HomeMy WebLinkAbout1B, Administrative FinesEN HILLS
MEMORANDUM
DATE: October 19, 2009 Item 1.B
TO: Honorable Mayor & City Council
FROM: James Lehnhoff, Community Development Director
Meagan Beekman, City Planner
SUBJECT: Administrative Fines
Requested Action
Clarify the City Council's goals and priorities for an administrative fine program, review the
current State Statutes regarding this issue, discuss strengths and weaknesses, ask questions, and
provide direction and priority on a course of action.
Intrnrl»etinn
In October 2008, the City Council directed staff to begin researching rental regulation and
administrative fining programs for the 2009 work plan. This project was primarily initiated due
to increasing concern over property maintenance issues, code enforcement issues, the conversion
of owner occupied housing to rental housing, and college student occupied rental housing. At
the time the City Council created a priority list of action items associated with what would
become known as the Community Enhancement Program. Throughout 2009, Staff updated the
abatement code, worked on updating the code enforcement policy for the City, amending the
City Code to clarify enforcement, and focusing on implementing a rental registration program.
In June of 2009, the City Council adopted a rental registration program that is currently
underway.
The purpose of this memo is to review a possible administrative fine program. At the end of
their 2009 session the State Legislature passed new statutes regarding the use of administrative
fines for traffic related offenses within a municipality. Those changes to State law have created
a renewed interest among many communities to examine their own administrative fine programs.
The City of Arden Hills is currently working with the other communities that contract for police
services with Ramsey County to review options for a traffic offense administrative fine program.
At this time Staff is asking the City Council to discuss and provide feedback on an administrative
fine program for violations of the Code other than those related to traffic offenses.
City of Arden Hills
City Council Work Session for October 19, 2009
I Wetro-inet lardenhills lAdmin I Council Ugendas & Packet Information 12009110-19-09 Worksession l Packet Information 110-19-09 -Work Session
- Admin Fines. doc
Page 1 of 5
Setting Goals and Priorities
Before continuing, it is important to determine what the City Council would like to get out of an
administrative fine program. The goals of the program will help dictate the type of program that
might be implemented by the City. The processes for implementing administrative fines
described in this memo have different strengths, weaknesses, benefits, and costs. Determining
which tools will work best will depend on the goals and priorities of the City. What are the
City's goals for an administrative fine program? What results are desired?
Code Violation Trends
To help put the administrative fine program into context, a review of code violation trends is
provided. At the end of the first half of 2009, there were a total of 196 registered complaints.
The majority of the complaints had to do with improper parking of vehicles. Other complaints
had to do with objectionable weed and grass growth and property maintenance issues. Staff is
in the process of preparing the full third quarter code enforcement report. By comparison there
were a total of 167 registered complaints by this same time last year.
In 2008 there were a total of 491 code enforcement cases involving 509 issues. The majority of
those pending cases were unresolved parking of vehicles, recreational vehicle (RV) storage
issues, and situations that require continued monitoring. In 2007 there were a total of 191 code
enforcement cases involving 255 issues. In 2006, there were a total of 325 issues of which some
properties had more than one issue. The majority of those code enforcement cases are for
parking issues (too many vehicles and/or parking on lawns), garbage container location,
drainage/erosion control, animal control, and unmaintained lawns.
An estimated 80 percent of complaints are resolved upon first contact with the property. Most of
the remaining 20 percent are resolved with a phone call or second notice. For those properties
that require a second or third notice, it is not uncommon for some properties to fall back out of
compliance. However some properties refuse to comply or stay in compliance, which can result
in a civil or criminal citation. Since the City's goal is to obtain compliance, staff works
diligently with properties before pursuing the civil or criminal citation process, which can take
six to twelve months and legal fees to obtain compliance during which time the property remains
out of compliance
Existing Code Enforcement Resources
The City currently has a quarter time code enforcement officer. The remaining three quarters of
that position is dedicated to residential building reviews and inspections. Due to increasing code
enforcement demands, the amount of time used for code enforcement in this position has been
increasing, which decreases the amount of time available for required inspections. In addition to
the Code Enforcement Officer, the Building Official, City Planner, Community Development
Director, and other administrative staff contribute to code enforcement efforts as necessary.
City of Arden Hills
City Council Work Session for October 19, 2009
IlMetro-inetlardenhillslAdminl CouncilUgendas & Packet In00rmation12009110-19-09 WorksessionlPacket Information110-19-09 -Work Session
- Admin Fines.doc
Page 2 of 5
As part of the City's contract, the Ramsey County Sheriff is also responsible for enforcing the
City's regulations. Their services are particularly needed after regular business hours and on
weekends. Additional conversations with the Sheriffs office may be needed to ensure that the
City's regulations are being enforced, and residents need to be educated to know that they are
able to call Ramsey County during non -business hours.
Staff is in the process of contacting other cities of similar size to assess their code enforcement
staff resources. Each of the cities adjacent to Arden Hills has a full-time code enforcement
officer.
Complaint and Enforcement Policy
In May of 2009, the City adopted an updated code compliance policy. Staff had been following
a procedure prior to the update; however, a more formal policy provides a better foundation for
staff. The purpose of the update was to provide a standard procedure and a clearer process to
residents. The policy does allow for flexibility so that Staff can work toward the best outcome
depending on the unique circumstances of a given situation. The policy is included in
Attachment A.
Administrative Fines
The administrative fining process has grown in both popularity and in controversy in recent
years. Page 5 of the City Attorney's July 31, 2008, letter includes the detailed legal background
for this tool (Attachment B). Recent action at the State Legislature has permitted cities to levy
administrative fines for traffic related offense. While State Statue remains largely silent on
administrative fines for other types of City Code violations, it is the opinion of the City Attorney,
and the league of Minnesota Cities, the a city is within its rights to enforce its own Code, and the
use of administrative fines is a reasonable way of doing that.
Although definitive research on the effectiveness of administrative fines is not available, Staff
spoke with other cities about their programs. Some cities use administrative fines extensively
and issue a fine along with the first notice for a violation, which is the case in Coon Rapids
where they have a much larger code enforcement load. Other cities that were contacted use
administrative fines more sparingly or not at all, even when the option is available in their Code.
According to the cities that were contacted that use administrative fines, few properties received
the actual fine because the fine would often be waived if the property was brought into
compliance within a set time period. Still other cities have chosen not to use administrative fines
at all citing the additional staff time required to implement and operate the program compared
with lack of proven effectiveness. It should be noted that the communities that use
administrative fines on a regular basis also have their own police force to issue them.
City of Arden Hills
City Council Work Session for October 19, 2009
IMetro-inetlardenhillsW dminl Council Wgendas & Packet Info rmation12009110-19-09 WorksessionlPacket Information110-19-09 -Work Session
- Admin Fines. doc
Page 3 of 5
As part of this program, a city must build in due process. After a fine is issued, the person
receiving the fine can appeal it to the hearing officer at City Hall. The hearing officer is
generally a third party chosen by the City, though in some cases it can be the city council. The
hearing officer reviews the violation and determines if the fine was warranted or should be
dismissed. There are not any statistics readily available on the number of fines that are appealed.
An important aspect to note of any administrative fine program is that it is a voluntary fine. This
means that should a property owner refuse to pay the fine, there is no way for the City to require
payment. Instead, the administrative fines are seen as an alternative to the lengthy and costly
legal citation process and meant to encourage conformance before a citation is issued. Most
communities issue administrative fines on the second or third letter that goes out to a property for
a violation. If the violation is corrected, the administrative fine is waived. If the violation is not
corrected, the city could begin the citation process. In cases where compliance is unattained, a
criminal or civil citation is often the only remaining tool. For certain public nuisance violations,
a city can abate the property and assess the cost of the abatement and any administrative costs
associated with it. A public nuisance includes such violations as excessive grass and weed
growth, and garbage piles, removal of snow and ice from sidewalks. Parking and sign violations
are not considered public nuisances and cannot be abated.
In order to use the administrative fine process, the City would need to adopt the necessary
regulations to the City Code and amend the fee schedule to include the fines for various
violations. Specific violations could also be listed with differing fines for each depending on the
severity of the nuisance. Most cities that we spoke with charged between $50 and $150 for the
first violation. Fines for subsequent violations increased from anywhere between 25 and 100
percent. The Code would also need to appoint a hearing officer to hear appeals to the
administrative fines.
Since the goal of administrative fines is to gain compliance, the program would not be a revenue
generator for a city, and would not pay for itself in terms of staff time and resources. This
process would require involvement from the City Administrator, Community Development
Director, City Planner, City Attorney, Building Official and Code Enforcement Officer. While
there is not a standard cost for setting up this type of program, a reasonable estimate is $2,500 to
$3,500 for the cost of staff and city attorney time. This process would also require a continual
dedication of staff time and resources without a guarantee of cost recovery.
Until an administrative fine policy is created, it is difficult to estimate the number of fines that
would be issued each year and the impact of ongoing costs; estimates gathered from other
communities suggest that the range might be ten to 20 fines issued in a given year, of those even
fewer are actually paid. Revenue is unlikely to meet or exceed the cost of the program but could
vary depending on the fine (e.g. the City of Roseville charges $100 per fine). Since an
administrative fine does not guarantee compliance, some fines would likely be converted to civil
or criminal citations. There could be savings if an administrative fine prompts compliance
City of Arden Hills
City Council Work Session for October 19, 2009
I (Metro-inetWrdenh ills lA dmin l Council Ugendas & Packet Information12009W-19-09 Worksessionftcket InformationW-19-09 -Work Session
- Admin Fines. doc
Page 4 of 5
before a citation is issued, though that savings is difficult to predict since the cost of a citation
can vary and relatively few citations are issued in any given year.
Excessive Consumption
Excessive consumption is another way to attempt to recover some of the costs taken up by
chronic public nuisance offenders. Roseville is currently looking at this as an option and New
Brighton currently uses a form of it. With excessive consumption, properties that are repeat
offenders, which require additional reinspections, or take up an excessive amount of staff time,
are billed for that time. The bill can be in the form of a flat rate for each inspection done, or an
actual calculation of the amount of staff time taken up by the property. Initial discussions with
the City of Roseville indicate that these bills, if unpaid, might be able to be assessed against a
property. Staff is exploring this option more with the City Attorney and the City of Roseville.
Recommendation
Despite the possible implementation of an administrative fine program some properties will
undoubtedly still have code violation issues. The primary goal of an administrative fine program
is to obtain compliance, which, despite the City's best efforts, can take time and diligence no
matter what tools are available.
While having an administrative fine program available as a tool for Staff might be useful in a
few situations, it is unlikely that such a program would have a broad or significant impact on the
City's code enforcement activities. Adopting such a program has benefits, provided that the
limitations of administrative fines are understood. The benefits of the program must also be
weighed against the cost of implementing and administering it. Based on Staff s research, it is
questionable if administrative fines would be an effective use of resources. Nevertheless,
administrative fines are a potential tool to the extent that they facilitate compliance with the
certain code violations and may reduce the need for civil or criminal citations.
Attachment.
A — Code Compliance Policy and Process
B — July 31, 2008, Letter from the City Attorney
C — Example Administrative Fine Code — City of North Oaks
City of Arden Hills
City Council Work Session for October 19, 2009
IlMetro-inetlardenhillsWdminl CouncilWgendas & Packet Information12009110-19-09 WorksessionlPacket Information110-19-09 -Work Session
- Admin Fines.doc
Page 5 of 5
Attachment A
Code Complaince Policy
October 19, 2009, City Council Work Session
City of Arden Hills
Code Compliance Policy
Policy Purpose: The City of Arden Hills seeks to protect the quality of life, property values,
aesthetics, and safety through consistent and timely enforcement of the Arden Hills City Code.
This code compliance policy is adopted to guide staff and designed to apply a standard procedure
to achieve code compliance while working to educate and provide a reasonable timeframe for
property owners and tenants to resolve noncompliance issues.
Submitting a Complaint: In order for the City to investigate a complaint, the following
information is required to be considered a completed complaint:
• Complete address of violation (or adjacent address if in the right-of-way).
• Description of violation.
• Name, address, and phone number of complainant (kept as confidential information).
• During regular business hours, the complaint can be submitted to City Hall by mail or by
phone at 651-792-7800. For on -street parking violations and any violation that occurs
during non -business hours, please contact the Ramsey County Sheriff non -emergency
line at 651-767-0640.
• People are strongly encouraged to contact City staff and/or the Ramsey County Sheriff
while the violation is occurring so that the violation can be witnessed.
City Code Compliance Process*:
1. Complaint. The completed complaint is submitted to the City.
2. Inspection. Staff visits the property to inspect the complaint, follow-up with
complainant to inform them of the compliance process, and initiate contact with the
property and tenants of the subject property. Staff will strive to complete this step within
two working days of receiving the completed complaint.
3. Notification.
a. City verified violation: For violations that are verified by a staff or sheriff
inspection, the property owner and tenant shall be informed of the violation, how
to resolve the violation, the applicable ordinance number(s), when the issue was
reported, any applicable educational materials, and instructions to resolve the
violation within seven days. Staff shall attempt to contact the property owner and
tenant by phone and shall send a letter with the required information. Proceed to
step four.
b. No City verified violation: For violations that have not been verified or witnessed
by City staff or the sheriff, the property owner and tenant may be informed of the
complaint, the applicable ordinance(s), and supplied with any applicable
educational materials by letter and/or phone. If the violation occurs and is
verified within 12 months of the initial report date, staff may proceed to step five
provided the property owner and tenant were informed of the initial complaint and
supplied with the applicable ordinance and educational materials.
\\Metro-inet.us\ardenhills\Planning\Community Development\Community Enhancement Program\Compliance Policy\051109 - AH code
compliance policy.doc
5/29/2009
4. Re -inspection. Staff re -inspects the property after seven days. If the violation is
resolved, the case will be closed. If the violation is not resolved, proceed to step five.
5. Final Notice. The property owner and tenant shall be informed of the violation, how to
resolve the violation, the applicable ordinance number(s), when the issue was reported,
and any applicable educational materials. The letter shall direct the violation to be
resolved within seven (7) days or 1) a citation may be issued, or 2) the abatement process
may be initiated, whichever is most applicable. Staff shall attempt to contact the property
owner and tenant by phone and shall send a letter with the required information.
6. City Action. If the violation remains unresolved after the seven (7) day time period, a
citation may be issued or the abatement process may be initiated, whichever is most
applicable.
7. Reoccurrence. If a substantially similar violation occurs on the same property within 24
months of a verified violation, the City may issue a citation or initiate the abatement
process initiated, whichever is most applicable, without the need for additional violation
notifications,
The City's primary goal is to obtain compliance. City staff shall apply this policy equitably;
however, unique situations may warrant flexibility if the result is a better and long lasting
solution.
*The Ramsey County Sheriff may issue tickets or citations outside of this code compliance
process.
Adopted: May 11, 2009
2
\\Metro-inet.us\ardenhills\Planning\Community Development\Community Enhancement Program\Compliance Policy\051109 - AH code
compliance policy.doc
5/29/2009
Attachment B
July 31, 2008, Letter from the City
Attorney
October 19, 2009, City Council Work Session
Warren E. Pelerson
Jerome P. Filla
Daniel Witt Frain
Clem A. Bergman
John Michael Miller
,Michael T. oberle
Steven H. Bruns
eve
Paul W. Fahning
Sonja R. Ortiz
Amy K. L. Schmidt
Ben 1, Rust
Jonathan R. Cuskey
fared M. Goerlitz
Noah Simon
Assistant City Administrator
City of Arden Hills
1245 West Highway 96
Arden Hills, Minnesota 55112
a
01 aq YAW
PROFESSIONAL AS S 0 C I A T 1 0 N
July 31, 2008
RE: Rental Licensing, Code Enforcement and Administrative Citations
Dear Noah:
Suite 800
55 East Fifth Street
St, Paul. MN 55101-1718
(651) 291-8955
1651) 228-1753 facsimile
www.pfb-pa.com
(651)290-6907
il U136PPt-pa.com
.VIA EMAIL
Recently, the City of Arden Hills has been considering whether to establish a licensing
ordinance for rental properties within the City. A citizens" task force met on two occasions
to discuss the merits of such an ordinance., and other alternatives. The task force has
made its recommendation to the Council.
As I understand the background of the discussion, there is some concern among the
Council and the community about on -going property issues, such as parking, property
maintenance, noise, nuisance conditions, and the like. As the task force debated the
issues, they also discussed pursuing stepped up enforcement of the City's applicable Code
provisions through the Building Official. This was relevant to the question of rental
licensing because such activity could provide a viable alternative to a rental licensing
ordinance. The task force also discussed the possibility of a rental registration ordinance,
and seemed interested in exploring alternatives to rental licensing or rental registration.
In addition to the implementation of a rental licensing ordinance,, or a rental registration as
a means of addressing on -going property concerns,, the City has a number of options
availablel, namely code enforcement, civil actions, abatement authority, hazardous building
provisions, and administrative fines. Each of these options is available for both rental and
owner -occupied properties. Each option is discussed below.
Code Enforcement 'By Notice and Citation.
The City's usual Code Enforcement process starts,when a property owner files a complaint
regarding the use or the maintenance of a neighbo . r's property. At this stage,, the identity of
the reporting property owner is confidential pursuant to the terms of the Minnesota Data
Practices Act. Upon the receipt of the complaint, the City usually undertakes the following:
'AL -SC AUNUTTED IN WiSCONSIN
July 31, 2008
Page 2
I- The na (Iff; inspects the offending property.
2. Where appropriate, the Bt,,___ I sends the offending property owner
a written notice which identifies the facts which support the complaint and
the sections of the City Code which are being violated. The Notice also
contains a compliance date.
3. A second inspecfionbccurs. If the property is in compliance, the City will
send a letter thanking the offending property owner for cooperating.
4. If the property owner is not in compliance within the required time, one or
two additional notices and inspections can occur.
When it becomes clear that the offending property owner cannot or will not
comply with the City's regulations, the Building Official prepares a criminal
citatiori and files it and supporting documents with the clerk of the Ramsey
County District Court. A copy is sent to our office. We have instructed the
Clerk of Court to require court appearances in connection with this type of
violation.
6. The Clerk of Court notifies the offending property owner to appear on a date
certain. The Building Official to inspect the property before the date of the
court appearance- At the first appearance,, the offending party can plead
guilty or not guilty. If a guilty plea is entered, the matter is resolved at that
time. If a not guilty plea is entered, the matter is scheduled for a pretrial at
a later date.
7. At the pretrial, the offending property owner has the same choices as he/she
did at the first court appearance. If the offending property owner continues
to plead not guilty, the matter is scheduled for a jury trial. All City Code
violations are misdemeanors unless specifically indicated otherwise in the
City Code. The maximum penalty for a misdemeanor is a fine of $1 1000 or
a jail sentence of 90 days or both. Since the offending property owner may
serve time in jail if convicted, the law allows the offending property owner to
have a jury trial.
8. From start to finish, the above process may take six (6) to nine (9) months
6
to complete, in the meantime, if the property continues to be in violation of
the City Code.
9. Criminal cases need to be proved beyond a reasonable doubt and, because
the defendant is the offending property owner and does not have to testify
against him/herself, discovery options are very limited. The issuance of a
July 31, 2008
Page 8
criminal citation results in the imposition of penalties and does not necessarily
resolve the underlying property maintenance issue. A person may choose to pay a
fine and/or serve some time in jail rather than clean up the property.
Code Enforcement by Notice and Civil Action
This Code enforcement method starts in the same way as the notice and criminal citation
process. However, during the initial notice phase, it may become clear that the violations are
of more serious nature and are ongoing. Therefore the city would not only want the problem
corrected, but it would like a court order to ensure that the problem doesn't reoccur. In regard
to civil enforcement process:
t . The city serves and files a Summons and Complaint.
2_ The offending property owner is required to fire an answer.
3. There is ample opportunity for discovery under the Rules of civil Procedure (i.e.
interrogatories, depositions, request for admissions, court ordered inspection of
the property).
4. In a civil case, it is usual for the court to require that the parties attempt to
,,mediate the issues before the case proceeds to trial.
5. The trial is usually to the court.
6. From start to finish, a civil case in the Ramsey county District Court can take six
(f) to twelve U2) months.
7. If the court finds in favor of the City, it could award the city its costs. The court
order could restrict future conduct. if there is a future violation of the court
order,, the city would simply petition the court to enforce its order.
Code Enforcement for Nuisance Abatements.
The City is authorized to define nuisances, abate nuisances, and to specially assess the cost of
abatement against the property on which the nuisance was located (Minn. Stat. 412.221,
subd. 23; 429.221, subd. 8 and city code chapter 6). The process for abating a nuisance is
as follows:
1. The Building Official notifies the property owner that a nuisance exists, identifies
the steps that must be taken to abate the nuisance, and indicates the time for
bringing the property into compliance.
July 31, 2008
Page 4
2. The notice is personally served or sent by certified mail to the property owner. if
the property is not occupied, the notice can be posted on the property.
3. If the nuisance is not abated by the property owner within the required time, the
City Administrator notifies the property owner that the matter will be reviewed
by the City Council at a specific meeting. Council will then consider the report
of the City staff and the comments of the property owner.
4. At the conclusion of the Council hearing, a decision is made by the City. If the
City Council determines that a nuisance exists, it approves the appropriate order
requiring that the nuisance be abated.
5. The City Council Abatement order can be appealed to the District Court, in
which case, the matter will be tried as other civil cases.
�. If a delay in the abatement of a nuisance will unreasonably endanger public
health, safety or welfare, the City can also order that the nuisance be summarily
abated.
7. The property owner is personally liable for the cost of the abatement and the
cost can be assessed against the property.
Code Enforcement or hazardous Building Removal.
The procedure for removing a hazardous building is as follows:
I. The Building Official makes a hazardous building determination.
2. The property owner is notified. if the property owner consents to the removal of
the building, the City abates the hazard and assesses the cost against the
property. if the property owner does not consent to a removal of the hazardous
building, the matter is presented the City Council with the staff's
recommendation. The property owner can appear and comment at the Council
meeting. The Council could then .adopt the appropriate order requiring the
removal of the hazardous building.
3. The City Council's order to remove the hazard is served on the property owner.
4. The property owner has twenty (20) days to file an answer with the Ramsey
County District Court. if an answer is not filed, the City proceeds to obtain a
summary judgment. If an answer is filed, the matter proceeds as other cases.
July 31., 2008
Page 5
Administrative Fines as an Alternative.
The issue of cities' authority to establish administrative fines for certain violations has been the
center of debate and controversy in Minnesota over the past several years. Some, including the
State Auditor, have concluded that cities do not have the authority to take such action in
certain areas of enforcement. At the same time, there has been great legislative effort over the
past several sessions for at least some clarity on the issue. Again in 2008, the Legislature
did not take any steps to clarify city authority to implement a scheme for administrative fines.
Accordingly, a city should proceed cautiously before passing such an ordinance, and consider
the following:
1. Authority.
As a general rule, cities have only the authority expressly granted to them in statute or
in a city charter, or necessarily implied by the express authority given to them. Mangold
Midwest Co. v. Village of Richfield, 143 N.w.2d 813, 819-20 (Minn. 1955). Except in two
specific circumstances, there is no express authority for a statutory city to impose
administrative penalties. The two specific circumstances are set out in (1) Minnesota Statutes
§ 461.12, subd. 3, which allows cities (or a licensing authority) to impose administrative
penalties for sale of tobacco to a minor; and in (2) 340A.415, which establishes an
administrative penalty for certain violations involving the sale of alcohol.
Otherwise, statutory cities generally rely on more general powers granted by the
legislature:
The council shall have the power to declare that the violation of any ordinance
shall be a penal offense and to prescribe penalties therefor. No such penalty
shall exceed a fine of $1,000 or imprisonment in a city or county jail for a
period of 90 days, or both, but in either case the costs of prosecution may be
added.
Minn.Stat. § 412.231 (emphasis added). Most cities interpret this section as either an
express grant of authority to establish administrative penalties, or at the very least, to be
authority "necessarily implied" in their general powers to do so. See also, State v. Robitshek
60 Minn. 123, 125, 01 N.W. 1023, 1024 (1895) (enforcement of ordinances is as much
within the authority and power of city council as is enactment).
Based on this general authority, many Minnesota cities, bath statutory and charter,
have established administrative penalties for a Variety of ordinance violations. However, this
has not been without controversy, specifically as it relates to cities enforcing their own traffic
regulations rather than state traff is laws. In 2003, the former Stage Auditor took the position,
_ July 31, 2008
Page 6
and the former Attorney General issued an opinion, that cities are preempted from enforcing
local traffic regulations. The current State Auditor has issued a Position Statement that her
office will follow the opinion of the AG as it relates to traffic code enforcement. Her office
issued letters/surveys to cities, asking whether they have an administrative process for traffic
offenses, how much revenue has been collected, and demanding repayment to the State for
any amount collected for traffic fines that should have been prosecuted in district court. Her
office issued a "Special Study" in February 2008 discussing the findings.
It is important to note that the former and current State Auditors and the AG do not
specifically deny a city's authority to enforce other code provisions, such as building code,
zoning code, housing code or public nuisance violations, through an administrative process,
despite statutory provisions that might apply (e.g., nuisance abatement of dangerous
buildings). certainly, as noted above, a city may enforce these other code provisions by
citation in district court if the city's code provides that such violations are misdemeanors.
Arguably, the focus of the State Auditor and of the Attorney General on preemption in the field
of traffic violations without an explicit statement denyingthe existence of city authority for local
enforcement of all types, could be read as recognition that. code enforcement in these other
areas is something inherently local, dealing directly with livability issues and community
values, and should be enforced locally.
The League of Minnesota cities has been working each legislative session over the past
several years for a clarification of cities` authority in this area. No bills have beers passed thus
far, but more are expected for the 2009 session beginning in February. In the mean time, the
League has taken the following position:
The League supports the use of city administrative fines for local regulatory
ordinances, such as building codes, zoning codes, health codes, and public
nuisance ordinances. The League supports the use of city administrative fines,
at a minimum, for regulatory matters that are not duplicative of misdemeanor or
higher state traffic and criminal offenses. Further, the League endorses the
concept that administrative penalty bearings should be held before disinterested
third parties, which may include city councils, to ensure fairness in the
proceedings.
If state leaders enact legislation that prohibits cities from using administrative
fines for minor traffic offenses, they should also change the distribution of
statutory violations fine revenues so that cities are adequately compensated for
enforcement and prosecution costs. Finally, the state should require that if a
court reduces the amount paid by a violator, any reduction should be made from
the surcharge and not the fine.
July 31, 2008
Page 7
As the Legislature continues to debate the issue, it is likely safe for cities to proceed
with administrative penalties for non -traffic -related violations.
2. Enforcement issues.
Assuming a city has full authority to establish an administrative process for code
enforcement in given situations, the question remains whether such a process will be effective.
This is an open question, with little, if any, guidance in the law.
Obviously, criminal enforcement in district court is an option,, but, as noted above, is
not perfect. However, it is far from clear whether an administrative process is more effective.
Except for the two statutes cited above, where administrative penalties are specifically
proscribed, cities are generally free to establish their own process. For example, there could be
progressive fines (first offense, $3 00; second offense,, $500; third offense $1000, and so on);
or there could be progressive fines to a certain point, eventually leading to a criminal citation.
Some cities provide that an unpaid administrative penalty results in a misdemeanor citation.
There is no conclusive evidence that thes'e procedures are more effective in accomplishing code
compliance.
There is also the issue of collection of an administrative penalty. Cities approach this
differently. Some do take the approach that an unpaid administrative fine becomes a lien
against the property and may be assessed against the property and collected In the same
manner as taxes. A statutory city does not have clear authority to follow this procedure. While
it is true that a city has authority to intervene to abate a public nuisance pursuant to Minnesota
Statutes § 429.021, subd. 10, and specialty assess the cost,, the assessment authority is for
the cost of abatement, not for an administrative penalty for a code violation. Accordingly,
authority to assess an unpaid administrative penalty is not express in every situation.
For example, a city does have the authority to certify "unpaid [water and sewer] charges
to the county auditor with taxes against the property served for collection as other taxes are
collected.vt Minn.Stat- § 444.075, subd. 3e. This authority does not extend to unpaid
municipal gas or electric charges. See A.G. Op. 624-D-5 (July 6, 1953). Likewise, there is
no explicit authority granted to statutory cities to certify any amount they choose for collection
with property taxes.
July 31, 2008
Page 8
There is no concrete evidence that statutory cities who do employ this procedure have
ever been challenged on it in court. Until there is a challenge or a legislative clarification, it is
advisable to consider another alternative for collection of unpaid administrative penalties.
Very ul urs, 1%.
come F ome
my K.. midt
JPF.-jrnt
M. Ron Moorse
Attachment C
Example Administrative Fine Code —
City of North Oaks
October 19, 2009, City Council Work Session
North Oaks City Code
§ 10.98 SUPPLEMENTAL ADMINISTRATIVE PENALTIES.
(A) In addition to those administrative penalties established in this code and the
enforcement powers granted in § 10.20, the City Council is authorized to create by
resolution, adopted by a majority of the members of the Council, supplemental
administrative penalties.
(B) These administrative penalty procedures in this section are intended to provide the
public and the city with an informal, cost-effective, and expeditious alternative to
traditional criminal charges for violations of certain provisions of this code. The
procedures are intended to be voluntary on the part of those who have been charged with
those offenses.
(C) Administrative penalties for violations of various provisions of the code, other than
those penalties established in the code or in statutes that are adopted by reference, may be
established from time to time by resolution of a majority of the members of the City
Council. In order to be effective, an administrative penalty for a particular violation must
be established before the violation occurred.
(D) In the discretion of the peace officer, City Clerk, or other person giving notice of an
alleged violation of a provision of this code, in a written notice of an alleged violation,
sent by first-class mail to the person who is alleged to have violated the code, the person
giving notice may request the payment of a voluntary administrative penalty for the
violation directly to the City Treasurer within 14 days of the notice of the violation. In the
sole discretion of the person giving the notice of the alleged violation, the time for
payment may be extended an additional 14 days, whether or not requested by the person
to whom the notice has been given. In addition to the administrative penalty, the person
giving notice may request in the notice to the alleged violator to adopt a compliance plan
to correct the situation resulting in the alleged violation and may provide that if the
alleged violator corrects the situation resulting in the alleged violation within the time
specified in the notice, that the payment of the administrative penalty will be waived.
(E) At any time before the payment of the administrative penalty is due, the person who
has been given notice of an alleged violation may request to appear before the City
Council to contest the request for payment of the penalty. After a hearing before the
Council, the Council may determine to withdraw the request for payment or to renew the
request for payment. Because the payment of the administrative penalty is voluntary,
there shall be no appeal from the decision of the Council.
(F) At any time after the date the payment of the administrative penalty is due, if the
administrative penalty remains unpaid or the situation creating the alleged violation
remains uncorrected, the city, through the City Attorney, may bring criminal charges in
accordance with state law and this code. Likewise, the city, in its discretion, may bring
criminal charges in the first instance, rather than requesting the payment of an
administrative penalty, even if a penalty for the particular violation has been established
by Council resolution. If the administrative penalty is paid, or if any requested correction
of the situation resulting in the violation is completed, no criminal charges shall be
initiated by the city for the alleged violation.