HomeMy WebLinkAboutRemus Suciu Code Denis Law Ariv City Of ` ty
Mayor
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City Clerk -Jason A.Seth,CMC
September 26, 2016
Remus Suciu
1924 Aberdeen Avenue NE
Renton, WA 98056
Re: Hearing Examiner Decision, FOV#: 15-000562
Dear Mr. Suciu:
I have attached the Hearing Examiner's Decision dated September 23, 2016, in the above
referenced matter.
If you have any questions or concerns, please feel free to contact me.
Sincerely,
"WI
Jason A. eth, CMC
City Clerk
Attachment
cc: Hearing Examiner
Craig Burnell, Building Official
Donna Locher, Code Compliance Inspector
Tim Lawless, Code Compliance Inspector
Robert Shuey, Code Compliance Inspector
1055 South Grady Way• Renton,Washington 98057 • (425)430-6510/Fax(425)430-6516• rentonwa.gov
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BEFORE THE HEARING EXAMINER OF
RENTON
DECISION
FILE NUMBER: FOV#: 15-000562
ADDRESS: 1924 Aberdeen Ave NE
Renton, WA 98056-2628
APPELLANT: Remus Suciu
DBA Auto Boat Cargo Transport
1924 Aberdeen Ave NE
Renton, WA 98056-2628
REVIEW AUTHORITY: City of Renton
TYPE OF CASE: Finding of Violation
RULING: Appeal Sustained; Finding of Violation Reversed
INTRODUCTION
Remus Suciu appeals a Finding of Violation violating RMC 4-9-090,the City's home occupation
standards, for parking a commercial vehicle outdoors contrary to the terms of a home occupation
permit. Mr. Suciu's appeal is sustained and the Finding of Violation is overturned. The appeal
is sustained because the Finding of Violation asserts a different violation than the Warning of
Violation. The Warning of Violation is based upon the assertion that Mr. Suciu had a
commercial trailer parked on his driveway. Based upon photographs and vehicle records, this
decision determines that the vehicle that is the subject of the Warning of Violation is not the
same vehicle that is the subject of the Finding of Violation. The Warning of Violation is based
upon a violation date of 9/15/15 when a semi-trailer was parked on Mr. Suciu's driveway. The
Finding of Violation is based upon another violation date (6/27/16) when Mr. Suciu had a boat
trailer parked on his driveway instead of the semi-trailer. As noted in a prior decision, the
Finding of Violation must be based upon the same violation as the Warning of Violation. In this
case the vehicle for the Finding of Violation was different than the vehicle for the Warning of
Violation,hence they are two different violations.
This is the second code violation case in a row where an appeal has been sustained for failure to
provide a required Warning of Violation prior to issuance of a Finding of Violation. There is
'Note that the Finding of Violation could not be based upon the 9/15/15 violation date because the City had given
Mr. Suciu six months to remove the trailer(apparently from the 9/15/15 Warning date—Se. Ex.2,p.4). As best as
can be ascertained,the Appellant did remove the 9/15/15 trailer from the driveway within the required six months.
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some room to argue that since Mr. Suciu violated the same code section, albeit with different
vehicles, that each of these two violations should be considered the same violation and that a
Warning of Violation for the first vehicle should satisfy notice requirements for the second
vehicle. Unfortunately, the code just isn't written that way for the reasons outlined in this
decision. At the very best, the code is subject to more than one reasonable interpretation on this
issue. Faced with multiple reasonable interpretations, a court is unlikely to adopt the
interpretation that works against a code compliance defendant if the defendant could reasonably
claim he understood the code to give him the right to a prior Warning of Violation.
It is recognized that the way the code is written makes it very difficult to deal with repeat
offenders. If Mr. Suciu is indeed a repeat offender as alleged by the City, he can continue to
repeatedly violate the conditions of his home occupation permit and just stop each particular
incidence once he gets a Warning of Violation, thereby completely avoiding monetary penalties.
However, RMC 1-3-1(D) authorizes the City to revoke Mr. Suci's home occupation permit if
these violations continue to occur. If the City can successfully prove that all of the past
violations alleged in the exhibits of this case have in fact occurred, Mr. Suciu could face a very
real possibility of losing his home occupation permit. No prior Warnings of Violation would be
necessary for this to happen. Mr. Suciu should keep this in mind if he has any intention of
playing games with the City's code enforcement system.
The City is invited to request reconsideration on the Warning of Violation issue if it believes that
the examiner has misconstrued the code. It is recognized that the examiner's interpretation will
make it exceedingly difficult for code enforcement personnel to deal with repeat offenders. The
Warning of Violation issue needs to be fully litigated to ensure that the code is being applied as
written and intended by the City Council. In order to avoid prejudgment and ex parte contact
appearance of fairness issues, the issue is best addressed through the appeal process as opposed
to separate meetings with City staff. Code enforcement staff may find it helpful to enlist the
assistance of the City Attorney's Office to put together their legal argument.
HEARING
The hearing was held on the alleged violations of this case on August 23, 2016, at 9:30 a.m. at
the Renton City Hall Council Chambers, 1055 South Grady Way, Renton, WA 98057. The
record was left open through August 24, 2016 in order to give Mr. Suciu an opportunity to
submit Exhibit 21.
TESTIMONY
Donna Locher, Renton code enforcement officer, testified that the City granted Mr. Suciu a
business license for an auto transport operation that ships vehicles and boats. The address is
1924 Aberdeen Ave. NE. The license was approved in 2012 with conditions, including no
equipment , no parking of commercial vehicles and no parking of employee vehicles. These are
standard conditions placed on home occupations to ensure they are compatible with surrounding
residential use. The purpose of the Ex. 5 and Ex. 6, 2013 photographs is to demonstrate how
long the situation has been going on. The city gets complaint because of noise and the parking.
Ex. 8-12 shows current violations. Ms. Locher said she ran a DOL records search on the vehicle
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listed in Ex. 12 and found that it has a gross weight of 80,000 pounds and it's used for
commercial purposes. The vehicle is next door to the subject property. The appellant owns both
properties and uses them both for his home occupation. Mr. Suciu was sent a warning letter on
September 15, 2015 and then a second warning letter on October 29, 2015 with a November 13,
2015 compliance date after Ms. Locher visited the site on October 28, 2015 (Ex. 14). On
September 22, 2015 Mr. Suciu met with Ms. Locher and agreed to remove the forklift, car from
the trailer and semi-cab from his properties. He also agreed to remove the commercial trailer
within three weeks. On October 28, 2015, the commercial trailer was still on the property, which
lead to the second warning letter. On November 2, 2015 Mr. Suciu asked for a six-month
extension to convert the commercial trailer into a motor home. Ms. Locher agreed to the
extension. On June 27, 2016 Ms. Locher went back to the property and the commercial trailer
was still there(Ex. 16 and 17) —the top was gone, but the trailer was still there. Since Mr. Suciu
had not removed the trailer she issued a Finding of Violation for $100. The violation letter was
sent to the address of his original business license application. Mr. Suciu then visited Ms.
Locher and told her he had transferred his business to the adjoining lot, 1916 Aberdeen Ave SE.
The home occupation must be conducted from the property for which the license was issued.
There have been numerous complaints since 2013 on the property. Her co-worker had also
observed welding being done on the property.
In response to examiner questions, Ms. Locher noted that the date of the violation was June 27,
2016, when she took photographs Ex. 16 and 17. The trailer remnant identified in Ex. 16 and 17
is the basis of the violation. There is a home on both adjoining properties owned by Mr. Suciu.
The trailer remnant depicted in Ex. 16 and 17 was located on the 1924 Aberdeen Ave SE
property. It was never moved.
Mr. Suciu testified he's not the owner of Auto Boat Cargo Transport (the applicant for the Ex. 3
home occupation license) and never was. The Ex. 10 trailer is not a commercial vehicle, it's a
personal vehicle. Mr. Suciu stated that he agreed to move it and he did move it. The vehicle Ms.
Locher saw six months later is an entirely different trailer with a different VIN number and
everything else. The second trailer is a boat trailer. He bought the trailer out of the Marysville
boat yard. The boat trailer is for personal use only. The trailer didn't have wheels at the time the
picture was taken but now it does. He has two boats. The fork lift is in Mr. Suciu's garage. His
driveway was empty for five months after he moved the first trailer.
In rebuttal, Ms. Locher noted that the business license states that Remus Suciu and Paula
Muresan dba Auto Boat Cargo Transport. The trailer is a commercial trailer since the business is
for the commercial vehicles. Ms. Locher asked Mr. Suciu if Auto Boat Cargo Transport
transports boats and he said it does not. Ms. Locher noted that they advertise boat hauling.
EXHIBITS
Ex. 1 Scheduling Letter dated August 8, 2016
Ex. 2 Code Compliance Narrative dated July 25, 2016
Ex. 3 Home Occupation License application dated June 6, 2012
Ex. 4 Business license approval dated June 7, 2012
Ex. 5 Photograph of semi-flat bed dated 2/27/13 by Locher
Ex. 6 Photograph 2/27/13 by Locher semi-flat bed
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Ex. 7 2/28/13 letter from Locher to Mr. Suciu
Ex. 8 9/15/15 photo from Locher of Nissan on trailer
Ex. 9 9/15/15 photo of forklift
Ex.10 9/15/15 photo of semi-trailer
Ex. 11 9/15/15 photo of red semi-cab
Ex. 12 9/15/15 photo of license 52640RP
Ex. 13 Warning of Violation dated 9/15/15
Ex. 14 Photograph taken 10/28/15 of semi-trailer
Ex. 15 Letter from Locher to Suciu 10/29/15
Ex. 16 6/27/16 photo of trailer
Ex. 17 6/27/16 Photograph of trailer(including side mirror)
Ex. 18 Finding of Violation dated 6/28/16 (including request for appeal)
Ex. 19 6/27/16 Photograph of trailer
Ex. 20 Photograph of driveway
Ex. 21 Receipt of boat trailer purchase
FINDINGS OF FACT
1. Appellant and Violation Site. The site is located at 1924 Aberdeen Ave NE, Renton WA,
989056-2628. The site in question is a single-family residence where Mr. Suciu operates a home
occupation for Auto Boat Cargo Transport. In the application for the home occupation license,
Mr. Suciu is listed as one of two parties "dob" [sic] as Auto Boat Cargo Transport. See Ex. 3. It
is uncontested that Mr. Suciu owns the home occupation site as well as an adjoining single-
family home lot located at 1916 Aberdeen Avenue NE as alleged in the City's code compliance
narrative, Ex. 2. It is determined that Mr. Suciu owns the property at which the subject violation
occurred.
2. Warning of Violation. A Warning of Violation was mailed to Mr. Suciu on September
15, 2015. The Warning of Violation alleged violation of RMC 4-4-090(4), without identifying
which specific subsections applied to the violations. The Warning of Violation identified several
vehicles and equipment in violation of RMC 4-4-090(4), including an allegation that there was a
"commercial trailer" located on 1924 Aberdeen Ave NE. The Warning of Violation doesn't
identify any specific date of violation. However, a photograph taken September 15, 2015
identifies an enclosed commercial trailer, without cab, located at 1924 Aberdeen Ave NE. See
Ex. 10.
3. Finding of Violation. A Finding of Violation was mailed to Mr. Suciu on June 28, 2016.
The Finding of Violation again quoted the entirety of RMC 4-9-090(4) without identifying which
specific subsections applied to the subject violation. The Finding of Violation also fails to
identify the alleged facts that serve as the basis of the violation. However, from the testimony of
Ms. Locher and the code compliance narrative, Ex. 2, it is determined that the Finding of
Violation was limited to the "commercial trailer" identified in the Warning of Violation as
identified in Finding of Fact No. 2 herein.
4. New Trailer Subject to Finding of Violation. The trailer that was the subject to the
Warning of Violation is not the same trailer that was subject to the Finding of Violation. As
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previously noted, both the Warning of Violation and Finding of Violation don't identify any
specific dates of violation. However, the Warning of Violation can clearly only apply to
violations that occurred before its issuance — the City is obviously not sending out Warning
notices for future violations. Mr. Suciu testified during the hearing that he had replaced the
commercial trailer subject to the Warning of Violation with a boat trailer. It is determined from
Ex. 21 that this is in fact what occurred. Ex. 21 includes a vehicle registration certificate
showing that Mr. Suciu received license plates for a boat trailer in February, 2016 with VIN No.
2056. The Ex. 21 registration certificate is accompanied with an undated photograph that shows
that a trailer with VIN No. 2056 on the driveway of the subject property in the same location as
the trailer depicted in the Ex. 17 6/27/16 photograph submitted by the City. Although the Ex. 21
photograph only shows a portion of the trailer, it is clear from the surrounding cracks in the
pavement, fencing and proximate mail box that the trailer is located on the driveway of the
subject property in the same location as the Ex. 17 6/27/16 photograph. As far as can be
ascertained from the limited evidence in the record, it is also determined the boat trailer is not the
same as the commercial trailer depicted in the 2015 photographs submitted by the City. The 2015
photographs show the trailer as completely enclosed. Presumably a boat trailer would usually not
be enclosed, given the awkward dimensions of a typical boat. When apprised of Mr. Suciu's
position at hearing that he had replaced the commercial trailer with a boat trailer, City staff did
not contest this position and in fact went on to argue that the boat trailer also violated city code.
CONCLUSIONS OF LAW
1. Authority of Examiner: The Hearing Examiner has the authority and jurisdiction to
review code violation as provided in RMC 1-3-2.
2. Applicable Criteria: The merits of this appeal do not need to be reached since the case
must be dismissed for failure to comply with the City's procedural requirements for first issuing
a Warning of Violation. Applicable provisions governing the Warning of Violation process are
quoted below in italics and applied through corresponding conclusions of law.
RMC 1-3-1(B)(9): "Violation" is a location,property, structure or condition that is inconsistent
with the intent of this Code and/or endangers the health, sanitation or safety of the residents,
neighborhood or community. Each day that a violation exists shall constitute a separate
violation subject to separate costs and/or penalties, though multiple violations at one location or
by a Violator should be heard jointly for administrative and fiscal economy.
RMC 1-3-2(B)(5): "Finding of Violation" means that after issuing a Warning of Violation, the
CCI or other authorized personnel has found that the condition or violation still exists and that a
Violator has been found to have committed a RMC civil code violation. (emphasis added)
RMC 1-3-2(E): Finding of Violation: When a CCI finds an RMC civil code violation, the CCI
shall provide the Violator(s) with a Finding of Violation.
1. When a CCI finds an RMC civil code violation, the CCI shall provide the Violator(s)
with a Warning of Violation.
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2. If that Warning of Violation does not result in a correction of a violation by
immediate voluntary compliance, or compliance pursuant to a voluntary correction
agreement, the CCI shall provide the Violator(s) with a Finding of Violation.
3. As clearly outlined in the code provisions quoted above, a Warning of Violation is
required prior to the issuance of a Finding of Violation. The only way that the City's
enforcement process for this appeal can be harmonized with the requirements quoted above is if
the violation subject to the City's Ex. 13 Warning of Violation can be considered subject to the
City's Ex. 18 Finding of Violation as well. Arguably, even though two different trailers are
involved as determined in Finding of Fact No. 4, they are the same violation because they
involve the same code section. From a due process standpoint, this would be an appropriate
interpretation because once the Appellant is put on notice that outside parking of commercial
vehicles violates RMC 4-4-090(4), it is entirely fair to issue Findings of Violation without prior
Warnings of Violation for the same type of violation in the future. However, such an
interpretation is not consistent with the wording of the provisions. Most notably, RMC 1-3-
2(B)(5) provides that a Finding of Violation may only be issued if the condition or violation
identified in the Warning of Violation "still" exists. Use of the word "still" means that the
commercial trailer located on the property must "still" be on the property once Finding of
Violation is issued. The violation "still" remaining does not mean that the commercial trailer
was removed at some point, the driveway was empty for a few minutes, hours, days or weeks
and then a boat trailer was put in its place.
Even without the "still" language, a code enforcement defendant could very reasonably conclude
that the City's code enforcement process is designed to provide a defendant an opportunity to
correct every separate violation alleged by the City prior to the issuance of a Finding of
Violation. RMC 1-3-2(E) only authorizes the issuance of a Finding of Violation if a Warning of
Violation hasn't resulted in compliance. There is nothing in the Chapter 1-3 RMC that suggests
that once a Warning of Violation has been issued for a certain type of violation that the City can
issue Findings of Violation for all future similar types of violation without a prior Warning of
Violation and accompanying opportunity to correct the violation. Without clear notice in the
code that Warnings of Violations could be dispensed with in this manner, it is unlikely that a
court would uphold such an interpretation in a judicial appeal.
DECISION
The appeal is sustained. The Finding of Violation for FOV#: 15-000562 is overturned and no
fines are due and owing.
Decision issued September 23, 2016.
Phi A.Olbrechts
Hearing Examiner
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NOTICE OF RIGHT TO APPEAL AND RECONSIDERATION
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.
Reconsideration. A request for reconsideration may be filed with the Renton City Clerk's Office
if done so within 14 calendar days of the issuance of this decision. All requests for
reconsideration must be based upon the evidence admitted into the administrative record.
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