HomeMy WebLinkAboutle ltr & decision Denis Law Mayor
City Clerk-Jason A.Seth,CMC
August 14, 2018
Mr. Hoa Le
1812 Elma Av NE
Renton, WA 98059
Re: Hearing Examiner's Decision
Case No.: CODE-18-000224
Dear Mr. Le:
Attached is your copy of the Hearing Examiner's Decision dated August 14, 2018 in the above-
referenced matter.
If I can provide further information, please feel free to contact me.
Sincerely,
/47-:/1
son A. Se Clerk
cc: Hearing Examiner
Craig Burnell, Building Official
Donna Locher, Code Compliance Inspector
Robert Shuey, Code Compliance Inspector
Kevin Louder, Code Compliance Inspector
1055 South Grady Way, Renton,WA 98057 • (425)430-6510/Fax (425)430-6516 • rentonwa.gov
BEFORE THE HEARING EXAMINER OF
RENTON
DECISION
FILE NUMBER: CODE18-000224
ADDRESS: 4526 ne 4TH St
Renton, WA 98059-5005
PROPERTY OWNER: Hoa Le
1812 Elma Ave NE
Renton, WA 98059
REVIEW AUTHORITY: City of Renton
TYPE OF CASE: Finding of Violation
INTRODUCTION
Hoa Le has been charged with four violations of Renton's Municipal Code for the actions of his
tenants for property he owns at 4526 ne 4TH St. The violations are for the most part not contested
by Mr. Le and are sustained except for Violation No. 4, since wood chips are too small to qualify
as"bulky" waste. However, as acknowledged by Ron Shuey,the City's representative„ Mr. Le's
property manager has made a good faith effort to cooperate with the City to compel Mr. Le's tenant
to abate the violations. Given these efforts, Mr. Shuey testified it would be reasonable to suspend
the $750 fines accruing from the three violations pending the successful eviction of the tenants.
Consequently, a fine of$750 in fines is imposed for the code violations of this appeal, but those
fines shall be suspended for three months through November 30, 2018. If Mr. Le has successfully
evicted his tenants by this date, the $750 in fines shall be deemed waived. Ron Shuey shall have
authority to extend the November 30, 2018 deadline to the extent that Mr. Le demonstrates that
additional time is reasonably necessary to complete the eviction process. Suspension of the fines
is also contingent upon Mr. Le showing proof to Mr. Shuey that he has filed an eviction action
with a court of jurisdiction by August 31, 2018.
HEARING
The hearing was held on the alleged violations of this case on August 16, 2016, at 10:00 a.m. at
the Renton City Hall Council Chambers, Mason County Commissioner's Chambers, 1055 South
Grady Way, Renton, WA 98057.
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TESTIMONY
Ron Shuey, Renton Code Enforcement Officer, presented some photographs taken the morning of
the appeal hearing as Ex. 11. Mr. Shuey noted that the code enforcement action was initiated by
complaint. The property was alleged to be operating a tree removal business at a residence. The
residential property was also covered in wood chips and was used to store cars and commercial
equipment. Mr. Shuey issued a Warning of Violation and sent it by mail and email. Within 24
hours he received a response from the property manager. Mr. Shuey noted he typically only deals
with the property owner (represented by the property manager in this instance) as opposed to the
tenants. On 5/23 he took some photographs to see how things were going. He emailed the property
manager to let her know there had been no real change with the property other than the removal of
two or three cars. All commercial vehicles, stump grinder, bob cat and commercial equipment
were still on the property. The property manager assured Mr. Shuey that she would talk to the
tenants about either cleaning up the property or face eviction. Mr. Shuey agreed to give the
property manager additional time to try to work something out. On June 8 Mr. Shuey drove by
again and everything was pretty much the same as it had been before. Mr. Shuey then issued a
Finding of Violation. The finding alleged operating a business without a business license, which
Mr. Shuey had verified at the website, junk vehicles by virtue of being unlicensed or clearly
inoperable from right of way observation, parking in excess of maximum authorized vehicles and
storage of bulky waste due to wood chips. In response to examiner questions, Mr. Shuey noted
that the bulky waste charge was based upon the wood chips and tree remnants. The front yard
used to be a nicely maintained yard with lawn and circular drive. Now it's completely covered in
wood chips. The driveway was probably gravel. In a drive by inspection on the day of the hearing,
Mr. Shuey counted ten vehicles on the property. Wood chips were still all over the property.
Mr. Le, Appellant, stated he "agreed with all the violations." He wasn't aware that as property
owner he could be fined for the actions of his tenants. He believes that the person responsible for
the violation should pay for it, especially the business license violation. He inquired how he could
know whether or not a business is being operated without a license by his tenants.Mr.Le requested
reduction of the fines since he was just the property owner. In response to examiner questions,
Mr. Le noted that his property manager did contact the tenant upon first hearing from Mr. Shuey
and that the manager tried to persuade the tenant to comply.
The property manager, Cindy Ginsburgh, testified that she did not disagree with the alleged
violations. She tried to get the tenants to comply via email and phone calls. The tenants assured
her they were working on the violations but there were no results. On the day that Mr. Shuey
issued the Finding of Violation, Ms. Ginsburgh had a ten day eviction notice served upon the
tenants. The eviction process can sometimes take a long time.
In response to examiner questions, Ms. Ginsburgh stated that she forwarded the Warning of
Violation to the tenants by email on the date she received it from Mr. Shuey. Ms. Ginsburgh was
not able to state when she contacted the tenant next after the Warning of Violation, except to state
that communications were frequent. Ms. Ginsburgh did check on the property between the
Warning of Violation and Finding of Violation but did not see much improvement.
Mr. Shuey noted that Ms. Ginsburgh has been very cooperative and done what she could to get the
tenants to comply. Mr. Shuey had advised Ms. Ginsburgh that he would put the code enforcement
Code Enforcement Decision-2
process on hold if Ms. Ginsburgh initiated eviction, but when she didn't do so Mr. Shuey issued
the Finding of Violation. Mr. Shuey stated he would be agreeable to an order suspending fines
contingent upon the appellant initiating eviction within a couple weeks of the hearing and
completion of eviction within six months.
EXHIBITS
The 10 exhibits identified in the City of Renton Exhibit List,CODE 18-000224 were admitted into
the record at the June 25, 2018 hearing. A packet of eleven photographs plus website information
taken that morning were presented by Mr. Shuey were admitted as Ex. 11.
FINDINGS OF FACT
1. The violation site is located at 4526 ne 4TH St, Renton. The site in question is a single
family residence owned by Hoa Le, 1812 Elma Ave NE, Renton, WA 98059.
2. Chronology. Rob Shuey, Renton Code Enforcement Officer, first received a complaint
about the subject property on April 19,2018. He issued a Warning of Violation on April 20, 2018
detailing five code violations, four of which comprise the violations of the Finding of Violation
subject to this appeal. He consulted with Mr. Le's property manager, who assured Mr. Shuey she
would work with the tenants to compel compliance. The Warning of Violation required abatement
by May 23,2018. Mr. Shuey did a site visit on May 23, 2018 and found four of the five violations
still remained. He again consulted with the property manager and extended the compliance date
an additional two weeks. Mr. Shuey inspected the property again on June 7, 2018 and found the
property still in noncompliance with four of the five regulations identified in the Warning of
Violation. Mr. Shuey issued a Finding of Violation alleging the four code violations on June 8,
2018.
3. Violations. Factual findings specific to the four violations alleged in the June 8, 2018
Finding of Violations are addressed below. All findings are for violations located upon the subject
property on June 8, 2018. Mr. Le didn't contest any of the facts underlying the findings below:
Violation I Operating without a Business License: Mr. Le's tenant was operating a
business without a business license. The name of the business was Norwest Tree Services.
Mr. Shuey determined the business was operating at the site based upon a webpage
advertisement for the service. He determined the business did not have a business license
by searching City business license records.
Violation 2 Junk Vehicles —Private Property: The following vehicles were on the subject
property on June 8, 2018: A 1997 Apollo 25 foot Vessel License WN 121 DU(Expired 06-
30-10), a 2004 Vermeer Brush Chip Trailer license 10721AB (Current), a 1996 Ford
Pickup license C07507F (Expired 12-04-17), a 1999 International 4000 Truck license
B08929E (Expired 12-04-17), a 2008 BMW 535 License BHL3920 (current), a 1996
Chevrolet Pickup license B94700U(current),a 2007 Ford Pickup license C30747J(expired
04-05-18),a 1995 GMC Topkick Truck license C 77181L(current),a red colored twin axle
car hauling trailer(make,model and license unknown),a white Isuzu Cargo Truck GVWR
14,000 (license unknown), a white International 4700 Cargo Truck (license unknown), a
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Bobcat Skid-Steer Loader (Commercial Equipment), a Vermeer Stump Grinder
(Commercial Equipment),a Covered Utility Trailer(Make, Model and License Unknown).
Violation 3 Parking Over Four Vehicles in Residential Zone: More than four vehicles were
parked on the subject property as described for Violation 2. The vehicles were not parked
within enclosed buildings since they were visible to Mr. Shuey from the public right of
way and he noted seeing more than ten in plain view as outlined for Violation No.2 above.
Violation 4 Bulky Waste on Private Property. Wood chips generated from on-site tree
business were spread throughout entire front of property, including former driveway and
yard.
CONCLUSIONS OF LAW
1. Authority of Examiner: The Hearing Examiner has the authority and jurisdiction to review
code violations as provided in RMC 1-3-2.
2. Zoning. According to the City's COR map posted at its website,the zoning of the subject
property is Commercial Arterial (CA).
3. Owner Responsibility for Tenant Actions. Mr. Le questioned why he is being made
responsible for the actions of his tenants, in particular for the tenant's operation of a business
without a business license. RMC 1-3-2(B)(l0) defines a "violator" to include any owner of
property where a code violation exists. RMC 1-3-2(C)(2)authorizes the City to issue a Finding of
Violation against any violator. Taken together, RMC 1-3-2(B)(10) and 1-3-2(C)(2)authorize the
City to hold property owner's responsible for any violations committed on the owner's property.
However, upon appeal the hearing examiner has the authority to reduce fines to the extent that
justice requires, such as in circumstances where the owner could not have been reasonably aware
of a violation or where the owner has limited control over the violation. See RMC 1-3-
2(F)(1)(fines may be levied "up to" $250). That is why ultimately the fines of this case may be
waived in their entirety if Mr. Le engages in a reasonable effort to evict his tenants since they
have failed to cooperate with him in abating the violations subject to this appeal.
4. Code Violations: As identified in Finding of Fact No. 3,the code sections allegedly subject
to each violation are as follows:
Violation 1: RMC 5-5-3(1).
Violation 2: RMC 6-1-3
Violation 3: RMC 4-4-080(F)(10)
Violation 4: RMC 8-1-4(E)
The code sections cited above are quoted below in italics and applied through corresponding
conclusions of law.
Code Enforcement Decision-4
Violation 1 RMC 5-5-3(A)(3) Operating a Business Without a Business License: No person
shall engage in Business unless such Business is authorized by a valid City of Renton general
business license...
5. Violation 1 Sustained. As determined in Finding of Fact No. 3, the tenant of the subject
property was operating a business without a business license on June 8, 2018. The Finding of
Violation does not accurately quote from the text of the on-line City business license regulations,
but the code violation is clear under both the language of the Finding of Violation as well as that
of the provision quoted above.
Violation 2 RMC 6-1-3 Junk Vehicles: The storage, maintenance or retention ofjunk, wrecked,
dismantled or an apparently inoperable vehicle, vehicle hulk, or any parts thereof on private real
property in the City is hereby declared to be a public nuisance and subject to abatement in
accordance with this Chapter and RMC 1-3-3, as now worded or hereafter amended.
RMC 6-1-2 Junk Vehicle Definition: A vehicle that meets at least three of the following
requirements: (1)a vehicle that is three years old or older; (2)a vehicle that is extensively
damaged, such damage including but not limited to any of the following: a broken window
or windshield, or missing wheels, tires, motor, or transmission; (3) a vehicle that is
apparently inoperable; (4) a vehicle that has an approximate fair market value equal only
to the approximate value of the scrap in the vehicle's current condition; or (5) evidence of
inoperability or damage that includes, but is not limited to, any buildup of debris that
obstructs use, or a flat or missing tire or tires, or a nonfunctional motor or transmission,
or missing bumpers, or missing license plates, or expired vehicle license plate tabs.
RMC 6-1-2 Inoperable Definition: A vehicle that is apparently not functioning or is
inoperative or cannot be lawfully operated upon public roads or highways.
6. Violation 2 Sustained for Vehicles with Expired Tabs. The vehicles identified in the
paragraph below as having expired tabs are concluded to qualify as junk vehicles that were stored
on private property on June 8, 2018 in violation of RMC 6-1-3.
Under the definitions above, a vehicle qualifies as a junk vehicle and is thus barred from storage
on private property include vehicles with expired tabs. That is the only basis for concluding a
vehicle qualifies as a prohibited junk vehicle from the observations reported by Mr. Shuey. The
vehicles he identifies as having expired tabs in Finding of Fact No. 3 are the 1997 Apollo 25 foot
Vessel License WN121DU (Expired 06-30-10), a 1996 Ford Pickup license C07507F (Expired
12-04-17),a 1999 International 4000 Truck license B08929E(Expired 12-04-17),and a 2007 Ford
Pickup license C30747J (expired 04-05-18). Sometimes the state of damage shown in the
photograph of a vehicle is enough to establish that vehicle as a junk vehicle under the criterion
above, however the limited June 8, 2018 photographs (the violation date) do not show any such
damage.
Violation 3 RMC 4-4-080(F)(10) Maximum Parking for Residential Uses — Detached
Dwellings Outside of Center Downtown Zone: ...A maximum of 4 vehicles may be parked on a
lot, including those vehicles under repair and restoration, unless kept within an enclosed
building...
Code Enforcement Decision-5
7. Violation 3 Sustained. As determined in Finding of Fact No. 3, more than four vehicles
were parked outside on June 8, 2018 in violation of RMC 4-4-080(F)(10). Mr. Le correctly points
out that the subject property is not zoned residential, but RMC 4-4-080(F)(10) expressly applies
to residential "uses,"not residential "districts." The single family home as depicted in the exhibit
photographs is for a residential use, although the property is also concurrently being used for a
home business.
Violation 4 RMC 8-1-4(E) Unlawful Storage of Bulky Waste: Unlawful Storage of Bulky
Waste: It shall be unlawful for any person in the City to store, maintain, keep, retain, dump or
accumulate bulky waste on private real property in the City, except for any licensed ancillary
disposal provider or licensed business in connection with bulky waste collection or disposal in an
area zoned for the collection or disposal of bulky waste.
RMC 8-1-2 Bulky Waste Definition: BULKY WASTE: Large items of solid waste,
including but not limited to items such as furniture; large household appliances, including
but not limited to refrigerators,freezers, ovens, ranges, stoves, dishwashers, water heaters,
washing machines, or clothes dryers;junk vehicles, vehicle hulks or any parts thereof as
defined in RMC 6-1-2, as now worded or hereafter amended;and any other oversized solid
wastes which would typically not fit into or be permitted for collection as garbage in
garbage cans.
8. Violation 4 Reversed. Violation 4 is not sustained because the wood chips do not qualify
as"bulky waste." Although the chips in toto certainly qualify as"large" in volume,the definition
contemplates "items" of solid waste that are individually large in scale, such as furniture and
appliances. Wood chips do not individually qualify as "large" items. None of the examples in
the "bulky" waste definition are small items that collectively are large in volume. They are all
large individually and would be commonly understood as"bulky." No one commonly understands
an individual wood chip to be "bulky." The wood chips much more easily qualify as unlawful
storage of garbage or yard waste under RMC 8-1-4(C), but that is not the provision referenced in
the Finding of Violation.
FINES
Fines are governed by RMC 1-3-2(F)(l)', which imposes a penalty of"up to" $250 per violation.
As outlined in Conclusion of Law No. 3,the"up to" language grants the examiner some discretion
in the levying of fines in the interest of justice. As testified by Mr. Shuey, Mr. Le's property
manager has been very cooperative with the City and has made some good faith effort in attempting
to secure compliance from the tenants of the subject property. For these reasons, Mr. Shuey's
The Finding of Violation correctly identifies that RMC 5-5-3(G)requires a"minimum"penalty of$250 for
operating without a business. This provision is construed as applying only to business owners operating without a
business. The liability of Mr.Le for the actions of his tenants originates from his status as a property owner under
Chapter 1-3 RMC. Consequently,his liability for penalties is also construed as subject to Chapter 1-3 RMC,
specifically the discretion authorized under the"up to" language of RMC 1-3-2(F)(1).
Code Enforcement Decision -6
concurrence with waiver of fines if Mr. Le evicts his tenants within a reasonable amount of time
is adopted by this decision.
DECISION
Violation No. 1, 2 and 3 as identified in Finding of Fact No. 3 are all affirmed and Violation No.
4 is reversed for the reasons identified in the Conclusions of Law. $750 in fines is imposed for the
code violations of this appeal ($250 for each sustained violation)but those fines shall be suspended
for three months through November 30, 2018. If Mr. Le has successfully evicted his tenants by
this date, the $750 in fines shall be deemed waived. Ron Shuey and/or his designee shall have
authority to extend the November 30, 2018 deadline to the extent that Mr. Le demonstrates that
additional time is reasonably necessary to complete the eviction process. Suspension of the fines
is also contingent upon Mr. Le showing proof to Mr. Shuey and/or his designee that he has filed
an eviction action with a court of jurisdiction by August 31, 2018.
Decision issued August 14,2018.
Phi A.Olbrechts
Hearing Examiner
NOTICE OF RIGHT TO APPEAL
Appeal to Superior Court. An appeal of the decision of the Hearing Examiner must be filed with
Superior Court within twenty-one calendar days,as required by the Land Use Petition Act,Chapter
36.70C RCW:
Code Enforcement Decision -7