Loading...
HomeMy WebLinkAbout31-Planning and Building CITY OF SAN BE()IARDINO - REQUESQFOR COUNCIL ACTION From: Larry E. Reed, Assistant Director Dept: Planning and Building Services Dau: December 2, 1991 . Appeal of Board of Building SU~~:Commissioners Findings and Action of September 6, 1991 for property located at 1098 w. 5th St. Mayor and Common Council Meeting eof n~v~...~'-Y -4, 1331 Synopsis of Previous Council action: The Mayor and Common Council directed the Planning and Building Services Department to reinspect the premises located at 1098 W. 5th Street, and provide the owner Mr. Peters with a list of all violations with the time specified to correct these violations. Recommended motion: That the Mayor and Common Council uphold the findings of the Planning and Building Services Department and require Mr. Peters to obtain all proper permits within 10 days and to correct listed violations within thirty (30) days. (See attached) In the event the violations are not corrected within the presribed'period of time, then the City or person(s) authorized by the-Building Official, will initiate action to abate the nuisance. OWner to pay all current and futrure costs incurred by the City in the abatement of City Code violations and/or nuisance. S ignatu re Larry E. Reed Contactparson:Larrv E. Reed. Assistant Director Phone: (714) 384-5357 Supporting daU attached: Correction List for 1098 W. Ward: 1 5th St. FUNDING REQUIREMENTS: Amount$"l?n fin Source: (Acct. No,) 001-000-41733 (Acct. DescriPtion) Finance: Council Notes: 75.0262 Agenda I tem No 31 revised CIT" OF SAN BERORDINO - REQUEST ()OR COUNCIL ACTION From: Larry E. Reed, Assistant Director Subject: Appeal of Board of Building COImnissioners Findings and Action of September 6, 1991, for property located at 1098 W. 5th Street. Oept: Planning and Building Services Date: November 26, 1991 Mayor & Common Council meeting of 11-04-91 Synopsis of Previous Council action: The Mayor and Common Council directed the Planning and Building Services Department to reinspect the premises located at 1098 W. 5th Street, and provide the owner Mr. Peters with a list of all violations with the time specified to correct these violations. Recommended motion: ~)r'J That the Mayor and Common Council uphold the findings of the Planning ~d BUilding~~ Services Department and require Mr. Peters to obtain all proper permit to correct listed violations within thirty (30) days. (See attached) In the even the vio- lations are not corrected within the prescribed period of time, then the City or person(s) authorized~~~pe Building Official, will initiate action to abate the nuisance. Owner ~ ~ all current and future costs in the form of a lien or a personal obligation of the owner. rb-/ Signature Contact person: Larry E. Reed. Assistant Dire"tor Phone: (71 L.) 1S!L.-~1~7 Supporting data attached: Correction List for 1098 W. 5th St. Ward: 1 FUNDING REQUIREMENTS: Amount: $320.60 Source: (Acct. No.) 001-000-41733 Finance: J 1l!Zf4 (Acct. Descriotion) Council Notes: 75-0262 Agenda Item No. 31 o 0 CITY OF San Bernardino DE'ARTMENT 0' 'LAMNING AND IUILDINQ .IRvIC.S AL aOUGHEY,AICP DIRECTOR Maurice Peters 1098 If. 5th St. San Bernardino, Ca. Nov. 25, 1991 Re: Code Violations at 1098 W. 5th Street Dear Mr. Peters, During the council meetinc of November 4, 1991, the CitJ Council directed this Depart_nt to inspect Jour propertJ at the above referenced address and to provide JOu with a comprehensive list of violations. On Novelaber 25, 1991, this inspection was conducted bJ Code Enforce_nt Officer DannJ NoUo, and IDJseU, Senior Buildinc Inspector Joseph Lease. The violations observed at this time are as follows: Electrical Violations 1) Electrical connections made to the hJdraulic lift on the north side of the building without required permits.(SBMC 15.04.020, UAC301 (a)) Also, the electrical installation is substandard; flexible cord maJ not be used in lieu of permanent wiring and may not be run throuch walls and "J not be attached to the buildinc's surfaces. (SBMC 15.04.020, NEC 400-8) 2) Unused openincs in the panelboard and in out let boxes must be properlJ sealed. (SBMC 15.04.020, NEC 110-12) 3) Extension cords used of permanent wiring. 400-8) extensively inside of the building in lieu Removal required. (SBMC 15.04.020, NEC 4) No electrical equipment (e.g. receptacles, wiring, Junction boxes, -etc.) maJ be located within 18 inches of the floor of the repair car ace unless listed for Class 1, Division 2 hazardous location as defined bJ NEC 511-3. Removal required. (SBMC 15.04.020, NEC 511-4 and 511-S(d)) 300 NO"TH D STREET SAN 8ER!'\lA"OINO, CAI.IFOANIA 92411.0001 (11.)1'4-'1'1/10" . , o o 5) Exposed electrical wires In various locations (e.g. Interior ot the south wall, exterior ot the south wall, etc.). Wires lIust be properly terminated and enclosed In approved Junction boxes. (SBMC 15.04.020, NEC 300-15) 6) Inadequate support ot llgbt tlxture above radiator dip tank. (SBMC 15.04.020, NEC 410-15) 7) Tbe tlexlble ..tallic conduit wblcb serves tbe air co~ressor Is disjointed and dallaged, and tbe conductors are exposed. (SBMC 15.04.020, UAC 104 (e)) 8) Tbe cover tor tbe electrical disconnect serving tbe air compressor I.S IIlsslng, tbus exposing live electrical parts. (SBMC 15.04.020, NEe 110-17(a)) 9) Porcb cover Installed at tbe soutb exit door wltbout required permit.(SBMC 15.04.020, UBC 301(a)) 10) Daaaged llgbt tlxture In tbe restrooll (bas exposed wiring). (SBMC 15.04.020, UAC 104(e)) 11) Substandard electrical connection to bouse trailer at tbe east end ot tbe lot (l.e. tlexIble cord run over parking lot tor approxi..tely 130 teet, wltb nUllerous splices and non-waterproot connection at traller). (SBMC 15.04.020, NEC 400-8, NEC 410-57) 12) Daaaged electrical llgbt tlxture In the ottlce at tbe soutb side ot the building (exposed electrical wiring). Also, llgbt, switch, and associated Wiring bas recently been Installed wltbout required perm1ts.(SBMC 15.04.020, UAC 104(e) and 301(a)) ProDertv Maintenance Vlolatlons.CSBMC 15.24.050) 13) Broken windows. 14) Tbe toilet In the restroom Is broken and tbe urinal drain Is stopped up. 15) Grattiti on tbe building. 16) Tbe exterior ot the building needs painted. .. o o 17) The small house trailer at the east end of the lot is used for human habitation. The block wall at the north side of the lot is damaged. Also, the chain link fences are damaged or improperly installed (i.e. wood posts used with chain link fencing). 19) Debris and salvage items stored on the lot. 18) 20) Asphalt paving damaged at various locations. 21) Damaged pole sign at the southwest corner of the lot. 22) Approximately 12' X 12' X 8' deep hole has been excavated in parking lot. Must be =ackfilled, compacted and repaved. Miscellaneous 23) The hydraulic lift on the north side of the building must be removed, since all repair work must be conducted inside of the building and a permit has not been, and cannot be obtained for the installation. (SBMC 19.06.030) 24) The business known as Amigos Auto Center is illegally conducting all of its repair work outdoors, since it has no shop area available to it. Victor's Radiator shop was also observed repairing vehicles outside of the building. All repair work must be conducted inside of the building. (SBMC 19.06.030) 25) The abandoned underground gasoline storage tanks must be removed. A permit for the removal is required from the Fire Department. (UFC 79.114) This will be reported to the County Department of Environmental Health for enforcement action. 26) Numerous abandoned vehicles are stored on the lot. 8.36.010) (SBMC The above listed violations must be completed within 30 days of this date and a follow-up inspection obtained from this Department. If you should have any questions or require further clarification, please contact this office during normal business hours. Sincerely, Joseph Lease Senior Building Inspector Planning & Building Services Dept. City of San Bernardino 384-5071 . o o C~ARLES ~. EINDLEY ~.-:~or:1ey at Law : :224 Eas~ Orange~horpe Avenue F~a~en~ia, California 92670-5330 '':elephone: 714/579-7381 FAX: 714/579-7377 Bar: CA 55738 A~~orney for M. Rober~ Peters 'Ci ty of San Bernardino, APPELLAN'r'S OPENING STATEMENT Appellant ] ] ] ] ] ] ] ] PROJECT NUMBER: 91-3620 ,J. ,.-v- 3 ~ .M. Robert Peters, , '========================= -- .; Nature of Case " ,~ This is an appeal to the Common Council of the City ': lof San Bernardino, California, from the resolution of the Board was given only three notice \ i , ; I 1 the I I ':. :iof Building Commissioners on September 6, 1991. .1 Resolution of Board of Buildinq Commissioners Violated Peters' Constitutional Riqhts ~;:: .. ',7 Mr. Peters a day of ~ 3 : L meetinq of the Board which was insufficient time for him to :? , . !for the hearing. The Board made their resolution against Mr. , prepare I Peters I I M ':"U Mi thout him being present as he did not attend the hearing. Mr. .~o a reasonable had a constitutional right to protect, and he was entitled i i \ I I i , I I I , notice of the hearing; three days does not 21 : i ,I ;peters , constitute reasonalbe notice. " -- This Hearinq Was Continued Prom November 4, 1991 25 The Common Council continued this hearing to this date inorder for the City Planning and Building Services Department to reinspect the premises and to notify the appellant of any code Appellant's Statement Page 1 1f3/ o o 1 2 3 4 violations. The letter informing Mr. Peters of various code violations at 1098 West 5th Street is dated 'November 25, 1991, he re,?eived it late Tuesday, the 26th, which gave him two work 5 days prior to this hearing to reply to the alleged violations. 6 It needs also to be noted that the listed violations 7 must be completed within 30 days of November 25, 1991, with 8 a f~llow-up inspection by the city. 9 Electrical Violations 10 This is the first time that Mr. Peters has had written Il allegations of electrical violations at this location, and he 12 ill immediately consult with and hire an electrition to correct 13 the electrical problems. These are violations .1 through 12 14 15 16 17 18 owever, if the police cannot control the graffiti artists 19 nywhere in this ci fy, how does the city expect a property owner 20 ike Peters from preventing them from practicing their art work 21 n his walls? Other buildings on Mr. Peters' property have 22 ad to have been repainted a minimum of ten times this last 23 ear because of graffiti. 24 As to violation 17, the removal of the small house 25 trailer, a night watchman uses this trailer, and even with 26 him living on the property, in the last eighteen months a 27 conservative $17,000 worth of damage has been done to personal 28 property has been damaged or completely destroyed inclUding inclusive as denominated on the subject letter to Mr. Peters. copy of the letter is attached hereto. Property Maintenance Violations There is no problem in violations 13, 14, 15 and 16~ Appellant's Statement Page 2 1 2 3 .{ 5 6 7 8 9 10 1l 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 2i 28 o ? o 180 automobile glass broke~, 30 automobiles damaged or completely ruined and the theft of anything of value not nailed down. Car batteries have been stolen by the dozens, and }f one is 1eft in an autom?bile, it is gone over night. A picture is being pai?ted about what takes place with the night watchman living on th~ property. If he wasn't there at night, absolutely nothing would be safe from thieves. If the Council can guaranty around the clock police protection of both the buildings and' the personal property belonging to the appellant and his renters" the night watchman and his trailer will be removed immediately without question. However, it is doubtful that this council will make such a guaranty; so it is respectfully requested that no further issue be made about the trailer and the night watchman. The appellant agrees that the electrical wiring to the trailer should be made safe, and he will see that it is. Violations denominated as 18 through 22 can be corrected, but they obviously show that Mr. Peters' property has deliberately been overly inspected to find a defect no matter how small or how. it would affect the health and welfare of his neighbors. Miscelleneous violations Violations 23, 24 and 26 may be violations in accordance wi th certain City Ordinances, but for the city to prevent any repair work on automobiles to be done outside and not in an enclosed building is a flaqrant violation of a property owner's consti tutional rights and those of his renters. Cars have been stored on this property and repair work on automobiles has been Appellant's Statement Page 3 o o 1 done outside for the last fifty~four years includinq the 2 thirty-seven years your appellant has owned the property. 3 Why is it that this is the first time in those 4 fifty-four years that, to the best of appellant's knowledge 5 and belief, a citation has been given for this alleged violation? 6 Is it because the present city government has no respect for 7 its citizens' constitutional righ~s? 8 9 10 11 Even the ci tizens of San Bernardino should have the vested riqht under the United States Constitution to use and enjoy their property as lonq as the health and welfare of their .not neiqhbors are/placed in jeopardy. 12 As to violation 25, this underground tank has not been 13 used for many years, and it is not doing any damage to the 14 15 16 17 18 19 20 envirornent,' but if it has to be removed for some leqi timate reason' efforts will be made to do it. Points and Authorities Calder -v- Bull 3 Dall (US) 386 1 L Ed 648 and Gulf C & SFR Co -v-Ellis 165 US 150 40 L Ed 666 17 S Ct 255, The Supreme Court stated that the people of the united States enacted their constitution or form of government to establish justice, to promote the general welfare, to secure the blessings of liberty, and to protect their persons and property from violence. Plumas Countv -v- Wheeler 149 C 758 87 P 909 and Laurel Hill Cemeterv -v- San Francisco 152 C 464 93 P 70 Local ordiences passed under the police power, like all applicati"ons of that power must have a reasonable relation to that object. 21 22 23 24 Miller -v- Board of Public Works 195 C 477 234 P ill A valid exercise of the police power may not be arbitrary, iilnreasonable or discriminatory., and must not amount to an improper 'or arbetrary infrinqement of the constitutional rights 25 pf individuals. In re Baremore 174 C 286 165 P 50 26 27 28 In re Fuller 15 C2d 425 102 P2d 321 The degree of ~egulation must be commensurate with the evils to be remedied. IIIIIIIIII Aoop.llant's ~tarp~p~r Paqp' 4 ) o o 1 2 Miller -v- Mckenna 23 C2d 774 147 P2d 531 constitution provides that all men have the inalienable of acquiring, possessing and protecting property. The right Factor and Company -v- Kunsman i C2d 446 $5 P2d 177 and Yourself Gas Station 39 C2d 813 249 P2d 545 Are the 4 means reasonably designed to accomplish the results (health and safety) for the purpose adopted and do they have a substantial 5 relation to the objects sought to be attained. 6 7 8 3 P as to Herminghaus -v- So C.al Edison Company 200 C 81 252 607 The police power has not been judicially expanded so to invest the legislature department with arbitrary power destroy vested rights in private property. Sing Lee, Ex Parte 96 C 364 31 P 245 State Savings 9 Bank -v- Anderson 165 C 437 132 P 755 police power must be reasonable and free of oppression. 10 McKay Jewelers Inc. -v- Bawron 19 C2d 595 122 P2d 11 ill The legislature may not, under the guise of. the police power, impose uneccessary and unreasonable restrictions on the 12 ~se of private property, in the pursuit of useful.activities, or ~he conduct of a lawful and useful occupation or business that is 13 ~ot by its nature or because of the way in which it is carried pn, injurious to persons or property or to the public health, 14 ~onvenience, comfort, safety or morals. Whitewell. Ex Parte 8 P 870 and Dresel, Ex Parte 147 C 763 82 P 429 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: December 2, 1991 .Respectfully submitted, ~LQ'^ CHARLES T. HINDLEY Attorney for Appellant Appellant'S Statement Page 5 o 0 CITY OF San Bernardino DEPARTMENT OF PLANNING AND IUILDINO 'KRYle.. AL BOUGHEY.AICP DIRECTOR Maurice Peters 1098 W. 5th St. San Bernardino, Ca. Nov. 25, 1991 Re: Code Violations at 1098 W. 5th Street Dear Mr. Peters, During the council l118etlng of November 4, 1991, the CltJ Councll directed this Department to inspect Jour propertJ at the above referenced address and to provide JOu with a co.prehensive l1st of violat ions. On November 25, 1991, this inspect ion was conducted by Code Enforce_nt Officer DannJ NoUo, and mJseU, Senior BUllding Inspector Joseph Lease. The violatlons observed at this time are as follows: Electrical Violations - c.s 1) 1<1 . i . (; , Electrical connections made to the hydraulic lift OR the north side of the building without required permits.(SBMC 15.04.020, UAC 301 (a)) Also, the electrical installation is substandard; flexible cord may not be used in lieu of permanent wiring and may not be run through walls and may not be attached to the building's surfaces. (SBMC 15.04.020, NEC 400-8) ,( 'lC-J 1v .,(... \. 2) Unused openings in the panelboard and in outlet boxes must be properly sealed. (SBMC 15.04.020, NEC 110-12) .:, ..<o~ "'. ., . \ 3) Extension cords used of permanent wiring. 400-8) extensively inside of the building in lieu Removal required. (SBMC 15.04.020, NEC +'7 ~./ .:- , ' , 4) No electrical equipment (e.g. receptacles, wiring, Junction boxes, etc.) may be located within 18 inches of the floor of the repair garage unless listed for Class 1, Division 2 hazardous locat ion as deflned by NEC 511-3. Removal required. (SBMC 15.04.020, NEe 511-4 and 511-6(d)) 300 NORTH C' STREET. SAN BERNARDINO, CALIFORNIA 92"18-0001 (7'..)'......71,...7 ~ ,) '" , ".-.,.,...":> V :;....t'" ~< 8) ! . ':..:1 ~,I-./ " . . /c..;'::' 1) I J , 8) .;\S , ,.-rv J' ~ ' 9) "'~ 1\.'1'\'<-- , -;> 10) ,;1-" \1' 11) 0) \,." iXr-\ , 12) .L. / ~r"Y ..:) .1"'" \, - ro': ,;1-' 'V "-', o o 5) Exposed electrical wires in various locations (e.g. interior of the south wall, exterior of the south wall, etc.). Wires must be properly terminated and enclosed in approved Junction boxes. (SBMC 15.04.020, NEC 300-15) Inadequate support of light fixture above radiator dip tank. (SBMC 15.04.020, NEC 410-15) The flexible ~tallic conduit which serves the air co.pressor is disjointed and damaged, and the conductors are exposed. (SBMC 15.04.020, UAC 104 (e)) The cover for the electrical disconnect serving the air coapressor is missing, thus exposing live electrical parts. (SBMC 15.04.020, NEC 110-11(a)) Porch cover installed at the south exit door without required permit.(SBMC 15.04.020, UBC 301(a)) Damaged light fixture in the restroom (has exposed wiring). (SBMC 15.04.020, UAC 104(e)) Substandard electrical connection to house trailer at the east end of tbe lot (i.e. flexible cord run over parking lot for approximately 130 feet, witb nuaerous splices and non-waterproof connection at trailer). (SBMC 15.04.020, NEC 400-8, NEC 410-51) Damaged electrical light fixture in tbe office at the south side of tbe building (exposed electrical wiring). Also, ligbt, switch, and associated wiring bas recently been installed without required peraits.(SBMC 15.04.020, UAC 104(e) and 301(a)) Propertv Maintenance Violations.CSBMC 15.24.050) 13) Broken windows . 14) The toilet in the restrooa is broken and the urinal drain is stopped up. 15) Graffiti on the building. 18) The exterior of the building needs painted. ... - . .... o o ,- v /V .r"- 17) The small house trailer at the east end of the lot is used for human habitation. 18) The block wall at the north side of the lot is damaged. Also, v the chain link fences are damaged or improperly installed (i.e. wood posts used with chain link fencing). :~,J~~~-19) Debris and salvage items stored on the lot. If Jf_/V" 20) Asphalt paving damaged at various locations. V)- - 21) Damaged pole sign at the southwest corner of the lot. 22) Approximately 12' X 12' X 8' deep hole has been excavated in parking lot. Must be backfilled, compacted and repaved. Miscellaneous ,\j.J 23) The hydraulic lift on the north side of the building must be removed, since all repair work must be conducted inside of the building and a permit has not been, and cannot be obtained for the installation. (SBMC 19.06.030) 24) The business known as Amigos Auto Center is illegally conducting all of its repair work outdoors, since it has no shop area available to it. Victor's Radiator shop was also observed repairing vehicles outside of the building. All repair work must be conducted inside of the building. (SBMC 19.06.030) i\i ,) *- 25) The abandoned underground gasoline storage tanks must be removed. A permit for the removal is required from the Fire Department. (UFC 79.114) This will be reported to the County Department of Environmental Health for enforcement action. 26) Numerous abandoned vehicles are stored on the lot. 8.36.010) (SBMC The above listed violations must be completed within 30 days of this date and a follow-up inspection obtained from this Department. If you should have any questions or require further clarification, please contact this office during normal business hours. sincerely, Joseph Lease Senior Building Inspector Planning & Building Services Dept. City of San Bernardino 384-5071 ~ v' ~ *- .; C) c~ CHARLES T. HINDLEY p..~"":orney at Law : 1224 Eas~ Orangethorpe Avenue ,P1acen~ia, California 92670-5330 - , '':!:elephone: il4/579-738l 'FAX: 714/579-7377 Bar: CA 55738 A~torney for M. Robert Peters , i~ : \ Appellant ] ] ] ] ] ] ] ] PROJECT NUMBER: 91-3620 'Ci ty of San Bernardino. APPELLANT'S OPENING STATEMENT ~ ,'-v- ': 3 ~ ;M. Robert Peters. " ~ :========================= ~2 : I , Nature of Case " l' This is an appeal to the Common Council of the City 'j , 'iof San Bernardino, California, from the resolution of the Board '- 'Iof :i 1E :1 Building Commissioners on September 6, 1991. ~ 7 \ \ Resolution of Board of Building COmmissioners Violated Peters' Constitutional Rights :! , : ifor the hearing. The Board made their resolution against Mr. Ii ,I ,iPeters I I ;:to a had a constitutional right to protect, and he was entitled reasonable notice of the hearing; three days does not ~onstitute reasonalbe notice. :~ This Rearing Was Continued From November 4, 1991 2'; The Common Council continued this hearing to this date inorder for the City Planning and Building Services Department to reinspect the premises and to notify the appellant of any code Appellant's Statement Page 1 113/ CJ CJ The letter informing Mr. Peters of various code i violations at 1098 West 5th Street is dated 'November 25, 1991~ ~e rec::eived it late Tuesday, the 26th, which gave him two work 5 days prior to this h~aring to reply to the alleged violations. 6 It needs also to be noted that the listed violations 7 must be completed within 30 da:ys of November 25, 1991, with 8 a f~llow-up inspection by the city. 9 Electrical Violations 10 This is the first time that Mr. Peters has had written 11 allegations of electrical violations at this location, and he 12 ill immediately consult with and hire an electrition to correct 13 the electrical problems. These are violations .1 through 12 14 15 16 17 18 owever, if the police cannot control the graffiti artists 19 nywhere in this ci fy, how does the city expect a property owner 20 ike Peters from preventing them from practicing their art work 21 n his walls? Other buildings on Mr. Peters' property have 22 ad to have been repainted a minimum of ten times this last 23 ear because of graffiti. 24 As to violation 17, the removal of the small house 25 trailer, a night watchman uses this trailer, and ev~n with 26 him living on the property, in the last eighteen months a 27 conservative $17,000 worth of damage has been done to personal 28 property has been damaged or completely destroyed including 1 2 3 4 violations. nclusive as denominated on the subject letter to Mr. Peters. copy of the letter is attached hereto. Property Maintenance Violations There is no problem in violations 13, 14, 15 and l6~ Appellant's Statement Page 2 -== 1 2 S 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CJ ? c') 180 automobile glass broke~, 30 automobiles damaged or completely ruined and the theft of anything of value not nailed down. Car batteries have been stolen by the dozens, and }f one is 1eft in an autom?bile, it is gone over night. A picture is being pai?ted about what takes place with the night watchman living on th~ property. If he wasn't there at night, absolutely nothing would be safe from thieves. If the Council can guaranty around the clock police protection of both the buildings and. the personal property belonging to the appellant and his renters ,. the night watchman and his trailer will be removed immediately without question. However, it is doubtful that this council will make such a guaranty; so it is respectfUlly requested that no further issue be made about the trailer and the night watchman.. The appellant agrees that the electrical wiring to the trailer should be made safe, and he will see that it is. violations denominated as 18 through 22 .can be corrected, but they obviously show that Mr. Peters' property has deliberately been overly inspected to find a defect no matter how small or how. it would affect the health and welfare of his neighbors. Miscelleneous Violations Violations 23. 24 and 26 may be violations in accordance wi th certain City Ordinances, but for the city to prevent any repair work on automobiles to be done outside and not in an enclosed building is a flaqrant violation of a property owner's consti tutional rights and those of his renters. Cars have been stored on this property and repair work on automobiles bas been Appellant's Statement Page 3 1 1 1 1 1 1 . 0 0 done outside for the last fifty~four years including . thirty-seven years your appellant has owned the property. Why is it that this is the first time in t fiftY-,four years that, to the best of appellant's knowl and belief, a citation has been given for this alleged violati Is it because the present city government has no respect . 7 its citizens' constitutional rights? 8 Even the citizens of San Bernardino should have 9 vested right under the United States Constitution to use 0 en;oy their property as long as the health and welfare of t - ~ot 1 neighbors are placed in jeopardy. 2 As to violation 25, this underground tank has not . 3 used for many years, and it is not doing any damage to . 4 envirornent, but if it has to be removed for some leqitimate r 5 efforts will be made to do it. 16 Points and Authorities 17 Calder -v- Bull 3 Dall (US) 386 1 L Ed 648 and C & SFR Co -v-Ellis 165 US 150 40 L Ed 666 17 S Ct 255 18 Supreme Court stated that the people of the United States en their constitution or form of government to establish jus 19 to promote the general welfare, to secure the blessing liberty, and to protect their persons and property from violen 20 Plumas County -v- Wheeler 149 C 758 87 P 90 21 Laurel Hill Cemeterv -v- San Francisco 152 C 464 93 P 70 ordiences passed under the police power, like all applica 22 of that power must have a reasonable relation to that object. 23 Miller -v- Board of Public Works 195 C 477 381 A valid exercise of the police power may not be arbit 24 ~nreasona,ble or discriminatory. , and must not amount t ~mproper or arbetrary infringement of the constitutional r 25 of individuals. In re Baremore 174 C 286 165 P 50 26 In re Fuller 15 C2d 425 102 P2d 321 The degr regulation must be commensurate with the evils to be remedied. 27 IIIIIIIIII 28 Aoop.l1Ilnt's RtaT.p.JIIE'1'IT P",qP. 4 the 1 2 S 4 5 6 hose edge on? for the and heir been the eason Gulf The acted tice, s of ceo 9 and Local ti'ons 234 P rary, o an ights ee of w -J '- 1 2 3 ~ Miller -v- Mckenna 23 C2d 774 147 P2d 531 constitution provides that all men have the inalienable of acquiring, possessing and protecting property. The right Factor and Company -v- Kunsman Ii C2d 446 S5 P2d 177 and Yourself Gas Station 39 C2d 813 249 P2d 545 Are the means reasonably designed to accomplish the results (health and safety) for the purpose adopted and do they have a substantial relation to the objects sought to be attained. 4: 6 6 P 7 as to 8 Herminghaus -v- So C.al Edison Company 200 C 81 252 607 The police power has not been judicially expanded so to invest the legislature department with arbitrary power destroy vested rights in private property. 9 10 Sing Lee, Ex Parte 96 C 364 31 P 245 State Savings Bank -v- Anderson 165 C 437 132 P 755 police power must be reasonable and free of oppression. McKay Jewelers Inc. -v- Bawron 19 C2d 595 122 P2d 11 543 The legislature may not, under the guise of. the police . iPower, impose uneccessary and unreasonable restrictions on the 12 ~se of private property, in the pursuit of useful activities. or the conduct of a lawful and useful occupation or business that is 13 ~ot by its nature or because of the way in which it is carried n, injurious to persons or property or to the public health, 14: onvenience, comfort, safety or morals. Whitewell, Ex Parte 8 P 870 and Dresel, Ex Parte 147 C 763 82 P 429 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: December 2, 1991 _.e.pe~~ CHARLES T. HINDLEY Attorney for Appellant Appellant'S Statement Page 5 Q 0 CITY OF San l)ernardino DE'ARTMENT OF 'LANNING AND IUILDINQ ...RYICEI AL BOUGHEY.AICP DIRECTOR Maurice Peters 1098 W. 5th St. San Bernardino, Ca. Nov. 25, 1991 Re: Code Violations at 1098 W. 5th Street Dear Mr. Peters. During the council Dleeting of Novellber 4, 1991, the City Council directed this Depart.ent to inspect your property at the above referenced address and to provide you with a co~rehensive list of violat ions. On November 25, 1991, this inspection was conducted by Code Enforce.ent Officer Danny Nollo, and myself, Senior Building Inspector Joseph Lease. The violations observed at this time are as follows: Electrical Violations . r.) 1) 1 cJ 'I.c.: .101 Electrical connections ..de to the hydraulic lift OR the north side of the building without required permits. (SBMC 15.04.020, UAC 301 (a)) Also, the electrical installation is substandard; flexible cord may not be used in lieu of permanent wiring and may not be run through walls and ..y not be attached to the building's surfaces. (SBMC 15.04.020, NEC 400-8) o!. /,vrJ ..v' " ~ 2) Unused openings in the panelboard and in outlet boxes IIUSt be properly sealed. (SBMC 15.04.020, NEC 110-12) <5 ..(0\ . V' .1. \ 3) Extension cords used of permanent wiring. 400-8) extensively inside of the building in lieu Removal required. (SBMC 15.04.020, NEC .('-7 . ~v ".1..... 4) No electrical equip_nt (e.g. receptacles, wiring, Junction boxes, etc.) may be located within 18 inches of the floor of the repair garage unless listed for Class 1, Division 2 hazardous location as defined by NEC 511-3. Removal required. (SBMC 15.04.020, NEC 511-4 and 511-6(d)) 300 NORTH 0 STREET, SAN BERNARDINO. C A L I FOR N I A 9 2 " 1 8 . 0 0 0 1 (1 1 4 >> 3. 4 . 1071 I I . . 7 - , ,'/' l'l"fc.."--- Vi.... ..le. : .r~UI-../ V' ..... 7 ) ..<:;j:'s Ii i :,..' - , -"C,S ~,\C.l c:> CJ 5) Exposed electrical wires in various locations (e.g. interior of the south wall, exterior of the south wall, etc.). Wires must be properly terminated and enclosed in approved Junction boxes. (SBMC 15.04.020, NEC 300-15) 6) Inadequate support of light fixture above radiator dip tank. (SBMC 15.04.020, NEC 410-15) The flexible metallic conduit which serves the air co.pressor is disjointed and damaged, and the conductors are exposed. (SBMC 15.04.020, UAC 104 (e)) 8) The cover for the electrical disconnect serving the air compressor is missing, thus exposing live electrical parts. (SBMC 15.04.020, NEC 110-17(a)) 9) Porch cover installed at the south exit door without required permit. (SBMC 15.04.020, UBC 301(a)) ,.,-:; ~i'\,,,,,. :> 10) ,;re' VI .> \~;'" rl" . ,L.. . 'i /' ~r"~" - ^' .1vd-- ~I- 0' ,./01-- ",' Iv Damaged light fixture in the restroom (has exposed wiring). (SBMC 15.04.020, UAC 104(e)) 11) Substandard electrical connection to house trailer at the east end of the lot (1.e. flexible cord run over parking lot for approximately 130 feet, with numerous splices and non-waterproof connection at trailer). (SBMC 15.04.020, NEC 400-8, NEC 410-51) 12) Damaged electrical light fixture in the office at the south side of the building (exposed electrical wiring). Also, light, switch, and associated wiring has recently been installed without required permits.(SBMC 15.04.020, UAC 104(e) and 301(a)) ProDertv Maintenance Violations.CSBMC 15.24.050) 13) Broken windows . 14) The toilet in the restroom is broken and the urinal drain is stopped up. 15) Graffiti on the building. 16) The exterior of the building needs painted. , Q (~~ '- .>""'17) The small house tr:iler at the east end of the lot is used for ~ v human habitation. 18) The block wall at the north side of the lot is damaged. Also, v the chain link fences are damaged or improperly installed (i.e. wood posts used with chain link fencing). :J<~oJ.f,' 19) :,.A._/V' 20) 21) Debris and salvage items stored on the lot. v/ Asphalt paving damaged at various locations. Damaged pole sign at the southwest corner of the lot. 22) Approximately 12' X 12' X 8' deep hole has been excavated in parking lot. Must be backfilled, compacted and repaved. Miscellaneous i\J ':) 23) The hydraulic lift on the north side of the building must be removed, since all repair work must be conducted inside of the building and a permit has not been, and cannot be obtained for the installation. (SBMC 19.06.030) 24) The business known as Amigos Auto Center is illegally conducting all of its repair work outdoors, since it has no shop area available to it. victor's Radiator shop was also observed repairing vehicles outside of the building. All repair work must be conducted inside of the building. (SBMC 19.06.030) ~ /'l) * *- 25) The abandoned underground gasoline storage tanks must be removed. A permit for the removal is required from the Fire Department. (UFC 79.114) This will be reported to the County Department of Environmental Health for enforcement action. 26) Numerous abandoned vehicles are stored on the lot. 8.36.010) (SBMC The above listed violations must be completed within 30 days of this date and a follow-up inspection obtained from this Department. ' If you should have any questions or require further clarification, please contact this office during normal business hours. Sincerely, Joseph Lease Senior Building Inspector Planning & Building Services Dept. City of San Bernardino 384-5071