The Three Off-Order Conditions
The inspector emailed the owner's side a list of eleven things to do at 4880 T Street that appears on no order the City served. The list [S2], headed "Sac City Inspection 4..." [S2], opens "I have sent out the violation list a cpl times. I could spell it out a little better for inspections." [S2] and runs garage, main house, backyard: cover plates on the outlets, extension cords out, three framing inspections at the garage addition; the service panel, the fireplace siding, a window trim, "Fascia board replaced at the back of the dwelling at the roof." [S2], the front-yard landscaping power; the fence at the southwest corner cut down to seven feet [S2], the backyard shower, and "Workshop area reduced down to 120 Sq Ft and detached from the garage or removed. All utilities removed from the workshop area." [S2] It ends "These items are from my last inspection." [S2] It carries no photographs, no code section, no appeal advisory, and no date of its own. The two orders the City served — April 12, 2023 [M124] with its list [M125], and September 2, 2025 [M543] with its list read from its first entry [M544] to its last [M545] — carry the thirty-day appeal right [M543]; the fence height, the fascia board and the workshop's 120-square-foot condition are on neither, and the September list's only word on the workshop is "Added square footage at detached garage to be permitted" [M544].
The City's file holds no copy of that email and no such list as a document. What it holds is the inspector's own retyped text inside a note of 12/02/2025 [M037], entered after the owner's attorney wrote "Can you please email to me the list that you prepared and went over when we met at the property?" [M037] — the 09/16/2025 walkthrough, where the inspector's note says he handed the contractor "a correction notice, that included pictures" [M036], indexed the next day as "Correction Notice.doc" [M022] and not reproduced in the file either (Card 32). The owner's attorney called the meeting handouts "not the actual new Notice and Order" [E4]. The City's own permit guide in the same file gives a threshold, not a condition: no permit for accessory buildings "provided the floor area does not exceed 120 sq. ft. (and has no electrical)" [M119] and none for "Fences not over six feet high" [M119] — six feet where the emailed list says seven. What else moved through that channel is Card 34, Card 35 and Card 36; the file the City produced under Request 26-1965 [R.26-1965.1] holds no amended or supplemental order after the walkthrough.
Which served Notice and Order, carrying the thirty-day appeal right, ordered the eleven things on the list the inspector emailed [S2] — the fence cut down to seven feet [S2], the fascia board, the workshop "reduced down to 120 Sq Ft" [S2] with "All utilities removed" [S2] — when the two orders the City served [M125][M544] carry none of those three, the file the City produced under Request 26-1965 [R.26-1965.1] holds no copy of the email, no list as a document and no record of sending it, and the only trace of it there is the inspector's own retyped text in a 12/02/2025 note [M037]?
IN PLAIN TERMS
The inspector emailed the owner's side a list of eleven things to fix [S2]. It is not an order: no appeal rights, no code section, no date, no pictures. Three of the eleven — cut the fence to seven feet, replace the fascia board, shrink the workshop to 120 square feet and strip its utilities — are on no order the City ever served [M544]. The City's own file has no copy of that email and no such list; the only trace is the inspector's retyped text in a note [M037] two and a half months after the walkthrough, entered when the owner's lawyer asked him for the list. The question for the City: which served order carries that list?
RECORD CHAIN
- The rule — the appeal right attaches to a served order. The Notice and Order [M124] defines the abatement obligation and carries the appeal advisory [M123]. The Housing Code requires the order to contain "a brief and concise description of the conditions" [SCC.8.100.720(A)(2)] and a statement of required action [SCC.8.100.720(A)(2)] (SCC.8.100.720), with a parallel requirement for dangerous-building orders in SCC.8.96.130. The code requires service of the notice and order, amended notice, or supplemental notice (SCC.8.100.730), and requires any appeal to be filed within thirty days from the date of service [SCC.8.100.760(D)] (SCC.8.100.760). Under these provisions, the served order — original, amended, or supplemental — is the instrument that carries the 30-day appeal right.
- September 16 – December 2, 2025 — the list, its channel, and the City's only trace of it. 09/16/2025: the inspector's note says he gave the contractor "a correction notice, that included pictures" [M036]; 09/17/2025: the index row "Correction Notice.doc" [M022], the document itself not in the file (Card 32). 12/02/2025: the attorney's request, "Can you please email to me the list that you prepared and went over when we met at the property?" [M037], and the inspector's reply retyped into the same note, from "I have sent out the violation list a cpl times" [M037] to "These items are from my last inspection." [M037] — the eleven items of the emailed list [S2], which carries no photographs [S2] and no date. The file the City produced under Request 26-1965 [R.26-1965.1] holds no copy of the email, lists no such document, and records no service of it.
FULL CIRCLE
The cited code requires the Notice and Order to describe the conditions, state the required action [SCC.8.100.720(A)(2)], and carry the appeal path [SCC.8.100.760(D)], and it requires service of any amended or supplemental notice (SCC.8.100.720, SCC.8.96.130, SCC.8.100.730, SCC.8.100.760). The City did re-issue an appealable order on 09/02/2025 [M543] that itemized most conditions [M544]. But the fence-height, fascia, and workshop-120-Sq-Ft items moved through the separate emailed list [S2], reproduced word for word on the inspector's 12/02/2025 case note [M037], and through the October email chain [E4], without appearing on any served order carrying the appeal advisory.
The file the City produced under Request 26-1965 [R.26-1965.1] contains no City-produced Notice and Order formally incorporating those three off-order items into the noticed scope of the case. Any contrary showing would have to come from records outside the CPRA productions the City already closed as complete — R.25-3549, R.26-1549, and R.26-1965 (how to obtain the records) — against the completeness baseline in Card 4 and the email-specific completeness exemplar in Card 46.
The expected response is that officials commonly discover new items as an inspection or project progresses and must inform the owner of everything necessary to achieve compliance; that email and a correction list are ordinary channels for that communication; that the order's existing "all required permits" [M543] language already covered these items; and that the served Correction List had already reached the workshop at B45 [M544] — "Added square footage at detached garage to be permitted" [M544] — and that the 120-square-foot, no-utilities figure is the City's own permit-exemption threshold from the Guide to Permits in the same file, "provided the floor area does not exceed 120 sq. ft. (and has no electrical) [M119]," offered as the no-permit alternative to B45.
Informing the owner of newly identified items and adding those items to a noticed enforcement obligation are two different acts. The cited provisions require the order itself to describe the conditions and state the required action [SCC.8.100.720(A)(2)]; an order that does not state a condition gives the owner no served, appealable statement of it. B45 [M544] ordered the added square footage "to be permitted" [M544]; the emailed list ordered the workshop "reduced down to 120 Sq Ft and detached from the garage or removed [S2]," with "All utilities removed from the workshop area." [S2] Permitting a structure and shrinking it, detaching it, or removing it are not the same requirement. B23 [M544] named "siding and trim" [M544] on the "East side of property" [M544], not the fascia board at the back of the dwelling, and the seven-foot fence-height limit has no counterpart anywhere on the served Correction List, from B31 [M544] through P09 [M545]. The City's re-issued 09/02/2025 order [M543] itemized conditions with the appeal advisory attached [M543] and did not include the fence-height, fascia, or workshop-120-Sq-Ft/detach items on page 544 [M544] or page 545 [M545]. The permit guide does not close the gap either: an exemption threshold printed in a guide is not a served condition, the served B45 line says only "to be permitted [M544]," the guide's own fence line is "Fences not over six feet high" [M119] where the emailed list ordered the fence "cut down to 7' [S2]," and the fascia item has no exemption reading at all. On the reviewed record, those three conditions became part of the compliance path without appearing in a served appealable order.
What would defeat this card is a served Notice and Order, amended notice, or supplemental notice carrying the appeal advisory and stating the fence-height, fascia, and workshop-120-Sq-Ft/detach conditions; the file the City produced under Request 26-1965 [R.26-1965.1] holds none. Card 4 is the completeness baseline (what the file the City produced means, and does not mean).
APPLICABLE LAW
- SCC.8.100.720: Housing Code Notice and Order issuance and content requirement.
- SCC.8.96.130: Dangerous-building order procedure and parallel description-of-conditions requirement.
- SCC.8.100.730: Service of a Notice and Order, amended notice, or supplemental notice.
- SCC.8.100.760: Appeal of a Notice and Order; appeal must be filed within thirty days from the date of service.
SOURCE CITATIONS USED BY THIS CARD
- E4: Owner-side Gmail print, "Corrections for City Code compliance" - 10/16/2025 and 10/20/2025 attorney email thread relaying the "minimal permit," "DOES contain requirements to obtain a permit," and "not the actual new Notice and Order" statements; local file:
SOURCES/E/E.4/E.4.pdf. - M123: M page 123 - 04/12/2023 Notice and Order cover letter; 30-day appeal advisory
- M124: M page 124 - Notice and Order to Repair or Demolish face; Bo Cosley, Principal Building Inspector; Paul Lovato, Building Inspector III; para 7 - appeal runs from this served Notice and Order
- M125: M page 125 - served Correction List; B31 "Other" and B59 "Permits Required" (SCC.8.100.190) generic entries; "Neither interior nor exterior has been completely inspected"
- M022: M page 22 - Documents index showing
Correction Notice.docadded 09/17/2025 as "Correction notice."; 08/25/2025 case-photo captions including "Dry rot at fascia board" and "Exterior trim shows dry-rot" - M036: M page 36 - Paul Lovato 09/16/2025 case note stating he provided the contractor a correction notice, that included pictures, during the 09/16 visit, uploaded a copy to documents, and gave the owner's representative 30 days to obtain the building permit; 10/20/2025 phone-call note; 10/23/2025 siding email.
- M037: M page 37 - case-note continuation carrying Paul Lovato's 12/02/2025 note, which sets out the emailed violation list word for word - "I have sent out the violation list a cpl times" through "These items are from my last inspection." - including the fascia board, seven-foot fence-height, and workshop-120-Sq-Ft/detach/utility-removal language.
- M543: M page 543 - 09/02/2025 re-issued Notice and Order; Willie Harris, Principal Building Inspector; Paul Lovato, Building Inspector 4; para 4 "all required permits"; para 7 appeal right
- M544: M page 544 - 09/02/2025 re-issued Notice and Order continuation; itemized Correction List (continues at M545: P09 comment) enumerating B23, B45, E02, E03, E06, E08, E11, P05, P08, and P09 (plus B31/B59 generic placeholders reproduced word for word from the 2023 list)
- M545: M page 545 - 09/02/2025 re-issued Notice and Order, last page of the Correction List; P09 "Dryer at backyard not approved for use" - the served list ends here with no fence-height, fascia, or workshop-120-Sq-Ft/detach entry
- M119: M page 119 - City "Guide to Permits for Residential Projects and Additions" in the produced file; "A building permit is not required for" accessory buildings "provided the floor area does not exceed 120 sq. ft. (and has no electrical)" and "Fences not over six feet high"
- R.25-3549: NextRequest CPRA production 25-3549
- R.26-1549: NextRequest CPRA production 26-1549
- 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 - provenance for master production
M; closed by the City with a written determination that all responsive records had been provided - S2: Owner-side screenshot of the inspector's list email, headed "Sac City Inspection 4..." - eleven garage, main-house, and backyard items including the fascia board, the seven-foot fence-height, and the workshop-120-Sq-Ft/detach/utility-removal language; no photographs. Its text is reproduced word for word in Paul Lovato's 12/02/2025 case note at M037.
CARD REFERENCES
- Card 1 - the B59 "Permits Required" placeholder gap the new list never cured
- Card 26 - the 09/02/2025 re-issued Notice and Order M543-M545, which itemized most conditions (B23/B45/E02/E03/E06/E08/E11/P05/P08/P09) with an appeal right; it did not carry the fence-height, fascia, or workshop-120-Sq-Ft items that remain only on the emailed list and its 12/02/2025 case-note reproduction
- Card 31 - the on-tape permit contradiction (spine)
- Card 34 - the destructive siding-removal instruction through the same channel
- Card 35 - the dictated permit scope / spine resolution (the more severe permit-record variant)
- Card 36 - the contractor walk-off (the practical consequence)
- Card 4 - record-production-complete baseline
- Card 46 - email-bearing completeness exemplar