The Missing Signature-Authority Bridge

Case 23-009185 | Card 5 | 4880 T Street, Sacramento CA 95819

The order that put 4880 T Street under repair-or-demolish carries one signature, and it belongs to a title the code does not list. The April 12, 2023 Notice and Order [M124] recites that the Chief Building Official had caused the building to be inspected, had determined it substandard and/or dangerous, and had determined that the building(s) must be repaired or demolished [M124]. Its date line prints "Dated: 04/12/2023 Bo Cosley, Principal Building Inspector" [M124], and nothing is signed there. The one signature on the page sits over the typed name and title Paul Lovato, Building Inspector III [M124]. The section that governs the order says "the building official shall issue a notice and order directed to the record owner of the building" [SCC.8.100.720(A)(2)]; for the Chapter 8.96 authority the order names, that official is the chief building official and "his or her assistants as described in Section 15.04.100" — Deputy Chief Building Official, Principal Building Inspector, Supervising Engineer, and Code and Housing Enforcement Chief. Principal Building Inspector is on that list. Building Inspector III is not.

What the owner was served was the order and its packet — a letter, the order, its attachments, an appeal form, and a correction list [M131] — and nothing in it delegates, designates, or approves. The City's own file says who issued the order: the inspector's note of the day before its face date reads "I issued the Notice and Order" [M024] (Card 6: the two reasons that note gives for issuing it, measured against the file). The log's one entry for the order's date is a clerical activity, "HSG - NOTICE ORD S/DB" [M001], assigned to Monica Atkins. Twenty-eight months later the City issued a second order in the same case [M543] with a different Principal Building Inspector's name printed on the date line and the same inspector's signature, now as Building Inspector 4. The file the City produced in May 2026 under Request 26-1965 [R.26-1965.1] holds no delegation, designation, approval, or review by any official on the code's list for the April 12, 2023 order. For the second order that same file shows a listed official on the ground — "I arrived onsite on 8/21/25 with PBI Cosley at 11:30am" [M035], the inspector wrote of the visit twelve days before it — and the name printed on that order is not his [M543].

Who issued the April 12, 2023 order [M124] at 4880 T Street — when its only signature is a Building Inspector III's [M124], a title the code's list of building officials does not carry, the Principal Building Inspector whose name is printed on its date line [M124] signed nothing, the inspector's own note says "I issued the Notice and Order" [M024], and the City has produced no delegation or approval [R.26-1965.1] by any listed official?

IN PLAIN TERMS

City code says who may issue a Notice and Order: the chief building official and four assistants it names. Principal Building Inspector is one of them. Building Inspector III is not. The April 12, 2023 order [M124] has a Principal Building Inspector's name typed on the date line with no signature, and one signature — a Building Inspector III's. The inspector's own note says "I issued the Notice and Order" [M024]. Nothing mailed with the order delegated or approved anything, and the file the City produced in May 2026 [R.26-1965.1] holds no such page for that order either. The question for the City: who issued the order, and where is the page that shows it?

RECORD CHAIN

  1. April 11, 2023 — the inspector's own account of issuing the order.

    The case file NOTES page carries this entry in Paul Lovato's name, dated the day before the order's face date: "7:00 am. I arrived to SFR to take photos and update case files. Due to lack of contact from the Owner and failure to obtain an HDB permit I issued the Notice and Order, I also ordered a Cloud be placed on the title and a Title report be done." [M024]

    The reasons in that sentence are Card 6 (neither is a condition of the building, and the City's own records carry no permit class of that name); the day it carries against the order's face date is Card 7 (the same verification narrative under two dates). This card takes one thing from it: the verb, and who wrote it.

  2. April 12, 2023 — the order, and the two names on it.

    The Notice and Order [M124] recites that "the Chief Building Official, has caused to be inspected and has determined" [M124] the building substandard and/or dangerous, and that "The Chief Building Official has determined that the building(s) must be repaired or demolished, the option being yours" [M124]. Its date line reads "Dated: 04/12/2023 Bo Cosley, Principal Building Inspector" [M124]; the signature line below it reads "By" [M124] over "Paul Lovato" [M124] / "Building Inspector III, (916) 808-5703" [M124]. The only handwriting on the page is on that line.

    The activities log for that date holds one row for the order, "HSG - NOTICE ORD S/DB" [M001], with Monica Atkins [M001] in the column headed ASSIGNED TO and nothing in the comment column. The proof of service lists what was mailed with it — Letter, Notice and Order to Repair or Demolish Sub-Standard Building, Attachment A (legal property description), Warning Statement, Notice of Change of Owner(s) Address or Sale of Property, Three Day Notice of Cal. Health and Safety Code 17980.7 Receivership, Appeal Request Form, Correction List and Proof of Service by Certified Mail [M131] — and no delegation or approval is among them.

  3. September 2, 2025 — a second order, a different printed name, the same signature.

    Twenty-eight months later the City issued a second Notice and Order in Case 23-009185, in two addressee copies. Each is dated "Dated: 09/02/2025 Willie Harris, Principal Building Inspector" [M543] and each carries one signature, over "Paul Lovato" [M554] / "Building Inspector 4, (916) 808-5703" [M554]. The name printed on the date line had changed; the name under the signature had not. Building Inspector 4 is not on the list either.

  4. May 22, 2026 — the file the City produced under Request 26-1965.

    The City released the 631-page case file [R.26-1965.2] under Request 26-1965 and closed the request the same day: "All responsive records have been provided." [R.26-1965.1] It contains no standing delegation, written designation, case-specific authorization, review note, approval email, or task entry showing that an official on the SCC.15.04.100 list issued or approved the April 12, 2023 order, and none connecting the signature it carries to the name printed on its date line.

    For the September 2, 2025 order the same file shows more, not less. The NOTES entry dated 08/21/2025 in the inspector's name opens "I arrived onsite on 8/21/25 with PBI Cosley at 11:30am" [M035] and records that "PBI Cosley let the owner know that the conditions at the property would normally cause power to be removed from the property" [M035]. Twelve days later the order went out over a different Principal Building Inspector's [M543] name. A listed official acted in the case that month; the order does not carry his name, and no page ties either name to the other.

FULL CIRCLE

The City's first available answer is that the date line is the issuance: the order is dated over a Principal Building Inspector, an official the code lists, and the "By" signature is execution on his behalf.

On the page the date line carries no signature, and the one signature is a Building Inspector III's [M124]. The City's own inspector wrote, in the City's own file, that he issued it [M024]. Twenty-eight months later the same case produced a second order with another Principal Building Inspector's name printed over the same inspector's signature [M543]. Execution on someone's behalf is an act of that someone, and for the April 12, 2023 order the file records none: no direction, no approval, no review. For the second order the file does record a listed official's act — "PBI Cosley let the owner know that the conditions at the property would normally cause power to be removed from the property" [M035] on 08/21/2025 [M035] — and the name printed on the order that followed is a different Principal Building Inspector's [M543].

The City's second available answer is that a listed official did sign in this case — the Code and Housing Enforcement Chief, on the instrument recorded against the title.

That is a different document (Card 12: the recorded notice, of which the produced file holds only an unsigned, un-notarized copy). The order the owner was served, the one that set the thirty days and the demolition option, carries no listed official's signature.

What would defeat this card is one page: a delegation, designation, or written approval for the April 12, 2023 Notice and Order [M124] carrying the name and title of an official on the SCC.15.04.100 list, or a written rule that a Building Inspector III may issue one. The May 2026 case file [R.26-1965.2], closed with "All responsive records have been provided." [R.26-1965.1], contains neither. Card 4 is the completeness baseline (what the file the City produced means, and does not mean).

APPLICABLE LAW

SOURCE CITATIONS USED BY THIS CARD

CARD REFERENCES