City of Seattle v. McCready

868 P.2d 134, 123 Wash. 2d 260, 1994 Wash. LEXIS 127
CourtWashington Supreme Court
DecidedFebruary 24, 1994
Docket59359-1
StatusPublished
Cited by157 cases

This text of 868 P.2d 134 (City of Seattle v. McCready) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Seattle v. McCready, 868 P.2d 134, 123 Wash. 2d 260, 1994 Wash. LEXIS 127 (Wash. 1994).

Opinion

Utter, J.

In this case, we once again consider the constitutionality of portions of the City of Seattle’s Residential Housing Inspection Program (RHIP). In Margola Assocs. v. Seattle, 121 Wn.2d 625, 854 P.2d 23 (1993), we were confronted with a number of constitutional challenges to the funding provisions of the RHIP. We rejected most of these challenges, including those based on taking without just compensation, substantive due process, equal protection, and the impairment of contracts. Margola, 121 Wn.2d at 642-54. We remanded the case for further proceedings, however, because a material question of fact persisted as to whether the funding provisions were an impermissible tax or a permissible fee. Margola, 121 Wn.2d at 640-41.

Here, we are faced with a constitutional challenge to the manner in which Seattle has implemented the RHIP. A number of Seattle landowners assert that "inspection warrants” issued by a superior court in implementation of the RHIP violate the fourth amendment to the United States Constitution and article 1, section 7 of the Washington State Constitution. They argue the warrants are unconstitutional because they were issued without probable cause to believe the buildings to be searched were in violation of the pertinent building and housing codes.

We hold that under Const. art. 1, § 7, the warrants must be quashed.

*263 I

As we noted in Margóla, Seattle previously enforced its building and housing codes, including the Building Code, the Electrical Code, the Housing Code, etc. (collectively, "the housing codes”), solely on a complaint and probable cause basis. 121 Wn.2d at 631-32. That is, the City’s Department of Construction and Land Use (DCLU) would investigate potential violations of the housing codes only when there was either a complaint of a violation or if DCLU had other evidence constituting probable cause to believe a violation had occurred.

In 1986, DCLU concluded the complaint-based system was inadequate and that some form of "proactive” enforcement program was needed. The agency therefore proposed to the Seattle City Council that research be done in the direction of formulating such a program. In 1987, the Seattle city council accepted DCLU’s recommendation, determining that "housing code enforcement on a complaint basis frequently delays City intervention until structures have become seriously deteriorated.” Seattle City Ordinance 113531 (July 30, 1987). The city council therefore directed DCLU to develop and implement a "demonstration program” involving proactive enforcement, in which inspections would be based on objective factors such as building size, age, and geographic location rather than on probable cause. Ordinance 113531, §1.

The demonstration program operated from 1987 through the end of 1988. Three hundred fifty apartment buildings were chosen at random from the City’s housing stock and inspected for housing violations. DCLU then compiled the data from the inspections. DCLU reported to the city council that while 78 percent of the 350 buildings inspected had some sort of housing code violation, only a "small percentage” had "serious” code violations. Clerk’s Papers, at 197. However, DCLU also reported that over 80 percent of the buildings with violations had not been the subject of complaints under the previous system. Clerk’s Papers, at 197. In light of the findings of the demonstration program, DCLU *264 recommended to the city council some sort of permanent proactive enforcement program be adopted.

The city council therefore directed the agency by resolution to "design and propose a proactive enforcement program”. Seattle City Resolution 28046 (Sept. 18, 1989). The council indicated that any proposed program should employ computer modeling of objective factors in order to identify the worst "30 percent” of the City’s multifamily apartment buildings for inspection. Resolution 28046. Pursuant to Resolution 28046, DCLU developed the RHIP.

Unfortunately, the precise characteristics of the RHIP are not contained within a single legislative or administrative document; instead, the details of the RHIP must be gleaned from the various affidavits and declarations which are present in the record. In brief, the RHIP is a "predictive model” inspection program, whereby DCLU chooses to inspect buildings on the basis of certain objective factors associated with those buildings rather than on specific information of a violation of the housing codes. The "predictive model” which is the source of the RHIP’s inspection decisions was developed by a private economics consultant. The consultant employed multiple regression analysis, a common statistical tool, to identify correlations between objective factors, like a building’s age, and likelihood of serious code violations. Based on the data from the demonstration program, he ultimately identified three objective factors which had a statistically significant relationship to the likelihood of violations: building age, assessed value per unit, and number of code violations in the past 5 years. Using these three factors as predictors, the consultant selected the 30 percent of Seattle’s multifamily apartment buildings with the highest likelihood of serious code violations.

DCLU implemented an inspection program with respect to the buildings on the 30 percent list through a system of owner notification, tenant consent, and, finally, search warrants. According to the official who manages the RHIP, apartment building owners are notified as a "matter of courtesy”. Clerk’s Papers, at 342. A letter is sent to each of *265 the affected tenants explaining the RHIP and requesting the tenant’s consent to inspect. If the tenant refuses entry to the city’s inspectors, a search warrant is sought ex parte. It is unclear from the record whether notice of the warrant proceeding is provided to the nonconsenting tenant. One tenant has indicated he received no notice, Clerk’s Papers, at 1388, while another was informed a warrant would be sought, though not on what date or in what forum, Clerk’s Papers, at 1173.

Resolution 28046 had directed DCLU to "design and propose” a proactive inspection program. While this language might imply the city council intended to review the RHIP before its implementation and pass an authorizing ordinance, no ordinance has been issued enacting the RHIP. However, the council has taken a number of actions indicating its support for DCLU and the program. As part of its budget ordinance for 1990, the council approved funds for the implementation of the RHIP. See ordinance 114800 (Dec. 1, 1989) and Clerk’s Papers, at 250. The council also enacted an ordinance providing civil penalties for persons who interfered with RHIP inspections. Ordinance 116315 (Aug. 21, 1992). And finally, on July 13,1992, the council issued a resolution, in which the mayor "concurred”, recognizing that warrants might be necessary in order to carry out the RHIP. Resolution 28562 (July 13, 1992).

On April 2, 1991, prior to seeking any warrants, Seattle filed a class action in superior court, seeking a declaratory judgment that the RHIP was valid under both the Fourth Amendment and Const. art. 1, § 7. The complaint named a number of the appellants, including James and Ann.

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Bluebook (online)
868 P.2d 134, 123 Wash. 2d 260, 1994 Wash. LEXIS 127, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-seattle-v-mccready-wash-1994.