The Missing September 16 Inspection Photographs

Case 23-009185 | Card 32 | 4880 T Street, Sacramento CA 95819

On June 4, 2026, the City closed CPRA Request 26-2206 — filed that same day asking for Bo Cosley's photographs from his September 16, 2025 inspection visit at 4880 T Street — with the verbatim statement: "The City does not have any records responsive to this request" R.26-2206.2. During that walkthrough, the property's own security cameras recorded a camera or phone raised and aimed toward the house.

On September 16, 2025, the porch camera recorded a blue-shirted person in dark pants at burned-in timestamps 10:03:01 and 10:03:11, and a second sidewalk-facing camera recorded the same apparent photographing/framing posture from another angle P2 P3 P4 P5 P6 P7. The identification rests on the porch/sidewalk frames, the City's own case note confirming PBI Cosley was onsite at 10:00 a.m. M036, and the property representative's contemporaneous identification in the walkthrough review notes V2.

No photographs attributed to Cosley from that walkthrough appear in any of the three case-file productions the City has closed as complete — not the November 2025 file, not the April 2026 re-export, not the May 2026 Case File. The documents index carries no 09/16/2025 Case-Photo entry attributed to Cosley M022. The owner's representative's targeted request for these photographs is the request the City closed on June 4, 2026 with the no-records statement R.26-2206.2.

The CCTV establishes a narrower predicate: a camera or phone was raised and aimed toward the house, conduct consistent with photographing or framing photographs. The stills do not, by themselves, show that an image file was saved. If image files were created and the City has none, the produced record does not account for their disposition between the walkthrough and the June 4, 2026 no-records response.

IN PLAIN TERMS

The City stated in writing, on June 4, 2026, that it has no photographs from Bo Cosley's September 16, 2025 inspection of 4880 T Street. The property's security cameras recorded that inspection. At 10:03 a.m., they captured the person identified in the walkthrough record as Cosley raising a camera or phone toward the house from the walkway and the sidewalk. No photograph from that visit appears in the City's documents index or in any of three case-file productions. If photographs were saved, they were either not preserved or not found in the City's search. This was an official inspection connected to the permit and compliance consequences that followed.

RECORD CHAIN

  1. The CPRA no-records closure. On June 4, 2026, the City closed a California Public Records Act request for Bo Cosley's photograph records from the September 16, 2025 visit to 4880 T Street with the statement that it had no responsive records R.26-2206.2. Under GC.7922.530, the City must make disclosable responsive records available; the closure is the City's record-position that no responsive records were available to produce. The request named the date, the inspector, and the property.
  2. The CCTV record of camera-or-phone use. Two cameras at the property recorded the blue-shirted person in dark pants on the walkway and then on the public sidewalk, a camera or phone raised to his face toward the house, at burned-in 10:03:01 and 10:03:11 on the porch frames P2 P3 P4 P5, with the sidewalk frames from a second camera carrying no burned-in stamp P6 P7. The stills support photographing or framing conduct; they do not, standing alone, prove that a shutter was activated or that an image file was saved.
  3. The case-file absence — three productions, zero photographs. The 09/16/2025 case note confirms Cosley on-site that morning M036. The documents index shows no 09/16/2025 Case-Photo entry attributed to Cosley; the surrounding Case-Photo rows are a 09/02/2025 Notice-and-Order packet image, a 09/11/2025 handyman document, and a 09/17/2025 correction notice M022. Three successive case-file productions — closed as complete on November 7, 2025; April 20, 2026; and May 22, 2026 — contain no 09/16/2025 Cosley photograph R.25-3549 R.26-1549 Case File.
  4. The three accounts consistent with the two records. The CCTV shows conduct consistent with photographing or framing photographs; the City stated it has no responsive records. One of three accounts must hold: (a) no image file was created or saved despite the camera-or-phone posture; (b) image files were created but never uploaded or retained in any City system; or (c) responsive photographs exist in a City system and the June 4, 2026 closure statement is inaccurate. The produced record does not identify which account applies.
  5. The walkthrough context. The September 16, 2025 walkthrough is the same event where, on the property's own audio, a City speaker said a permit was still required but explained that electrical work had been allowed to start because of a visible hazard; Paul also discussed the workshop in 120-square-foot / utilities-removal terms and described a falling-roof concern Card 31. Any Cosley photographs from that visit would date from the same event. Cosley's signature block appears on every administrative penalty order in this case Card 15. No photograph attributed to him from that walkthrough appears in any case file the City has produced to the owner.

The produced record shows the following on the points at issue:

FULL CIRCLE

The City's June 4, 2026 CPRA response stated that it had no photographs from Bo Cosley's September 16, 2025 inspection of 4880 T Street R.26-2206.2. The porch camera, with burned-in timestamps, and the sidewalk-facing camera show the blue-shirted person identified in the walkthrough record as Cosley raising a camera or phone toward the house from the front walkway and the public sidewalk P2 P3 P4 P5 P6 P7 M036 V2. The footage shows photographing or framing conduct; the response states that no responsive photographs exist.

If any image was saved, the no-records response means that photographs created by a Principal Building Inspector at an active enforcement property were not retained, uploaded, or preserved in any City system between September 16, 2025 and June 4, 2026. The person shown with the camera or phone is the official addressed in Card 15. The walkthrough is the same event as the property's audio-recorded safety and permit statements Card 31 and preceded the October 2025 permit track from which the contractor withdrew Card 36. No photograph from that morning appears in any case-file production.

The City may argue: An inspector's personal reference photographs taken during a walkthrough are not automatically case records; they may be deleted as working-file material without triggering CPRA obligations; and the CPRA closure was accurate at the time of the search.

The record answers each point. If any inspector photographs were created, used, or retained by the City in connection with the inspection, they are potential public records subject to CPRA search and production unless exempt; if withheld, CPRA requires an identified withholding basis GC.7922.530 GC.7922.540. The City's own case note records that the correction notice provided to the contractor "included pictures" M036 — photographs were attached to a case action that same day. And the no-records response is a factual statement; the CCTV stills document camera-or-phone use that the produced record does not account for.

When the owner's representative re-filed on June 23, 2026, the new request attached the property's own CCTV stills and sought the photographs' metadata, device and account identifiers, and any upload, deletion, non-retention, or search records. The City closed that request the same day as a "duplicate" of Request 26-2206 and its June 4 "no records" closure R.26-2492.1. The duplicate closure addressed neither the new CCTV evidence nor the new record categories. The CPRA framework and enforcement anchors for the missing-photo request are GC.7920.000 and GC.7923.000.

The produced record pairs an official no-records CPRA closure for Cosley's 09/16/2025 photographs with property CCTV showing photographing-or-framing conduct and three case-file productions containing no Cosley photograph from that walkthrough. The finding is the records-handling gap itself; the stills alone do not prove that a saved photograph exists.

APPLICABLE LAW

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