HomeMy WebLinkAbout1987 01 20 Regular
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DEP ART~IENT OF LEGA T.. AI"'I~'AIRS
OFFICE OF THE A TTORNEY GENERAL
THE CAPITOL
TALLAHASSEE. FLORIDA 32301
JIM SMITH
Att:maev General
:;~;'te of Florida
February 27, 1985
Mr. Harold M. Knowles
Board Counsel
Municipal Code Enforcement Board
528 E. Park Avenue
Tallahassee, Florida 32301
85-17
Re: LOCAL GOVE&~NT CODE ENFORCEMENT BOARDS
ACT--~ruNICIPALITIES--refusal by board to
extinguish lien when fine has been paid
but property remains in noncompliance;
levy of fine by board when property
brought into compliance prior to hearing
before board; imposition of fine by
board based on finding of violation be-
fore board has ordered compliance or
before compliance period has expired;
unauthorized. Ch. 162, F.S.
Dear Mr. Knowles:
This is in response to your request for an Attorney General's
Opinion on substantially the following questions:
1. WHETHER A MUNICIPAL CODE ENFORCE-
MENT BOARD MAY REFUSE TO EXTINGUISH A
LIEN AGAINST PROPERTY CITED AND FINED
FOR A VIOLATION OF A MUNICIPAL ORDINANCE
WHERE THE FINE IHPOSED BY THE BOARD HAS
BEEN PAID BUT THE PROPERTY REMAINS IN
NONCOMPLIANCE?
2. WHETHER A HUNICIPAL CODE ENFORCEHENT
BOARD MAY LEVY A FINE AGAINST A PERSON
WHO IS CITED BY A MUNICIPALITY FOR A CODE
VIOLATION BUT ~n10 BRINGS THE PROPERTY
INTO COMPLIANCE BEFORE THE CASE IS PRE-
SENTED TO THE BOARD?
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ENFORCfUiENT BOARD
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Mr. Harold M. Knowles
Page Two
85-17
3. WHETHER A MUNICIPAL COD~ EHFORCEMENT
BOARD IS AUTHORIZED TO IMPOSE AN INITIAL
FINE ON A VIOLATOR BASED SOLELY ON ITS
FINDING THAT A VIOLATION PAS OCCURRED AND
BEFORE THE BOARD HAS ACTUALLY ORDERED COM-
PLIANCE OR BEFORE THE COMPLIANCE PERIOD
HAS EXPIRED?
Your questions are answered in the negative for the following
reasons.
The expressed intent of the "Local Government Code Enforce-
ment Boards Act," Ch. 162, F.S., is to promote, protect and
improve the health, safety and welfare of the citizens of
this state by authorizing the creation of administrative
boards to provide an equitable, expeditious, effective, and
inexpensive method of enforcing county and municipal
technical codes. See, ~~162.01 and 162.02, F.S. Pursuant
to ~162.03(1), F.S~each county or municipality may, at its
option, create or abolish by ordinance such a code enforce-
ment board as provided in Ch. 162, F.S.
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The enactment of Ch. 162, F.S., creating adQinistrative
enforcement procedures and authorizing the imposition of
administrative fines by local governmental bodies was
necessitated by the provisions of ~l, Art. V, and ~18, Art.
I, State Const., which state that commissions established
by law or administrative officers or bodies may be granted
quasi-judicial power in matters connected with the functions
of their offices, and that no administrative agency shall
impose a sentence of imprisonment, nor shall it i~ose any
other enalt exce t as rovided b law. See, AGO 84-55
an authorities cite therein. ---
The powers of a local government code enforcement board are
described by ,162.08, F.S., which states that such board
shall have the power to:
(1) Adopt rules for the conduct of
its hearings.
(2) Subpoena alleged violators and
witnesses to its hearings. Subpoenas
may be served by the sheriff of the
county or. police department of the
municipality.
(3) Subpoena evidence.
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Mr. Harold M. Knowles
Page Three
85-17
(4) Take testimony under oath.
(5) Issue orders having the force of
law to command whatever steps are
necessary to bring a violation into
compliance.
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And see, ~162.07(4), F.S., which provides that at the con-
clusion of an enforcement board hearing the board shall
issue findings of fact and shall "issue an order affording
the proper relief consistent with ~o...,ers ~ranted herein."
(e.s.) It is the general rule wit regar to aJministrative
officers or agencies that they possess no inherent power and
may exercise only such authority as is expressly or by
necessary i~plication conferred by law. S~e generally, 67
C.J.S. Officers ~9l90, 192. ~ee,~., Lang v. Walker, 35
So. 78, 80 (Fla. 1903); Gessner v. Del-Air Corporation, 17
So.2d 522 (Fla. 1944). And see, Molwin Inv. Co. v. Turner,
167 So. 33 (Fla. 1936) (an express power duly conferred may
include implied authority to use means necessary to make the
express power effective, but such implied authority may not
warrant the exercise of a substantive power not conferred).
In addition. any reasonable doubt~5- tu the lawful existence
of a particular power sought t;:o~_bJ~ ~x.ercised by an adminis-
trative a enc or officer must be resolved a ainst the
exercise thereof. , State ex reI. Greenberg v. Flori a State
Board of Dentistry, 297 So~2a-02a (1 D.C.A. Fla., 1974),
ceit. dismissed, 300 So.2d 900 (Fla. 1974); City of Cape
Coral v. GAC Utilities, Inc., of Florida, 281 So.2d 493
(Fla. 1973).
In AGO 84-55 this office was asked to consider whether a
municipality that has established a local government code
enforcement board could require by ordinance that the code
enforcement board impose an administrative charge or fee on
individuals, businesses or other entities which are found
guilty of a violation of one or more of the municipality's
technical codes. As I stated in that opinion, 9162.03, F.S.,
gives local governing bodies the option of creating or
abolishing such code enforcement boards by ordinance as
provided in Ch. 162, F.S., but does not authorize local
governing bodies to regulate such boards or their nembers
except as provided in 9~l62.03 and 162.05, F.S. Although
9162.13,F.S., permits a local governing body to enforce
its codes by means other than those prescribed in ~~162.01 _
162.12, F.S., no provision of Ch. 162, F.S., delegates any
power to local governments or their governing bodies which.
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Mr. Harold M. Knowles
Page Four
85-17
have created a code enforcement board pursuant to.Ch: 162
to enact any legislation to modify or deviate from the pro-
visions of Ch. l62,F_S., or to confer any power or impose
any duty or requirement upon the code enforcement boards,
their members, or the code inspectors. The duties, functions
and powers of the code enforcement boards are set forth in
and derived from ~~162.07 - 162.09, F.S., and the local
governing body is granted no power to place any additional
requirements or impose any additional duties on such boards.
As I stated in AGO 84-55 and reiterate here, I cannot say
th;tt municipalities cierive any rower under ~2 (b), Art. VIII,
State Const., or ~166.02l, F.S., to regulate Qunicipal code
enforcement boards or impose any duties or requirements on
such boards or to otherwise regulate the statutorily pre-
scribed procedures of such boards.
Thus, Ch. 162, F.S., represents a delegation of the power of
the Legislature to create a local government code enforce-
ment board as an enforcement mechanism and gives the governing
bodies of municipalities and counties the option of creating
or abolishing by ordinance such boards which have the powers
and duties s~t forth in that chapter. 'g~j;L._lQ_caL..gQYe:1:'Jling
bo cho ses to utilize this enforceme me nism and the
proce ures---s ~:..L-.!t is bourid~
~~~ . 'ons of this chapter regarding efffOrcement~
procedures and en orcement oar s. ap er , F. ., does
not constitute a deIegat10n to ~ocal governmental bodies of
the Legislature's exclusive power to fix or provide for
administrative penalties or the costs of prosecution of
legislatively-prescribed enforcement procedures or the
collection of such penalties or costs. Thus, a local govern-,
mental entity or its governing body derives no delegated .
authority from eh. 162, F. S., to enforce its technical I!
codes, in any manner other than that provided in eh. 162. _'
Section 162.09, F.S., makes provision for administrative
fines and liens and states'as follows:
The enforcement board, upon notification
by the code inspector that a previous
order of the enforcement board has not
been complied with by the set time, may
order the violator to pay a fine not to
exceed $250 for each day the violation
continues past the date set for compliance.
A certified copy of an order imposing a
fine may be recorded in the public records
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85-17
and thereafter shall constitute a lien
against the land on which the violation
exists or, if the violator does not own
the land, upon any other real or personal
property owned by the violator; and it may
be enforced in the same manner as a court
judgment by the sheriffs of this state,
including levy against the personal property,
but shall not be deemed to be a court judg-
ment except for enforcement purposes. After
1 year from the filing of any such lien which
remains unpaid, the enforcement board may
authorize the local governing body attorney
to foreclose on the lien.
And see, ~162.l0, F.S., regarding the duration of liens
ImPosed by such boards. The lien provided for in this
section secures and is the method of enforcing the fine
imposed for noncompliance with a previous order of the en-
forcement board. I am not aware of, nor have you brought
to my attention, any provision of Ch. 162, F.S., authorizing
a code enforcement board to refuse to extinguish a lien
against property which has been cited and fined for a vio-
lation of a municipal ordinance when the fine i~posed by
the board has been paid but the property remains in noncom-
pliance. Nor does Ch. 162, F.S., provide for or authorize
a code enforcement board to levy a fine against a person
who has been cited for a code violation but who brings the
property into compliance before the case is presented to
the board. Finally, no rovision of Ch. 162 empowers the
board to levy an ~n~t~a ~ne e ore como ~ance ~s or ere
or before the per~od set for compliance has expired.
Therefore, unless and until judicially or legislatively
determined otherwise, it is my opinion that a municipal
code enforcement board is .not authorized to refuse to
extinguish a lien against property cited and fined for a
violation of a municipal ordinance where the fine imposed
by the board has been paid but the property remains in
noncompliance. Nor may a municipal code enforcement board
levy a fine against a person who is cited by a municipality
for a code violation but who brings the property into
compliance before the case is presented to the board.
Finall , a munici al code enforcement board ossesses no
authority to ~mpose an ~n~t~a ~ne on a v~o ator ase
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Mr. HaroldM. Knowles
Page Six
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before the
compliance
Prepared by: I
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Gerry Hammond.
Assistant Attorney General
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85-17
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occurred an
iance or th~
GENERAL
CASEN .,.. .
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VIOLATION
FROM: Nov. 1.1986
TO: Dec. 31. 1986
SECTION
86-309-0022
8~0023
86~0026
86-309-0027
86-309-0028
86-309-0035
86-309-0036
86-309-0039
,
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I 86-309-0062
86-313-0001
86-313-0062
86-316-0029
I 86-316-0030
86-316-0032
86-e-0032
86-317-0033
86-317-0037
86-322-0015
86-322-0032
86-324-0010
86-324-0011
86-324-0012
86-324-0013
86-327-0016
86-327-0024
86-327-0025
86-3'9-0013
86'9-0014
Di sabl e Vehi cle
Disable Vehicle
Disable Vehicle
Disable Vehicle
Disable Vehicle
Disable Vehicle
Disable Vehicle
Disable Vehicle
Unkept Property
Stagnant Pool
Como Veh. Prk. Res. Area
Barking Dog
Opo Business WIO license
Ope Business WIO license
Ope Business WIO license
More Than 2 Adult Dogs
Animals @ large
Unkept Property
No Bld'g. Permit (fence)
Alarm Connect To P.O.
Boat Improperly Parked
Boat Improperly Parked
Boat Improperly Parked
Excess 23 Feet
Improperly Parked
Veh. Parked Res. Area Como Veh. Moved
isabled Vehicle
isabled Vehicle
isabled Vehicle
Vehicle removed
Vehicle removed
Vehicle removed
Vehicle removed
Vehicle removed
Vehicle removed
Vehicle removed
Vehicle removed
Property Cleaned Up
Code Board
Vehicle Moved
No Further Complaints
Obtained Business license
Obtained Business license
Obtained Business license
Removed One Dog
Animals Secured
Property Cleaned Up
Permit Obtained
Alarm Disconnected
Boat Moved
Boat Moved
Boat Moved
Boat Moved
Boat Moved
Vehicle Removed
Vehicle Removed
Vehicle Removed
44.85
44.85
44.85
44.85
44.85
44.85
44.85
44.85
7.1(a)
5.149(c)
44.81(1a)
4.15
8.20
8.20
8.20
44.79
4.13(a)
7.l(a)
5.122
9.32
44.74
44.74
44.74
44.74
1l4.74
44.81
44 . 85
44.85
44085
CASEI,
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FROM:
VIOLATION
Nov. 1. 1986
TO: Dec. 31. 1986
SECTION
86-329-0016
~-0017
8~~-0020
86-330-0001
86-333-0011
86-338-0012
86-338-0026
86-339-0010
86-339-0038
86-340-0011
86-342-0021
86-342-0036
86-344-0062
86-347-0032
86.-0021
86-349-0022
86-349-0023
86-349-0028
86-349-0030
86-350-0037
86-350-0040
86-352-0052
86-352-0054
86-353-0020
86-351-0051
86-358-0014
86-363-0031
86..-0032
Disabled Vehicle Vehicle Removed
Disabled Vehicle Vehicle Removed
Disabled Vehicle Vehicle Removed
Pool Gate Unlocked/Open Gate Closed/locked
Dog @ large Dog Secured
Com. Veh. Prk. Res. Area Com. Veh. Removed
Disabled Vehicle Vehicle Removed
Animal @ large Animal Secured
No Bld'g. Permit Permit Issued
Com. Veh. Prk. Res. Area Com. Veh. Removed
.
Disabled Vehicle Vehicle Removed
Noise Nuisance Noise Ceased
Unkept Property Property Cleaned Up
Chickens Res. Area Chickens Removed
Junk Vehicle Vehicle Removed
Junk Vehicle Vehicle Removed
Junk Vehicle Vehicle Removed
RoVo Parked Reso Area R.V. Removed
R.Vo Parked Res. Area R.V. Removed
Junk Vehicle Vehicle Removed
Unkept Property Property Cleaned Up
Junk Vehicle Vehicle Removed
Junk Vehicle Vehicle Removed
More Than 2 Adult Dogs One Oog Removed
Barking Dog No Further Complaints
Barking Dog No Further Complaints
Com. Veh. Prk. Res. Area Com. Veh. Removed
Com. Veh. Prk. Res. Area Com. Veh. Removed
44.85
44.85
44.85
5.128
4.13(a)
44.81
44.85
4.13(a)
5.122
44.81 (la)
44.85
9.14
7.2(a)
44. 17
44.85
44.85
44.85
44.81
44.81
44.85
7.2(a)
44.85
44085
. 44 . 7 9
4.15
4.15
44.81
44.81
CASE-# .
VIOLATION
FROM: Nav. I, 1986
SECTION
TO: De c . 31, 1986
lilt
PENDING THIRTY DAYS
NONE
PENDING SIXTY DAYS
NONE
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NOTICE TO APPEAR AT HEARING
NAME Olive P. Wa~ner
ADDRES~nR 55 Altamontp Spring~. Fl.
YOU ARE HEREBY SUMMONED TO APPEAR AT A HEARING OF THE CODE
ENFORCEMENT BOARD OF THE CITY OF WINTER SPRINGS, FLORIDA, LOCATED AT CITY
HALL, 1126 EAST S. R. 434, WINTER SPRINGS 32708.
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YOU ARE NOTIFIED TO APPEAR AT;
TIME 7 : 15 PM
DATE January 20, 1987
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AT THE AFORESAID TIME AND PLACE THE BOARD WILL H~ EVIDENCE TO
DETERMINE WHETHER YOU ARE IN VIOLATION OF SECTION 5-149{c) OF THE
MUNICIPAL CODE. YOU WILL.~E AFFORDED THE OPPORTUNITY TO PRESENT EVIDENCE
THAT YOU ARE NOT IN VIOLATION OF THE AFORESAID SECTION OF THE CODE, AND YOU
MAY BE REPRESENTED BY COUNSEL OF YOUR CHOICE. I
YOUR FAILURE TO APPEAR CAN RESULT IN JUDGEMENT RENDERED AGAINST
YOU.
This is in reference to the
city of Winter Springs, Fl.
I CERTIFY A COpy OF THIS DOCUMENT WAS SERVED BY
)( CERTIFIED MAlL THIS /.1- DAY OF
HAND DELIVERY
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ORDER OF THE CODE ENFORCMENT BOARD - CITY OF WINTER SPRINGS
IN RE: OLIVE P. WAGNER
The Code Enforcement Board of the City of Winter Springs, Florida sat in Hearing
on January 20, 1987, in the matter of Olive P. Wagner to determine whether she is
in violation of Sec. 5-149(c) of the Code of Winter Springs, Florida. Upon hearing
all evidence on the matter, the Board arrived at the following:
FINDINGS OF FACT AND LAW
1. OLIVE P. WAGNER is in violation of Sec. 5-149(c).
After arr1v1ng at the foregoing Findings of Fact and Law, the Board enters an Order
as follows:
ORDER OF THE BOARD
1. OLIVE P. WAGNER comes into compliance with SEc.5-149(c). On service
of the Order of the Board she will be fined $500.00. She will have a three day
grace period to clean up the pool before there is an additional $100.00 per day fine
assessed until she comes into compliance.
Now then the Code Enforceent Board of the City of Winter Springs, Florida instructs
all enforcement procedures to be instituted to accomplish this order.
This
day of January, 1987.
JAME
CODE
CITY
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NOTICE OF VIOLATION
THE CITY OF WINTER SPRINGS CODE
86-287-0030-C6
NAME MIKE BARRETO
ADDRESS 214 Wade St Winter Springs
DATE January 5, 1987
CODE SECTION IN VIOLATION
44.85
CODE REQUIREMENTS
Vehicles must be currently registered and capable
of being driven .
FACTS OF VIOLATION
1966 VW BeatIe, VINf! 116233708, has no tag
CODE ENFORCEMENT BOARD INSPECTOR:
Officer Sonafelt
For further guidance to determine the procedure to comply with the code of the
City of Winter Springs, please contact Code InRpec.tor
at 1126 East S.R.434,Winter Springs, Fl. 327-1000 Monday - Friday 8:00 a.m. to
5:00 p. m.
Response: (To be filled in by Code Enforcement Officer) TO BE CORRECTED BY
1/12/87
OR APPEARANCE BEFORE THE CODE BOARD WILL BE REQUIRED AND
POSSIBLE FINES IMPOSED.
I certify a copy of this document was served by
Hand Delivery,
k
Certified Mail, this,j day of ~'~?<<4rv , 1987.
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. SENDER: Complete iterm 1 and 2 when addltlonal_Meesere desired. and complete Item. 3 and 4.
Put your add..... in the "REnJRN TO" aplICI on the nMIr11 .Ide. Failure to do thl. will prevent this
an:! from being returned to you. The..llt!!m [J!;IiRt f.. will Qrovlde YOU the name of the e!!!2!!
delivered to and the ~ of dllMAt\.'or addltlo..I fees th. a following services ere available. COnsult
poitm-.ter tof fees a~) for additional MrVIce(.) requnted.
1. 0 Show to whom dII~. ~. and addreaee'. add...... 2. 0 Restricted DeIiV9l'V.
3. Article Addreaed to: 4. A Ie '. bar
?1cke ,(fa ,-,,-efo
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5. Signature - Addressee
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Type of Service:'
Registered B Insured
ertified COD
Exprlll Mall
Alway. obtain .ignature of eddr..... or
8lIlInt and DATE DELIVERED.
8. Add......... Addrlll (ONL Y if
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DOMESTIC RETURN RECEIPT
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Case
H 8~-309-0062-C:r ~
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NOTICE OF VIOLATION
THE CITY OF WINTER SPRINGS CODE
Property located at:
NAME
Olive P. Wagner
ADDRESS P.O. Box 55 Altamonte Springs. Fl
55 S. Fairfax Ave
Winter Springs, Fl
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DATE 11-5-86
CODE SECTION IN VIOLATION r.hRprpr 7 And Chapter 5-149 (c)
CODE REQUIREMENTS
copy of ordinances attached
FACTS OF VIOLATION Grass and weeds overgrown, traFlh in yard.
Swimming pool black with a12ae growth.
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~DE ENFORCEMENT BOARD INSPECTOR:
>",,l;.,',r:: ;
B. Sonafelt
. For further guidance to determine the procedure to comply with the code of the
City of Winter Springs, please contact r.ndp Tn~~{"t-nr
at 1126 East S.R.434,Winter Springs, Fl. 327-1000 Monday - Friday 8:00 a.m. to
5:00 p. m.
Response: (To be filled in by Code Enforcement Officer) 'T'n be corrected gy
November 12. lqfHi or App~Rr.::ln{"p h~fnr~ t-h~ rn(Je ROi'rd uill
be required.
I certify a copy of this document was served by
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Hand Delivery,
By:
~~ day of pmJ.
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Certified Mail, this
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. SENDER: Complete items 1 end 2 when IIddltlonalservlcesare dellred, and compleht Items 3 and 4.
Put your address In the "RETURN TO" spece on the I1MII"Ie side. Failure to do this will prevent this
card fr being returned to you. ~'return rt!:eiPt fee will provide you the name of ~n
I t nd t of . For eddftfol'llll fHI the 10l10Wl'ng IiMCii are ~MUI~
or .) for -*fltlonall8l'VJc:ela) ~.
~MId..il"tl....h... 2. 0
4. Article Number
P 336 556 615
Type of ServIce:.
'~. R....:~8 ." , iMuNC('
Certified COD
Express Mall
DOMESTIC RETURN RECEIPT
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