The Holiday-Eve Appeal Clock
Twice, in consecutive years, a penalty order for 4880 T Street went onto the front door the day before a holiday. On 11/22/2023 at 9:39 a.m., the day before Thanksgiving, the City's log records: "I posted Order Imposing Administrative Penalty and Building Monitoring fee on the front door" [M003]. On 12/24/2024, Christmas Eve: "I posted a Admin. Penalty/HDB Monitoring Fee on the front door" [M007]. Each order prints its own clock. The fifth penalty order, dated 11/22/2023, reads on page 211 of the 631-page file [R.26-1965.2]: "You may appeal the imposition of this administrative penalty within 20 calendar days after the date this order is served by filing with the Office of the City Clerk a written notice of appeal and paying an appeal fee in the amount of $100.00. If you fail to appeal, this order shall be final." [R.26-1965.2] The sixteenth, dated 12/19/2024, prints the same block on page 395 [R.26-1965.2]. The monitoring-fee order that travels with each carries its own appeal block on the same twenty-day terms [M133].
The City's own pages carry the rest of each timeline, and they answer the first question a reader would ask. The fifth order did not sit: the inspector's entry of 11/21/2023 reads "Any contact from owner? Permits acquired? Send 5th admin penalty / 5th Monitoring fee." [M003]; the next day the clerk wrote "Please send 5th HSG Admin penalty of $1,000" [M003], the order was dated 11/22/2023 [R.26-1965.2] and prints "Payment Deadline: 12/13/2023" [R.26-1965.2], a first-class mailing was sworn "On 11/22/2023, I served the following document" [R.26-1965.2], the packet went on the door at 9:39 a.m., and the certified receipt came back as a green card logged 11/29/2023 [M003]. The sixteenth did sit: the inspector's entry of 12/18/2024 reads "Any contact from owner? Permits acquired? Send 16th admin penalty / Monitoring fee." [M007]; on 12/19/2024 the clerk wrote "Please send 16th HSG Admin penalty of $1,000" [M007], the order was dated 12/19/2024 [R.26-1965.2] and prints "Payment Deadline: 01/09/2025" [R.26-1965.2] and a first-class mailing was sworn "On 12/19/2024, I served the following document" [R.26-1965.2] — then the door posting came five days later, on Christmas Eve, and the green card was logged 01/02/2025 [M007]. Twenty calendar days from 11/22/2023 ended 12/12/2023; from 12/19/2024, 01/08/2025; from the Christmas Eve posting, 01/13/2025 — counted from any of the City's dates, both windows ran through the holiday. The sworn form the City prints for the door, the Declaration of Posting Notice, is blank for the fifth order [R.26-1965.2] and for the sixteenth [R.26-1965.2] (Card 17: all forty-nine of them are). The fifth and sixteenth cycles sit in the ledger (Card 11); every order in the run recites the same rule without choosing a half of it (Card 15).
With its own file showing the sixteenth order dated and mailed on 12/19/2024 [R.26-1965.2], posted on the front door on Christmas Eve [M007], its certified receipt logged back on 01/02/2025 [M007], and the sworn posting form for it left blank [R.26-1965.2] — which of those days did the City count as the day this order was served, the day it printed as the start of a twenty-calendar-day appeal window [R.26-1965.2], and where in the file it produced under Request 26-1965 (closed May 22, 2026 [R.26-1965.1]) is that day written down?
IN PLAIN TERMS
In consecutive years the City's log records penalty orders posted on this property's front door the day before Thanksgiving [M003] and on Christmas Eve [M007]. Each order gives twenty calendar days from the day it is served to appeal, for a fee, or it becomes final [R.26-1965.2]. The City's file gives each order more than one service day: the day it was written and mailed, the day it went on the door, the day the certified receipt came back — and the sworn form for the door posting is blank [R.26-1965.2]. Counted from any of them, both windows ran through the holiday. The question for the City: which of those days did it count as the day the sixteenth order was served, and where in the file it produced under Request 26-1965 (closed May 22, 2026 [R.26-1965.1]) is that written?
RECORD CHAIN
- June 29, 2023 — the first order and its clock. The first Order Imposing Administrative Penalty in the run is dated 06/29/2023 [M146]; its signing page states that an appeal is filed with the Office of the City Clerk within 20 calendar days after the date this order is served [M147], with an appeal fee, and that an order not appealed shall be final [M147]. The monitoring-fee order carries its own appeal block on the same twenty-calendar-day terms [M133]. The fifth order (page 211 [R.26-1965.2]) and the sixteenth (page 395 [R.26-1965.2]) print the same block.
- November 21 – 29, 2023 — the fifth cycle, in one day, the day before Thanksgiving. The re-inspection entry dated 11/21/2023 reads: "Any contact from owner? Permits acquired? Send 5th admin penalty / 5th Monitoring fee." [M003] On 11/22/2023 the clerk's entry reads "Please send 5th HSG Admin penalty of $1,000" [M003]; the order carries that date and "Payment Deadline: 12/13/2023" [R.26-1965.2]; the proof of service by first-class mail is sworn "On 11/22/2023, I served the following document" [R.26-1965.2]; and the POST NOTICE entry reads: "On 11-22-2023 at 9:39 am I posted Order Imposing Administrative Penalty and Building Monitoring fee on the front door" [M003]. Thanksgiving 2023 fell on November 23. The certified receipt is logged as a green card received 11/29/2023 [M003]. The Declaration of Posting Notice printed for this order has the day and the place left blank [R.26-1965.2]. The General Case Information log carries a matching narrative entry of the same posting [M026].
- December 18, 2024 – January 2, 2025 — the sixteenth cycle, posted on Christmas Eve. The re-inspection entry dated 12/18/2024 reads: "Any contact from owner? Permits acquired? Send 16th admin penalty / Monitoring fee." [M007] On 12/19/2024, a Thursday, the clerk's entry reads "Please send 16th HSG Admin penalty of $1,000" [M007]; the order carries that date and "Payment Deadline: 01/09/2025" [R.26-1965.2]; the proof of service by first-class mail is sworn "On 12/19/2024, I served the following document" [R.26-1965.2]. The POST NOTICE entry dated 12/24/2024 reads: "on 12/24/24 I posted a Admin. Penalty/HDB Monitoring Fee on the front door" [M007]. Christmas 2024 fell on December 25. The certified receipt is logged as a green card received 01/02/2025 [M007]. The Declaration of Posting Notice printed for this order has the day and the place left blank [R.26-1965.2]. The General Case Information log carries a matching narrative entry of the same posting [M031].
- June 30, 2023 – March 11, 2025 — the other postings in the log. Other postings fall on other dates — 06/30/2023 at 7:35 a.m. [M002], 02/07/2024 at 8:10 a.m. [M004], 11/15/2024 at 9:46 a.m. [M007], and 03/11/2025 [M007] — and on those days the clerk's issuing entry and the posting share a date, as they do on 11/22/2023.
- May 22, 2026 — what the file the City produced under Request 26-1965 holds for these two orders. For each: the order, a sworn first-class mailing declaration, the log's posting entry, a green-card entry, and a Declaration of Posting Notice with its day and place blank. The file the City closed on May 22, 2026 [R.26-1965.1] holds no page naming which of those days the City counted as the day of service, no page stating the day either appeal window closed, and no posting-route or work-assignment record for 11/22/2023 or 12/24/2024 (Request 26-1965).
FULL CIRCLE
The City's first available answer is that a recurring cycle, not a chosen day, set these orders in motion; that the clerk's issuing entries show the November order went out the day it was generated and the December order three business days after; and that both eves were ordinary business days.
The November pages bear that out: directive, clerk entry [M003], sworn mailing [R.26-1965.2] and door posting [M003] all on 11/22/2023 — the last business day before Thanksgiving, with the twenty calendar days ending 12/12/2023 and the City's own receipt back on 11/29/2023 [M003]. The December order was dated and mailed on Thursday 12/19/2024 [R.26-1965.2]; Friday the 20th and Monday the 23rd passed; the door posting came on the fifth day, Christmas Eve [M007]. The payment date the City printed on that order, "Payment Deadline: 01/09/2025" [R.26-1965.2], is counted from 12/19/2024, not from the door — on the City's own count, five of the twenty days had run before the packet was posted.
The City's second available answer is that posting is one form of service among several; that the mailed copy carries its own sworn date; and that these orders go out "CERTIFIED AND FIRST CLASS" [M007], as the returned-mail entry of 03/07/2025 shows.
Granted, and that is the point. For the sixteenth order the City's file gives a mailing sworn 12/19/2024 [R.26-1965.2], a posting on 12/24/2024 [M007], and a certified receipt logged 01/02/2025 [M007]; the one sworn form that would fix the posting day is blank [R.26-1965.2] (Card 17). Twenty calendar days from the mailing ended 01/08/2025, six days after the City logged its receipt; from the posting, 01/13/2025. The mailing declaration swears to a mailing; it does not say which day the City counted from, and the file the City produced under Request 26-1965 (closed May 22, 2026 [R.26-1965.1]) holds no page that does.
What would defeat this card is a page in the file the City produced under Request 26-1965 — a completed Declaration of Posting for either order, a posting-route or work-assignment record for 11/22/2023 or 12/24/2024, or an entry naming the day the City counted as service and the day each appeal window closed. The file the City closed with "All responsive records have been provided." [R.26-1965.1] holds none of them. Card 4 is the completeness baseline (what the file the City produced means, and does not mean).
APPLICABLE LAW
- SCC.1.28.010: Sacramento City Code Chapter 1.28, the City's administrative-penalty chapter
- The appeal terms applied here are the ones the City printed on the orders themselves: an appeal filed with the Office of the City Clerk within 20 calendar days after the date this order is served, with the appeal fee, and an order that is final if no appeal is filed (the fifth order, page 211; the sixteenth, page 395); the monitoring-fee order carries its own appeal block on the same twenty-calendar-day terms
SOURCE CITATIONS USED BY THIS CARD
- M002 — POST NOTICE summary entry: William Ely, 06/30/2023, 7:35 a.m. Routine non-holiday posting used as baseline contrast.
- M003 — POST NOTICE summary entries, including: William Ely, 11/22/2023, 9:39 a.m., "I posted Order Imposing Administrative Penalty and Building Monitoring fee on the front door." Also contains Jeremiah Carter postings dated 09/11/2023 and 10/23/2023. Also the 11/21/2023 re-inspection directive, the 11/22/2023 clerk entry "Please send 5th HSG Admin penalty of $1,000", and the 11/29/2023 GREEN CARD RECVD entry. This is the Thanksgiving Eve 2023 posting entry.
- M004 — POST NOTICE summary entry: William Ely, 02/07/2024, 8:10 a.m. Routine non-holiday posting used as baseline contrast.
- M007 — POST NOTICE summary entries: Carl Tafoya, 12/24/2024, "I posted a Admin. Penalty/HDB Monitoring Fee on the front door"; William Ely, 11/15/2024, 9:46 a.m.; Jeremiah Carter, 03/11/2025. Also the 12/18/2024 re-inspection directive, the 12/19/2024 clerk entry "Please send 16th HSG Admin penalty of $1,000", the 01/02/2025 GREEN CARD RECVD entry and the 03/07/2025 LETTER RETURNED entry ("CERTIFIED AND FIRST CLASS"). This is the Christmas Eve 2024 posting entry; also contains routine non-holiday posting dates used as baseline contrast.
- M026 — General Case Information log, matching narrative entry of the 11/22/2023 Thanksgiving Eve posting.
- M031 — General Case Information log, matching narrative entry of the 12/24/2024 Christmas Eve posting.
- 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; public provenance for
M - M146 — the first Order Imposing Administrative Penalty in the run, dated 06/29/2023 (with the 06/28/2023 certified-mail proof of service above it); the date for RECORD CHAIN item 1.
- M147 — signing page that follows the 06/29/2023 order (undated on its face): the printed "YOUR RIGHT TO APPEAL" block and the "Bo Cosley / Principal Building Inspector" signature block.
- R.26-1965.2 — the 631-page May 2026 case file. Pages used on this card: 210 – 211, the fifth Order Imposing Administrative Penalty dated 11/22/2023 ("Payment Deadline: 12/13/2023") and its "YOUR RIGHT TO APPEAL" block; 214, proof of service by first-class mail sworn 11/22/2023; 215, the blank Declaration of Posting Notice for that order; 395, the sixteenth order dated 12/19/2024 ("Payment Deadline: 01/09/2025") with its appeal block; 399, proof of service by first-class mail sworn 12/19/2024; 400, the blank Declaration of Posting Notice for that order.
- M133 — Declaration of Posting Notice page, followed by the Order Imposing Housing and Dangerous Buildings Monitoring Fee carrying its own "YOUR RIGHT TO APPEAL" block on the same twenty-calendar-day terms.
- SCC.1.28.010 — Sacramento City Code Chapter 1.28 on the City's code library; cited on this card only as the City's administrative-penalty chapter.
CARD REFERENCES
- Card 17 — the forty-nine Declaration of Posting forms in the file, all blank where the log says they are.
- Card 15 — The Ground the Order Left Out: every penalty order in the run recites both halves of the rule and picks neither.
- Card 11 — The $36,020.40 Placeholder Ledger: the fifth and sixteenth cycles inside the total.
- Card 4 — Fourteen Written CPRA Completeness Determinations: the production-completeness baseline.