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HomeMy WebLinkAbout04-25-2001 Legal Opinion - Code Enforcement Issues File Matter:BROWN, WARD, SALZMAN & WEISS, P.A. ATTORNEYS AT LAW Usher L. Brown' John H. Ward' Gary S. Salzman° Jeffrey S. Weiss Suzanne D'Agresta Anthony A. Garganese° Scott D, Danahy James G. Vickaryous Alfred Truesdell Arthur R. "Randy" Brown, Jr. Brett A. Marlowe Jeffrey P. Buak Kristine R. Kutz Joseph G. Colombo Joanne Reed Day ' Board Certified Civil Trial Lawyer ° Board Certified Business Litigation Lawyer ° Board Certified City, County & Local Government Law April 25, 2001 Jimmette Cook, Code Enforcement Manager City of Winter Springs 1126 East State Road 434 Winter Springs, Florida 32708 Re: Legal Opinion - Code Enforcement Issues File Matter: City of Winter Springs - General File Number: 1193 Dear Jimmette: Two Landmark Center 225 East Robinson Street, Suite 660 Post Office Box 2873 Orlando, FL 32802-2873 (407)425-9566 (407) 425-9596 FAX Website: www.orlandolaw.net ibuak c ,orlandolaw net Cocoa, FL: 866-425-9566 Please allow this correspondence to serve as a follow-up to the questions and issues raised at the March 2001 meeting of the Code Enforcement Board. Specifically you requested legal opinions of the following matters: In cases where the owner of property is a landlord, the premise is rented, and a violation of the City Code is occurring upon the property, is the violator the tenant, the owner, or both? The answer depends upon the specific City Code provisions. For instance; Jimmette Cook, Code Enforcement Manager City of Winter Springs April 25, 2001 Page 2 (A) Where a vehicle has been determined to be derelict, disabled or abandoned (See § 12- 53, City Code) the Code provides that no person in charge or in control of any property within the City, whether owner, tenant, occupant, etc... shall allow such vehicles to be placed or remain upon such property. Therefore, the property owner and tenant would be in violation. (B) Where there is excessive accumulation or untended growth of weeds, undergrowth or other dead, or living plant life; or stagnant water, rubbish, garbage, etc... it is the duty of the owner of the property to reasonably regulate and :ffectivcly control such growth or accumulation. (See § 13-2 (d), City Code). (C) Where there is a violation of the Building Code, the Code provides that any person who shall violate the same shall be guilty of a violation of this Code (See §6-4, City Code). Therefore, if a lessee, who has the authority of the owner to perform work upon the premises, does so in violation of the Code, that violation will be attributable to the lessee. However, should the violation continue in existence, then the owner of the property would be an appropriate violator as well. Where staff chooses to bring a Code Enforcement action before the Board, it will be appropriate in most cases to find both the tenant and property owner to be in violation of the Code. This is due to the fact that the tenant has physical control of the property and is more than likely the cause for the violation, however, the Code generally holds the property owner responsible as well for the maintenance and conditions of the property. May the Code Enforcement Board place liens upon personal property of the violators, such as a lien upon a vehicle parked in violation of the Code? Yes, but. Any fine which is imposed by the Code Enforcement Board may be recorded in the public records and shall constitute a lien upon the land on which the violation exists and any other real or personal property owned by the violator. If the violator does not own the land, then the City could look to collect the fine by filing a law suit to enforce the fine as a money judgment, which would entitle the City to obtain a levy upon personal property, such as unencumbered automobiles, clothing, electronic equipment etc. The violator, however, will be entitled to claim statutory exemptions from a levy therefore, it could be very difficult and costly for the City to proceed in this manner. May a Code Enforcement Officer for the City go upon property, with the direction of the Code Enforcement Board, but without an inspection warrant issued by the Court? Yes. Where a nuisance or hazardous condition exists upon property but is not of such a nature that it needs immediate governmental action to abate a serious or continuing danger to the Jimmette Cook, Code Enforcement Manager City of Winter Springs April 25, 2001 Page 3 public or occupants, including attractive nuisance cases, the City shall follow the following procedures: (A.) Give notice to the property owner, which may be combined with a notice of violation and notice of hearing before the Code Enforcement Board, stating the specific violations and that the City intends to seek an order from the Code Enforcement Board for City work or contracted work to repair or secure the property. The notice must also indicate that any costs associated with the work performed will be charged as a lien against the property. (B.) If the owner fails to perform the work necessary by the time set for hearing before the Code Enforcement Board, the Code Officer shall submit proof that the condition continues and the danger to the public. The Code Enforcement Board may render an order requiring the City to perform such work as is necessary to secure the property or to make necessary repairs. Does an inspection warrant give Code Enforcement staff the authority to enter a residence to check for Code violations? A municipal code inspector is without authority to enter onto any private, commercial or residential property to assure compliance with or to enforce the various technical codes of a municipality or to conduct any administrative inspections or searches without the consent of the owner or the operator or occupant of such premises or without a duly issued search or administrative inspection warrant. Inspection warrants are provided for by Florida Statute. (See §933.20-933.30, Florida Statutes). An inspection warrant means an order in writing, in the name of the people, signed by a person competent to issue search warrants pursuant to §933.01, and directed to a state or local official, commanding him or her to conduct an inspection required or authorized by state or local law or rule relating to municipal or county building, fire, safety, environmental, animal control, land use, plumbing, electrical, health, minimum housing or zoning standards. (§93 3.20, F.S.) Owner -occupied family residences are exempt from the provisions §933.20 et seq. (emphasis added) Therefore, with the exception of owner - occupied residence, a municipal code inspector must have the consent of the owner/operator/occupant or a duly issued inspection warrant to enter the private, commercial or residential property of another to assure compliance with the city's codes. In the case of owner - occupied residence the inspector must have the permission of the owner or a search warrant issued by the court. It is also important to note that any inspection warrant issued will speak very specifically to the duration for which the warrant is valid and as to what may be inspected. The legislature was apparently very concerned with the potential for misuse of this authority. If the person seeking the Jimmette Cook, Code Enforcement Manager City of Winter Springs April 25, 2001 Page 4 warrant is found to have done so maliciously or for purposes not provided within the act they can be found guilty of a misdemeanor. Likewise the inspector may not be used as a confidential informer or testify as a witness as a predicate for the issuance of a criminal search warrant or for probable cause to search any dwelling. If you have any questions, please do not hesitate to ask. Veit' truly yours, PP.Buak J cc: Anthony Garganese, City Attorney F:\DOCS\City of Winter Springs\Code Enf6rcement\Cook001.kj