The Undocumented Rate Doubling

Case 23-009185 | Card 14 | 4880 T Street, Sacramento CA 95819

The City's activity log assesses the administrative penalty on this case in numbered cycles. The 1st-cycle order, dated 06/29/2023, imposed $1,000.00 M146, and the 22nd-cycle activity-log directive of 07/24/2025 stated $1,000 M009. On 10/16/2025, Paul's case-history entry directed a 23rd Level C administrative penalty of $2,000, with generic rationale M036. The 10/17/2025 send directive reads "Please send 23rd HSG Admin penalty of $2,000" M010, and the Order Imposing Administrative Penalty issued that day orders the owner to pay $2,000.00 M585. No separate pre-10/17/2025 hearing decision, supervisor authorization, City Council action, amended fee-schedule entry, or rationale explaining why the amount moved from $1,000 to $2,000 per cycle appears in the produced file for this case.

The penalty is imposed as Level C under SCC.1.28.010. That section sets a Level C range of $1,000.00 to $2,499.99, gives the department head or designee discretion to set the amount using listed factors, and defines no automatic, duration-based escalation schedule. The 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);" Both $1,000 and $2,000 fall within that range. The produced record documents the $2,000 amount but does not include a separate rationale or approval record explaining why the higher amount was selected.

The City's documents agree that the 23rd cycle was $2,000. The finding concerns the step between the 22nd-cycle $1,000 directive and the 23rd-cycle $2,000 order: the produced file does not show a separate approval or rationale for selecting the higher amount within the Level C range.

IN PLAIN TERMS

For twenty-two rounds, the City billed this recurring fine at $1,000. On the 23rd round, in October 2025, the amount became $2,000. The city code allows fines in this range, but it has no rule that raises the amount automatically as time passes; an official chooses the figure. The case file the City produced, and stated was complete, contains no separate hearing result, supervisor approval, fee-schedule change, or written explanation for the higher amount beyond Paul's own case-history entry.

RECORD CHAIN

The $1,000 anchors. The produced anchor records show the 1st-cycle order at $1,000.00 M146 and the 22nd-cycle activity-log directive at $1,000 on 07/24/2025 M009.
The 23rd cycle opens at $2,000. Paul's 10/16/2025 case-history entry directs a 23rd Level C administrative penalty of $2,000 M036; the 10/17/2025 activity-log directive M010 and the order issued that day M585 both state $2,000.
The produced file contains no separate authorization or rationale for the higher amount. It contains no separate hearing decision, supervisor sign-off, fee-schedule amendment, or Council action, and the order itself does not cite any instrument or rationale for moving the per-cycle amount from $1,000 to $2,000.
The gap is internal to the City's own production. The doubled amount appears on the face of the City's own order; no separate authorizing or explanatory record appears in a file the City has stated is complete Card 4.

FULL CIRCLE

The record on this point is short. The penalty rose from $1,000.00 on the 1st-cycle order M146 to $2,000.00 on the 23rd-cycle order M585; the 22nd-cycle directive, the last before the change, states $1,000 M009. Paul's 10/16/2025 case-history entry directed the 23rd penalty at $2,000 M036, and the 10/17/2025 directive and issued order carry that figure M010 M585. The produced file, closed as complete, contains no separate record explaining the change Card 4.

The expected counter-position is that the escalation from $1,000 to $2,000 is automatic under duration-of-noncompliance tiers in the Sacramento City Code administrative-penalty schedule, so that no case-specific authorization needs to appear in the file. The cited section does not define such a schedule. SCC.1.28.010(D)(3)(c) sets a Level C range of $1,000.00 to $2,499.99, and Section 1.28.010 defines no automatic, duration-based escalation or doubling trigger; it commits the amount within the range to the department head or designee, applying listed factors. The produced record documents the $2,000 amount, but not a separate rationale or approval record explaining why the higher amount was selected. Where the same supervisor signature block validates every cycle, that undocumented rationale/approval issue also touches Card 15.

On the record the City produced and closed as complete Card 4, the per-cycle administrative penalty doubled mid-case from $1,000 to $2,000, and the produced file contains no separate authorization or rationale for the change M009 M010 M036 M146 M585.

APPLICABLE LAW

SCC.1.28.010: Sacramento City Code administrative penalties; Level C range of $1,000.00 to $2,499.99 at subsection D.3.c. The section gives the department head or designee discretion to set the amount using listed factors and defines no automatic duration-based escalation schedule; this card treats the move from $1,000 to $2,000 within the Level C range as a discretionary selection requiring explanation in the case record.

SOURCE CITATIONS USED BY THIS CARD

M009 — p. 9: activity-log entry for the 22nd penalty cycle; the $1,000-cycle directive reads "Please send 22nd HSG Admin penalty of $1,000," dated 07/24/2025.
M010 — p. 10: activity-log directive "Please send 23rd HSG Admin penalty of $2,000," dated 10/17/2025; 23rd-cycle directive at the doubled figure after prior HSG Admin directives through the 22nd cycle at $1,000.
M036 — p. 36: 10/16/2025 case-history entry by Paul directing the 23rd Level C administrative penalty at $2,000 with generic rationale.
M146 — p. 146: 1st-cycle Order Imposing Administrative Penalty; Penalty Amount $1,000.00; Penalty Category C; dated 06/29/2023.
M585 — p. 585: 23rd-cycle Order Imposing Administrative Penalty; Penalty Amount $2,000.00; Penalty Category C; dated 10/17/2025; payment deadline 11/07/2025; cites SCC.1.28.010(D)(3)(c).
Case File — M; full May Case File review, provenance R.26-1965; searched for any separate hearing decision, supervisor authorization, fee-schedule amendment, Council resolution, or rationale explaining the Level C per-cycle increase from $1,000 to $2,000 for Case 23-009185 beyond Paul's 10/16/2025 case-history direction. No such separate record found. Search performed 2026-06-10.
R.26-1965 — May 2026 master CPRA production; City closed as "all responsive records have been provided," May 22, 2026

CARD REFERENCES

Card 15 — Principal Building Inspector signature block validated penalty orders on the same Level C noncompliance catch-all; the undocumented rate change touches the same signature chain.
Card 11 — Master penalty ledger; documents the 23rd $2,000 administrative-penalty cycle and the later 11/18/2025 $2,000 administrative-penalty cycle that was waived to $0.
Card 4 — Closed-as-complete production baseline: the City's declaration that its production is complete is the evidentiary basis for "the authorizing record does not appear in the file."