Fourteen Written CPRA Completeness Determinations

Case 23-009185 | Card 4 | 4880 T Street, Sacramento CA 95819

The City of Sacramento opens every public-records request with the same sentence: "Within 10 days of processing, we will determine whether your request seeks disclosable records and release those records or if we require additional time to gather information and review records." [R.26-39.1] Between October 2025 and June 2026 it made that determination on fourteen requests in the audit of Case 23-009185 (three times on the first of them), in three formulations: "All responsive records have been provided." [R.26-1965.1], "The City has collected all documents that appear to be responsive to your request." [R.26-1549.1], and "The City does not have any records responsive to this request." [R.26-2206.2] Four of the fourteen requests had asked the City, for anything it could not find, to say so and name what was searched, two of them in these words: "Searched for and not found, with what systems were searched and what terms were used." [R.26-1963.1] None of the fourteen closures says what was searched, or by whom. For one of them, Request 26-71, the City later released its internal IT emails [R.26-1987.2], which name the two systems ("We already have the CitizenServe portion of the request covered" [R.26-1987.2]; the Accela export went to a ServiceNow ticket), the IT staff who built the export, and the parameters it was built to.

Those fourteen statements are the measure for every absence in this case. A record that existed, was responsive to a covered scope, and was not produced when the statement was made is a record the City had already stated in writing was provided, or was not there. Four of the fourteen are this case file: the April 2026 re-export [R.26-1549], the request for its system fields [R.26-1963] and the request for its audit trail [R.26-1964], each closed by pointing back to that April production, and the request for a searchable electronic export [R.26-1965], closed with a 631-page print report [R.26-1965.2].

For any of the thirteen closures other than Request 26-71, and above all the four that said no records exist, where is the City record that names the system searched, the person who searched it, and the person who determined that nothing further exists?

IN PLAIN TERMS

On fourteen requests the City wrote to this requester that a request was complete, that all apparently responsive documents had been collected, or that no responsive record exists. Those are the City's formal answers after a search. If a record later turns up that existed and fit one of those requests, the City had already stated in writing that it was not there, or had been provided. This card collects the fourteen, each with the scope it covered. Card 32 (the missing September 16 photographs), Card 45 (the twenty-two-minute closure), and Card 46 (the inconsistent closures on one case email) test particular records against them. For one request, 26-71, the City later released the IT emails behind its export. The question for the City: for the other thirteen, who searched, where did they look, and who decided that nothing more exists?

RECORD CHAIN

  1. October 2 – November 7, 2025 — the first request, narrowed, and closed three times.

    Request 25-3549 was filed for "all Code Enforcement records involving Inspector Paul Lavato from January 1, 2020 through September 19, 2025" [R.25-3549.1]. On October 2, 2025 the City answered that "As currently written, this request is so broad it would result in thousands of pages of code cases to redact and provide" [R.25-3549.1], sent a list of over 1,600 cases Lovato had been involved in [R.25-3549.1], and asked which of them the requester wanted.

    On October 2 the requester narrowed it to August 1 through September 19, 2025 and to "All cases where Inspector Paul Lovato is listed as inspector" [R.25-3549.1]. The City closed that scope on October 7 with "All responsive records have been provided." [R.25-3549.1]

    On October 14 the requester re-scoped the request: "I am now requesting the complete underlying file for Case #23-009185" [R.25-3549.1]. The City reopened it and closed it with the same sentence on October 23 and, after a second reopening, on November 7, 2025. On October 27 the requester had asked the City, for anything not found, to "identify who conducted the search, which systems were searched, and the exact search terms and date range" [R.25-3549.1], and on October 31 to "indicate which systems and custodians are being searched (Sac311, inspector call sheets, code-enforcement queue, archives, etc.)" [R.25-3549.1]. The November 7 closure names none.

  2. December 29, 2025 — received, released and closed the same day.

    Request 25-4711 asked the City to verify the email exchange recited in the 09/11/2025 case note [R.25-4711.3]. It was received on December 29, 2025 and closed that day: "All responsive records associated with this public records request have been released and this public records request is now closed." [R.25-4711.3]

    The release notice sent at 4:22 p.m. states, "The City has collected all documents that appear to be responsive to your request." [R.25-4711.2] One document was released. The City titled it "Re_ 4880 T Street Jackie's House - 25-3549.pdf" [R.25-4711.2] (Card 46: the inconsistent closures on that one case email).

  3. January 6, 2026 — a no-records closure on the delivery question.

    Request 26-39 asked for proof that the email described in the 09/11/2025 case log had been sent to the requester, or for written confirmation that no City record shows it was sent [R.26-39.1]. The portal records it opened at 12:08 p.m. and closed at 12:30 p.m. [R.26-39.1] on January 6, 2026, with "The City does not have any records that are responsive to your request. Any additional questions or concerns regarding code enforcement records will need to be directed to the Code Enforcement Department." [R.26-39.1] (Card 45: the twenty-two-minute closure).

  4. March 25 – April 20, 2026 — five closures, one exemption paragraph.

    Request 26-1061, for the raw note exports of five other named officers for November and December 2025, closed on March 25, 2026: "The City has collected all documents that appear to be responsive to your request." [R.26-1061.1] Request 26-71, for the inspector's 2025 notes and log export across all cases, closed on March 26, 2026 with "All responsive records have been provided." [R.26-71] after five extension notices (Card 40: five rolling notices and no determination date; Card 42: the index pointer and the unanswered custodian question).

    Request 26-1265, for a citywide search of Notices and Orders listing only violation codes B31 and B59 over the past five years, closed on April 2, 2026 with "All responsive records have been provided." [R.26-1265.1], a referral to the City's Code Violation Webpage [R.26-1265.1] and Helpful Search Tips [R.26-1265.1] for running the search there. Request 26-1060, for the 2025 Code Enforcement officer roster, closed on April 8, 2026: "All responsive records associated with this public records request have been released and this public records request is now closed." [R.26-1060.1] Request 26-1549, for a current export of the case file for Case 23-009185 with its activity log, notes and attachments, was received and closed on April 20, 2026 [R.26-1549.1].

    The Request 26-1061 and Request 26-1549 closures carry the same exemption paragraph, naming Government Code 7927.705 [GC.7927.705] and Government Code 7930.100 [GC.7930.100] and the categories complainants, victims and personal information, and identifying no record [R.26-1549.1].

  5. May 12 – May 22, 2026 — four closures; three of the requests had asked what was searched.

    Request 26-1863, for the case-file exports of three other code-enforcement cases, closed on May 12, 2026: "The City has collected all documents that appear to be responsive to your request." [R.26-1863.4] — the same sentence, and the same exemption paragraph, as the April 20 closure of this case file.

    Request 26-1963 asked for the CitizenServe system fields behind every entry in this case — Date Created, Date Modified, Created By, Modified By [R.26-1963.1] — and the items attached to those entries. Request 26-1964 asked for the case-level history: any audit trail, event log, change history, version history, workflow history, or similar record [R.26-1964.1]. Each asked the City to answer item by item, and for anything it could not find, to state "Searched for and not found, with what systems were searched and what terms were used." [R.26-1964.1]

    Request 26-1963 closed on May 18, 2026 at 9:53 a.m. with "The City does not have any records responsive to this request. All records were provided under 26-1549." [R.26-1963.1] Request 26-1964 closed two minutes later, in the same words [R.26-1964.1].

    Request 26-1965 asked for the case file in whatever native electronic format the City can export from the system [R.26-1965.1] — Excel, CSV, JSON, XML or another searchable structured format — and, if none was found, for a statement "including what export option, utility, system, or process was checked and why the City says no searchable export exists" [R.26-1965.1]. It closed on May 22, 2026 with "All responsive records have been provided." [R.26-1965.1] and a 631-page CitizenServe print report [R.26-1965.2].

  6. June 2 – June 4, 2026 — the call records and the photographs.

    Request 26-2110, for the Lovato and Cosley call-detail records covering the August 21, 2025 access window, closed on June 2, 2026: "The City of Sacramento has determined all responsive records are exempt from disclosure." [R.26-2110.1] Request 26-2204, narrowed to segregable call-detail metadata, closed on June 4, 2026 on the same exemption paragraph [R.26-2204.1]. Both were closed as exempt, not as complete or no-records; they are not among the fourteen.

    Request 26-2206, for the photographs Bo Cosley took at 4880 T Street on September 16, 2025, closed that same morning: "The City does not have any records responsive to this request." [R.26-2206.2] (Card 32: the missing September 16 photographs and what the property's own cameras recorded during that walkthrough).

  7. June 11, 2026 — the fourteenth closure, and the one search the City described in writing.

    Request 26-1987, for the City's internal communications about how the earlier requests were handled, closed on June 11, 2026: "All responsive records associated with this public records request have been released and this public records request is now closed." [R.26-1987.1]

    Among the records it released is the City's internal IT email for Request 26-71 [R.26-1987.2], which states the parameters the Accela export was built to: "the record number and any correlated notes associated with that record number which were entered by Paul Lavoto between 1/1/2025 and 12/31/2025 [R.26-1987.2]."

  8. June 23, 2026 — closed as duplicates.

    Request 26-2488 [R.26-2488.1] asked for the current, complete case file as held in both CitizenServe and Accela, with the system fields, in native format. It opened at 6:04 a.m. and closed at 9:30 a.m. [R.26-2488.2] — three hours and twenty-six minutes — with "This is a duplicate request of your previous request, 26-2487." [R.26-2488.2]

    The three documents released on Request 26-2487 [R.26-2487.5] carry the portal's stored upload timestamp of 11:13:45.964 [R.26-2487.5] a.m. and were released at 11:18 [R.26-2487.5] a.m. At 9:30 a.m. the request it had been pointed to had released nothing. One of the three is the File Summary Report dated 06/23/2026 [R.26-2487.2], which records the file as Status Closed, Close Date 06/18/2026, Disposition Work Completed (Card 39: the day-old permit that closed the case).

    The request for the case-specific Accela inspection and parcel-condition records [R.26-2489.1], and for the query parameters and report definition behind the export named in that email, closed the same morning as a duplicate of Request 26-1987 and Request 26-2487. The re-request for the September 16, 2025 photographs [R.26-2492.1], which added the property's own CCTV stills (P2, P3, P4, P5, P6, P7), closed the same day as a duplicate of the Request 26-2206 no-records closure.

  9. July 2 – August 27, 2026 — five notices, no determination.

    Request 26-2490 [R.26-2490.1], for the inspector's emails on this case, received five written extension notices — July 2 [R.26-2490.1], July 16 [R.26-2490.1], July 30 [R.26-2490.1], August 13 [R.26-2490.1] and August 27, 2026 [R.26-2490.2] — each of exactly fourteen days, each in the same words, each citing "Government Code 7922.535 (c)(2)" [R.26-2490.1], on a statute whose subdivision (b) provides that a notice "shall not specify a date that would result in an extension for more than 14 days" [GC.7922.535]. At the August 27, 2026 capture the request was open with no record released [R.26-2490.2], 65 days after receipt, with no determination made; the fifth notice promises one "on or before Thursday, September 10th 2026" [R.26-2490.2]. The day before that notice the City had closed Request 26-3401 [R.26-3401.1], for the written designation that lets the City Clerk extend a deadline, with "The City does not have any records responsive to this request." [R.26-3401.1] (Card 40).

  10. August 26 – 28, 2026 — twelve determinations, none naming a search.

    The twelve single-subject requests received August 18, 2026 (below) were all answered by August 28, eleven of them on August 28 between 11:36am and 12:03pm. Three closed "All responsive records have been provided." [R.26-3395.2] with documents — Request 26-3395 [R.26-3395.2], Request 26-3397 [R.26-3397.1] and Request 26-3404 [R.26-3404.1] — and one, Request 26-3405 [R.26-3405.1], with documents and instructions for the City's online permit system. Five closed with one sentence — "The record(s) you are seeking have already been released to the public as part of a prior City of Sacramento public records request" [R.26-3396.1] — Request 26-3396 [R.26-3396.1], Request 26-3398 [R.26-3398.1], Request 26-3399 [R.26-3399.1] and Request 26-3400 [R.26-3400.1] to 26-3395, and Request 26-3406 [R.26-3406.1] to 26-3397. Request 26-3403 [R.26-3403.2] closed "Referred to city website or portal; referred to outside agency/jurisdiction." [R.26-3403.2] And Request 26-3402 [R.26-3402.1], for the search records behind 26-2490 and the City's own record of the extension notices it issued in 2026, drew the extension paragraph: "We will notify you on or before Friday, September 11th 2026 as to whether the City is in possession of non-exempt records responsive to your request" [R.26-3402.1]. Each of the twelve had asked the City, for anything it could not find, to name the system searched, the person who searched it and the person who made the no-records determination (Request 26-3395's words are below); none of the twelve answers does.

FULL CIRCLE

The City's first available answer is that the Public Records Act calls for a written determination, not an account of the search behind it, and that it does not make records to answer requests. It has said the second half in writing: "It is important to note that our response adheres to our policy; we do not create records solely for the purpose of fulfilling Public Records Requests." [R.26-2493.1]

The records asked for were not records to be made. Request 26-1986 asked, for the requests it names, for the list of City systems and databases searched, the search terms and custodian scopes applied, and the name and job title of every employee who took part in the search [R.26-1986.1]; it closed on June 11, 2026 with "Referred to city website or portal." [R.26-1986.1] The same records were sought for three later closures on Request 26-2494, which opened at 6:13 a.m. on June 23, 2026 and closed at 9:54 a.m. with "This is a duplicate request of your previous request, 26-1986." [R.26-2494.1] And the identification the statute calls for is not a record at all: Government Code 7922.540 [GC.7922.540] places the names, titles and positions of the persons responsible in the response itself.

The City's second available answer is that completeness is per request, that several of these scopes are not limited to this case, and that a search was run. It has described a search twice, in one sentence: "After an exhaustive search where your request was diligently routed to the relevant departments within the City that might have possessed pertinent records, we have determined that there are no responsive records to this request." [R.26-2491.3] — Request 26-2491 [R.26-2491.3], July 28, 2026, and the owner-authority and consent-to-enter request [R.26-2493.1], July 29, 2026.

That sentence names no system, no custodian, no search term and no date, and it reads the same whatever the scope was. It appears on none of the fourteen closures, and the fourteen say less than it does.

For one of the fourteen the City has produced the search record. The internal IT emails released under Request 26-1987 [R.26-1987.2] name the two systems, the IT staff who built the export for Request 26-71, and the parameters it was built to; the March 26, 2026 closure of that request is its determination. What would defeat this card is the same kind of page for any of the other thirteen, above all for the four no-records closures, Request 26-39 [R.26-39.1], Request 26-1963 [R.26-1963.1], Request 26-1964 [R.26-1964.1] and Request 26-2206 [R.26-2206.2]: a record naming the system that was searched, the person who searched it, and the person who determined that nothing further exists. The file the City produced in May 2026 under Request 26-1965 [R.26-1965.1] is a 631-page CitizenServe report of the case activity file [R.26-1965.2], and no such record for any of the thirteen appears in it. This card is the completeness baseline (what the file the City produced means, and does not mean).

On August 18, 2026 twelve single-subject requests were filed, numbered 26-3395 through 26-3406. Request 26-3395 [R.26-3395.1], for the completed inspection report behind the June 18, 2026 closure, asks the City, if it finds no record, to "state that expressly and produce the records of the search: which systems (including CitizenServe and Accela) and which custodians were searched, the search terms and parameters used, the date of the search, the identity of the person who performed it, and the identity of the person who made the no-records determination under Gov. Code section 7922.540(b)" [R.26-3395.1]. Request 26-3403 [R.26-3403.1], for the notice of final disposition recorded after that closure or the records showing why none was, carries the same requirement in its own terms. On August 28, 2026 the City closed the first with three documents and "All responsive records have been provided." [R.26-3395.2], and the second with "Referred to city website or portal; referred to outside agency/jurisdiction." [R.26-3403.2] and "contact Sacramento County for lien records" [R.26-3403.2]; neither names a system searched, a person who searched, or a person who determined. The twelve answers are in the RECORD CHAIN above; the search record this card names is in none of them.

On August 29, 2026 Request 26-3620 [R.26-3620.1] asked, for each of the five requests closed as "already been released", for the identification — by request number, document title, and page — of the released record the City determined to be responsive to that item [R.26-3620.1], and for the name and title of the person who made each determination.

APPLICABLE LAW

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