The Missing Signature-Authority Bridge

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

The April 12, 2023 Notice and Order prints a listed official's title on its date line but bears only a "By" signature from an inspector whose title is outside the code's authority chain. The face page M124 recites that the Chief Building Official "has caused to be inspected and has determined" that the building is "in sub-standard and/or dangerous condition," and orders repair or demolition under the City's Notice and Order procedure SCC.8.100.720. The order also invokes Chapter 8.96. For that dangerous-building authority, SCC.8.96.105 defines the building official to include the Chief Building Official and the assistants described in SCC.15.04.100: Deputy Chief Building Official, Principal Building Inspector, Supervising Engineer, and Code and Housing Enforcement Chief. The order's date line names Bo Cosley as Principal Building Inspector M124, a listed title. The only signature, after "By," is Paul's, as Building Inspector III — not a listed title.

The produced record contains no delegation, designation, case-specific approval, or routing record authorizing Paul to sign "By" for the listed official. The City closed multiple productions covering this case as complete. The finding is not that every "By" signature is invalid; it is that the order names a listed official on the date line, carries only an unlisted inspector's signature, and the produced file contains no record connecting the two.

IN PLAIN TERMS

The city code lists the officials who may act as the building official. The order names one of them, Bo Cosley, on its date line. But a different inspector, Paul, signed it, and Paul's title is not on the code's list. The produced file contains no record showing Paul was authorized to sign for Cosley — no delegation, no review, no approval. The same pattern appears on the reissued 2025 order, again with no authorizing record.

RECORD CHAIN

  1. The code names the authority chain. SCC.8.96.105 defines the "building official" for Chapter 8.96 to include the Chief Building Official and "his or her assistants as described in Section 15.04.100." SCC.15.04.100 lists the assistant titles in full: Deputy Chief Building Official, Principal Building Inspector, Supervising Engineer, and Code and Housing Enforcement Chief. The Chief Building Official class specification JOB.CBO.SacCity.33229 further defines the role. Building Inspector III and Building Inspector 4 are not on the listed-authority chain.
  2. The April 2023 order uses a listed name but an unlisted signer. The April 12, 2023 Notice and Order face page M124 is dated under "Bo Cosley, Principal Building Inspector," a title on the SCC.15.04.100 list. The signature line below it, after "By," is Paul, Building Inspector III, a title that does not appear in that list.
  3. The City used a listed title elsewhere in the same matter. The recorded companion notice was signed by Peter Lemos, Code and Housing Enforcement Chief, another SCC.15.04.100 listed title (see Card 12).
  4. The same structure repeated in 2025. The September 2, 2025 reissued Notice and Order repeats the pattern: the document is dated under Willie Harris, Principal Building Inspector, but signed "By" Paul, Building Inspector 4 M543 M554. Building Inspector 4 is not a listed title.
  5. The full-file search found only those exact "By" signatures. A control search of the 631-page May 2026 Case File for "By" signature lines near Paul found three exact matches: the April 2023 Notice and Order M124, and two September 2025 reissued Notice and Order addressee copies M543 M554. Administrative-penalty pages were not counted because visual review shows Cosley signed those pages; Paul appears only in the case/staff field on that form.
  6. The produced file contains no record of signature authority. The closed-as-complete productions R.25-3549 R.26-1549 R.26-1965 contain no standing delegation, written designation, case-specific authorization, review note, approval email, task entry, or other record placing Paul within the SCC.15.04.100 authority chain or authorizing him to sign "By" for Cosley Card 4. A full-text search of the May 2026 Case File returns zero instances of "delegat," "designee," or "authorized representative."

FULL CIRCLE

This finding does not rest on treating every "By" signature as invalid. The April 12, 2023 order invokes both Chapter 8.100 and Chapter 8.96; for the Chapter 8.96 dangerous-building authority, the City's code defines the building official as the Chief Building Official and the listed assistants SCC.8.96.105 SCC.15.04.100. The April 2023 order's only signature line carries a title outside that chain M124. The same structure appears again in 2025 M543 M554, and the produced Case File contains no record giving Paul authority to sign under either listed official's name.

The expected response is that the order was Cosley's and that Paul signed it at Cosley's direction as a matter of routine practice. The produced record does not document any such practice or direction. It contains no standing delegation and no case-specific approval, review, or routing entry showing that Cosley, or any listed official, authorized Paul to sign under the printed title.

As produced, the Case File shows a listed official printed on the date line, a different inspector's signature on the only signature line, and no record of authority connecting the two M124.

APPLICABLE LAW

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