits Required” — stating on its face that the list was not complete and that neither interior nor exterior had been inspected. The Notice and Order’s Correction List M125 carried the same two entries; the two served lists are byte-for-byte identical in their B31 and B59 text.
Before a city can declare a building substandard and start charging the owner, its written order is supposed to spell out what specifically is wrong — name the structure, the work, or the condition. SCC §8.100.720(A)(2) Here the city’s first letter told the owner to call and schedule an inspection, M117 so by its own words it had not inspected yet; the letter attached a two-line list that said in plain print, “Neither interior nor exterior has been completely inspected.” M118 When the binding, fee-bearing order went out weeks later, it carried that exact same two-line list — word for word — instead of any real findings. M124 M125 One code just says “Other” with no description; the other says a permit is needed but names no structure or work. SCC §8.100.190 The owner then had thirty days to appeal an order that never said what to appeal, M130 while the city kept billing recurring $1,000 administrative penalties and monitoring fees on a monthly cycle for more than two years D.1 before it was ever let onto the property. M35
The first document mailed — the Buster Preliminary letter — ordered the owner to call within ten business days “to schedule an inspection of the property.” M117 Swap the name and address and the violation list fits any house in Sacramento: it is the demand letter’s generic codes, copied word for word, with nothing inspected and nothing added.
Each entry is laid out Code / Description / Full Violation / Comments. B31 concedes incompleteness on its face:
“This is not a complete Violation List of building code violations. Neither interior nor exterior has been completely inspected. Other building structural, electrical, plumbing or mechanical code violations may be identified upon further inspection.” M125 — N&O Correction List, B31 entry
B59 recites stock language under SCC §8.100.190 — “Work has been done without the benefit of a PERMIT…” — but names no structure, work item, location, or condition. M125
SCC §8.100.720(A)(2) — and the dangerous-building parallel SCC §8.96.130(B)(2) — require the order to contain “a brief and concise description of the conditions found to render the building substandard.” The order recites only that the conditions “are set forth on the attached list of violations,” M124 and that attached list M125 carries only “Permits Required” with no identified structure or work, and “Other” with no description.
The order is what the appellant must contest, and the description it carries is the target an appeal would attack. The thirty-day appeal window, measured from the order’s issuance date, M124 M130 ran against an undefined target. The same B31/B59 wording appeared unchanged in two prior CPRA productions — the April 2026 production R.26-1549 and the November 2025 production R.25-3549 — with no amendment adding property-specific conditions before the window closed.
The same two placeholder codes — which the City’s own Correction List said were not final findings — remained the only violations of record in the City’s produced file from the 04/12/2023 order M124 until the City’s first on-property access on 08/21/2025 M35 — the first time staff were “allowed in to the backyard.” Across that span the City billed recurring $1,000 administrative penalties and monitoring fees at $380 per request — 24 monitoring-fee requests from 05/2023 through 10/2025. D.1
The City’s procedure required the preliminary placeholder list to be replaced by the inspector’s actual findings before the order issued. M117 M118 The served order carried the identical B31/B59 placeholders, M125 which on their face admit the inspection was incomplete; the order therefore recites no description of conditions found beyond pointing to that list, M124 where the content rule requires one. SCC §8.100.720(A)(2) SCC §8.96.130(B)(2) Consequently, the appeal window M130 ran against a target that was never defined. On the City’s own record, the served order names no property-specific violation.
The anticipated City defense is that B31/B59 are standard intake codes and specifics would follow at inspection. The answer is that SCC §8.100.720(A)(2) requires the description in the order the owner must appeal, M124 not at some later inspection; the City billed fees and ran an appeal window against codes its own list called non-final. M125 Intake placeholders cannot carry a binding, fee-bearing order.