The Fee-Bearing Amendment Trigger
The City's inspector put a price on correcting the violation list: $1,400. On an email hand-dated 8/27 — a Wednesday, August 27, 2025, six days after the City's first recorded backyard inspection [M035] — Paul Lovato wrote to the owner's helper, copying two others: "I can amend the violations on the property, but what that will trigger is another notice & order to be sent out with the new violations on it and the Notice & Order comes with a fee of $1,400. We were just hoping the violations are corrected so we can close out the case." [S5] The subject line carries the City's own address typo, "Re: Inspection at 4800 T ST" [S5]. The source is an owner-side image of the email, read by eye; it does not appear in the file the City produced under Request 26-1965 [R.26-1965.1].
Six days after that email, on September 2, 2025, the City did send another Notice and Order. Its letter gives the City's reason for charging nothing: "Due to the fact that there has been a previous Notice and Order issued pertaining to the violations existing on this property, for which fees have been assessed, the current Notice and Order does not assess any additional fees" [M552]. Its Correction List carries the new violations from the backyard inspection — dry-rot at siding and trim, added square footage at the detached garage, extension cords wired together, a shower and a gas line in the backyard [M544] — on top of the two April 2023 entries, the ones that said of themselves "Neither interior nor exterior has been completely inspected" [M125] (Card 3: what the $305-per-inspection fee and the $400 appeal attached to; Card 11: the ledger). When the owner's helper had called the City about appeals on 04/10/2025, the City's own note records staff explaining that "the HCAAB is appealing the monitoring fee and not the violation" [M033].
Why was the owner's helper told that amending the violations would come as another Notice and Order with a fee of $1,400 [S5], when six days later the City served the amended list [M544] under a letter that says the order "the current Notice and Order does not assess any additional fees" [M552] — and where in the file the City produced under Request 26-1965 [R.26-1965.1] is the page that told the owner the amendment was free?
IN PLAIN TERMS
A violation list tells the owner what must be fixed, what can be appealed, and what the fees measure. In August 2025 the inspector wrote that he could change the list, but that changing it meant another Notice and Order with a $1,400 fee [S5]. Six days later the City sent the changed list [M544] with a letter saying the new order charged nothing [M552]. The City's own call note had told the owner's helper that the appeal board hears the fee, not the violation [M033]. The question for the City: why was the owner's helper told the change would cost $1,400 when the City made it six days later for free — and where in the file the City produced is the page that told the owner so?
RECORD CHAIN
- April 10, 2025 — the City explains the appeals to the owner's helper. The same entry [M033] records staff explaining the appeal routes to the owner-side helper, including that "the HCAAB is appealing the monitoring fee and not the violation [M033]."
- April 10, 2025 — who the email went to. The 04/10/2025 activity log entry [M033] describes the owner's helper as the property owner's friend/helper assisting with the appeal process; the email stating the amend-triggers-fee mechanism was addressed to her [S5].
- August 27, 2025 — "I can amend the violations on the property". The email states, "I can amend the violations on the property [S5]." The email frames the change as triggering a new order "with the new violations on it [S5]."
- August 27, 2025 — the amendment priced at $1,400. The same sentence connects the amendment to "another notice & order ... with a fee of $1,400 [S5]."
- September 2, 2025 — another Notice and Order, with the new violations on it, at no fee. The Notice and Order reissued on 09/02/2025 [M552] comes with a letter stating that "the current Notice and Order does not assess any additional fees [M552]." Its Correction List [M544] carries the backyard findings of 08/21/2025 — East side of property shows signs of dry-rot at siding and trim [M544], Added square footage at detached garage to be permitted [M544], Service panel dead front removed with extension cords tied in to breakers [M544], Added gas line for dryer in backyard requires permits [M544] — none of which is on the April 2023 list [M125].
FULL CIRCLE
The City's first available answer is the letter's own reason: "Due to the fact that there has been a previous Notice and Order issued pertaining to the violations existing on this property, for which fees have been assessed, the current Notice and Order does not assess any additional fees" [M552] — the $1,400 was not charged, so the price in the email did not come into play.
That answer is the card. On August 27 the inspector told the owner's helper that amending the violations would trigger "another notice & order to be sent out with the new violations on it and the Notice & Order comes with a fee of $1,400" [S5]. Six days later the City sent that order, with the new violations on its Correction List [M544], under a letter saying it "the current Notice and Order does not assess any additional fees" [M552]. The amendment the inspector priced at $1,400 was made at no charge; the price quoted to the owner's side was one the City's own next order did not collect.
The City's second available answer is that the owner's route to the list was the appeal, offered on the reissued order at $560.
That letter offers an appeal of the requirements of the Notice and Order [M552], within thirty days, at $560 — another price, on the order that came after the email. The City's own note of the helper's call says what the board hears: "the HCAAB is appealing the monitoring fee and not the violation" [M033]. The file the City produced under Request 26-1965 [R.26-1965.1] holds no page in which the City told this owner, before the amended order arrived, that the list could be corrected at no fee.
What would defeat this card is a page served on the owner, between the 08/27 email and the 09/02/2025 order, telling the owner the list would be corrected at no fee. The file the City produced under Request 26-1965, closed with "All responsive records have been provided." [R.26-1965.1], holds none. Card 4 is the completeness baseline (what the file the City produced means, and does not mean); Card 46 carries the City's three inconsistent closures on one case email.
APPLICABLE LAW
- SCC.8.100.720(A)(2): requires the Notice and Order to contain "a brief and concise description of the conditions found to render the building substandard" - that description is the object a monitoring fee measures compliance against and the object an appeal of the order addresses.
SOURCE CITATIONS USED BY THIS CARD
- S5 - Owner-side scanned image of Paul Lovato's email to the owner's helper, subject "Re: Inspection at 4800 T ST"; states he can amend the violations, that amendment would trigger another Notice and Order with a $1,400 fee, and that the City hoped the violations would be corrected so the case could close.
- M035 - May 2026 p.35: Paul Lovato's case note of 08/21/2025 — the first backyard inspection the file records.
- M125 - May 2026 p.125: the Correction List attached to the April 12, 2023 order — B31 "Other", B59 "Permits Required", "Neither interior nor exterior has been completely inspected."
- M033 - Case File page 33. 04/10/2025 activity log entry describing the owner's helper (named on the page) as the property owner's friend/helper and saying she was helping the owner with the appeal process; records staff explaining the appeal routes to her, including that "the HCAAB is appealing the monitoring fee and not the violation."
- M544 - Case File page 544. Correction List, Case 23-009185, in the 09/02/2025 reissued Notice and Order packet (M543 is the order dated 09/02/2025; M552 is the packet letter and proof of service listing "Correction List"). Carries the two April 2023 codes and adds ten new coded violations with backyard comments matching the 08/21/2025 inspection note (M035).
- M552 - Case File page 552. September 2, 2025 reissued Notice and Order cover letter (with "REISSN&O/MA" in the document/address line), served by Monica Atkins on 09/02/2025. States the reason for charging nothing ("Due to the fact that there has been a previous Notice and Order issued pertaining to the violations existing on this property, for which fees have been assessed, the current Notice and Order does not assess any additional fees"), states the owner's right to appeal the requirements of the Notice and Order to the Housing Code Advisory and Appeals Board at $560, and restates compliance timelines. The same packet's Correction List (M544) carries the new backyard violations.
- R.26-1965.1 - NextRequest 26-1965 portal/closure page recording the May 2026 production as closed with "All responsive records have been provided."
- R.26-1965 - NextRequest 26-1965 searchable CitizenServe case-file request, https://cityofsacramentoca.nextrequest.com/requests/26-1965 — Public request/provenance source for
M.
CARD REFERENCES
- Card 3 - The Placeholder Fee and Appeal Predicate: the $305-per-inspection fee and the $400 appeal, attached to the incomplete list.
- Card 11 - The $36,020.40 Placeholder Ledger: every charge run against the same two entries.
- Card 14 - The Undocumented Rate Doubling: a separate question from this card's price-to-amend.
- Card 46 - The Inconsistent Closures on the Same Case Email: why the production baseline matters for an email the file does not carry.
- Card 4 - Fourteen Written CPRA Completeness Determinations: the production-completeness baseline.