HomeMy WebLinkAbout12-01-2007 AO Discussion Points - City ResponseADMINISTRATIVE OFFENSE DISCUSSION POINTS
1. Administrative Offenses that are certified to Property Taxes should be property-
based.
The city agrees.
2. Should there be a neutral arbitrator?
I would suggest that if the Charter addresses this in any fashion, it should
provide the city with the authority to establish a third party neutral or
hearing officer and not get into any specifics for the reasons articulated.
3. Can a property owner request a fine be certified to his taxes immediately rather than
paid in cash?
Yes, we already provide for this now with diseased tree removal and for
some abatements. I would caution against using the word "immediately",
however, as we typically go through the certification process just once a
year. we could do it every March and every September, but the county
only processes such requests once a year early in the fall in preparation
for the following year's tax statements.
4. What should be the limit of total amount of fines certified rather than submitted to the
Court and over what period of time should this be applied?
I would not recommend establishing a limit in the first place, although I
understand why others may be more comfortable with a limit. That said,
if a limit is truly deemed necessary by the Commission, then I would
recommend the limit be established to reflect the sum of the three
graduated fines plus respective late fees. In other words, if the first fine
is $150, the second $300 and the third $450 (for same or similar
violations) and all are unpaid and thus subject to late fee of $50 each, the
total would be $1,050. Please keep in mind however that if court
citations are issued for the same offenses rather than AOs, the maximum
cumulative fines a judge could impose would be $3,000 with no provision
for certifying against the property taxes.
5. Do we need to specify a minimum period of time between the receipt of a fine and the
certification of unpaid fines to taxes?
No. If we extend the time frame by which a recipient has to pay the fine
to 30 days, I see no reason why we would need to further limit the time
before a certification could move forward. Even if we acted immediately
after the thirty-day period to begin the certification process, we would still
need to provide notice to the property owner and then provide them with
an opportunity to be heard before the city council.
6. Do abatement costs need to be included with A. O. fines at the time of certification
and should any limits on certification amounts specifically include or exclude
abatement?
It would not be a good idea to limit the amount of abatement costs that
can be certified to taxes. If an abatement is substantial, often the property
owner welcomes the assistance and acknowledges the responsibility to
pay. What we can do for more substantial abatement assessments is
perhaps offer to extend the assessment over more than just one year, but
even this should be left more to the request of the resident upon approval
of the council. The city presently has the authority to certify abatements
under section 607.09, subds 5-8.
NEW QUESTIONS FOR THE COMMISSION AND CITY STAFF
1. Do we want to change the amount of time citizens are granted to pay fines and is that
under the purview of the Charter?
The City Code presently requires that an administrative offense be paid
within 7 days. We start adding on late fees of $5 per week for every week
the fine remains unpaid. For County Citations, typically a person is
provided 21 days in which to pay. My suggestion, if there is a desire to
modify this, would be that we provide 30 days to pay the fine rather than
7, and then AFTER the 30 days, if the recipient has not otherwise
appealed the AO or scheduled a hearing, rather than charging a $5
weekly fee that after one year could total an additional $260, we charge a
one-time flat late fee penalty of $50.
2. What is an Administrative Rule?
An administrative rule is a provision, regulation or requirement imposed by
the administrative body—the City Council.
3. Should we or Can we use the fee schedule on which to define the offenses
included?
No--the fee schedule would not be an appropriate document within which
to include definitions. To the extent necessary to differentiate one fine or
fee from another, then yes, some level of explanation might be in order,
but in my opinion, definitions are better left in the City Code. In some
instances we have added Code references to some sections of the fee
schedule to make it easier to refer back to the governing language. (e.g.,
See Chapter 502 of the City Code.)
4. Where are the late charges for unpaid fines specified?
I conducted a cursory search of the City Code and the latest fee schedule
did not find reference to what the late fee is. This *should* be reflected in
the fee schedule adopted annually by the Council, and I would assert that
a $5 per week late fee is both cumbersome to track and potentially more
expensive in the long run. See my response to question #1.
5. A comparison of the language in 702.02 and 104.01 seems to show a discrepancy of
dollar maximums for fines: ie, misdemeanors = $700.00 and Administrative Offenses =
$100.
There is no discrepancy. This reflects the two different mechanisms by
which a person can be cited. If an officer (or other designated staff
member) writes a Ramsey County Court Citation for a violation of Code, it
is considered misdemeanor, punishable up to $700 and/or 90 days in jail.
For the same violation logged as an admin offense, the fine is $100. It
should be noted that the maximum fine is now $1,000, an amount set by
the state--not Mounds View--and if and when we amend the Code to
update regarding AOs, we'll update that amount at the same time.
6. What is an Administrative Offense as opposed to a misdemeanor and when does it
become a misdemeanor? We have language stating, “Any violation of this section
constitutes a misdemeanor.” This would seem to imply no difference at all.
Correct. The AO process was intended to help expedite corrective action
and to avoid having to send a resident to court in a different city just
because they had some junk in the backyard or an unlicensed vehicle.
This is even more of an issue today, in that I just received notice that due
to the backlog of cases, court citations we wrote in October will not be
heard by a judge until February. For violations which have not been
resolved, waiting five months to have a judge order someone to clean
their yard or remove a junk car is very frustrating, especially so for the
neighbors who have to put up with the ongoing violations. That is why we
use the AO process--to provide a more expedient citation review and
resolution, a more convenient process, and a less expensive process.
Toward that last point, given that the fines have not increased since their
inception in the 1980s, and since the fines are generally ignored, we feel
strongly that the new fine schedule and process for certifying unpaid
property-based fines move forward.