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RPVCCA_CC_SR_2012_04_17_04_Door_to_Door_SolicitationCITY OF MEMORANDUM RANCHO PALOS VERDES TO: FROM: DATE: SUBJECT: REVIEWED BY: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL CAROL LYNCH,CITY ATTORNEY APRIL 17,2012 THE REGULATION OF DOOR-TO-DOOR SOLICITATION WITHIN THE CITY /:'In CAROLYN LEHR \J!Y-- RECOMMENDATION Staff recommends that the Council receive and file this staff report and direct Staff to continue to provide information to the City's residents about the availability of the City's "do not disturb"signs,and that it is a misdemeanor for a person to disturb an individual who has posted such a sign at his or her residence. EXECUTIVE SUMMARY Over the last thirty years,the case law governing door-to-door solicitation regulations has changed dramatically.Courts have routinely struck down regulations that impinge upon the rights of those seeking to disseminate noncommercial information or ideas within the community.These judicial decisions caused the Rancho Palos Verdes City Council to revise its regulations regarding door-to-door solicitation in 2007.In so doing,the City Council eliminated the requirement that those seeking to go door-to-door to distribute noncommercial materials or to solicit funds first must obtain a letter of authorization from the City. Even though the requirement to obtain a letter of authorization was eliminated,the City Council retained another provision of the Municipal Code,which is similar to code provisions that have been upheld by the courts.This provision is the ban on knocking on doors or otherwise disturbing residents who have posted "no solicitation"or "do not disturb" signs on their properties.(Municipal Code Section 5.20.030 A.)This provision seems to be the most effective tool to prevent intrusions into residents'privacy by those seeking to disseminate information or to solicit funds.This type of provision has been upheld by the courts because it is "content neutral,"meaning that it applies to anyone seeking to go door- to-door,regardless of whether the person is seeking only to distribute information,to solicit funds,or to attempt to engage in a commercial transaction. Unlike code provisions that distinguish between the type of non-commercial speech that is regulated,which are presumed to be invalid,this type of ordinance,which applies to everyone,enjoys greater deference under the First Amendment.It also avoids the problem R6876.0001/1444091v1 4-1 Regulation of Solicitation April 17,2012 Page 2 of having a City-issued permit or letter create a false sense of security on the part of residents by virtue of the City's issuance of the permit.This is because the courts also· have restricted the information that governmental entities can obtain from noncommercial solicitors. Accordingly,Staff recommends that the City Council receive and file this report and continue to make information about allowable solicitation practices available to residents along with do not disturb signs that the residents can place on their properties.(It should be noted that residents are not required to use the "do not disturb"sign that is available at City Hall and may choose to post a different sign on their properties.)By posting such a sign,residents can preserve their right not to be disturbed or solicited and can report violators to the Sheriff's Department.The Deputies then can issue citations to individuals who violate the Municipal Code. BACKGROUND Because of the ongoing issue of crime in the City,and to provide information to the City's residents about the City's current Code provisions regarding door-to-door solicitation, Councilwoman Brooks requested that this matter be placed on a City Council Agenda. In 2002,the United States Supreme Court decided a case,Watchtower Bible &Tract Society Of New York v.Village of Stratton,536 U.S.150 (2002),which invalidated an ordinance regulating door-to-door canvassing,peddling and solicitation.The Watchtower case concerned an ordinance enacted by the Village of Stratton in Ohio.The ordinance targeted "canvassers,solicitors,peddlers,hawkers,itinerant merchants [and]transient vendors of merchandise or services."Under that ordinance,unless a solicitation permit had first been obtained from the mayor's office,such persons could not enter private property for any of the following purposes:"advertising,promoting,selling and/or explaining any product,service,organization or cause,or ...soliciting orders for the sale of goods,wares,merchandise or services."Moreover,even with a solicitation permit,such persons were prohibited from entering private property when the resident had filed a "no solicitation reg.istration form"with the Village and had posted a "no solicitation"sign. Stratton did not charge a fee for solicitation permits.In accordance with the ordinance,the Village routinely issued solicitation permits upon submission of a complete application. The Watchtower case arose because Stratton construed its ordinance as applying to persons seeking to distribute religious literature door-to-door.In particular,the Village interpreted the term "canvassers"as including Jehovah's Witnesses and the term "cause" as including their ministry.Two organizations (Watchtower Bible and Tract Society of New York,Inc.and Wellsville,Ohio,Congregation of Jehovah's Witnesses,Inc.)challenged the ordinance as violating their constitutional rights.They alleged that they do not solicit contributions for the sale of merchandise or services,but they do accept donations. Following numerous prior decisions by appellate courts,including the United States Supreme Court,the lower courts generally ruled in Stratton's favor.At the trial level,the district court limited the information required of permit applicants and struck the post 5 p.m. R6876.0001/1444091v2 4-2 Regulation of Solicitation April 17,2012 Page 3 canvassing ban,but otherwise sustained the ordinance.The Sixth Circuit Court of Appeals subsequently affirmed. By an 8-1 vote,the Supreme Court reversed the judgment for Stratton,struck down Stratton's ordinance,and remanded the litigation for further proceedings.The majority opinion,which was joined by six Justices,reasoned that the ordinance violated the First Amendment due to the "breadth of speech affected"and the "nature of the regulation." [Watchtower,supra at 6693.]The majority was troubled that the ordinance precluded anonymous and spontaneous distribution of political handbills,and that it burdened some speech by citizens holding religious or patriotic views. Additionally,the majority was not persuaded that the ordinance was tailored to Stratton's interests jn protecting residential privacy and preventing fraud and crime.The Court found that the interest in preventing fraud provides "no support forthe [ordinance's application]to petitioners [religious proselytizers],to political campaigns,or to enlisting support for unpopular causes."(lQ.at 166.)The Court also found that the Village had no interest in applying their permitting ordinance to such individuals based on privacy concerns.(lQ.at 168)("As to the resident's privacy concerns,the posting of 'No Solicitation'signs and enforcement taken against any organization or individual who disregards such signs provides ample protection for the resident's privacy.")Finally,the Court was not satisfied with the Village's proffered interest in the prevention of crime.The Court reasoned that "it seems unlikely that the absence of a permit would preclude criminals from knocking on doors and engaging in conversations not covered by the ordinance."(Id.at 169.) The Court clearly was most concerned with how the Stratton ordinance affected purely political and religious speech.This focus is evident from the examples (political handbill distribution and speech by persons with religious or patriotic views)used to illustrate the "pernicious effect"of Stratton's permit requirement.[Watchtower,supra at 6693.] The Court implied that municipalities can prohibit entry upon private property when the resident has posted a "no solicitation"sign or joined a government-maintained "no solicitation"registry.The Stratton ordinance contained such a prohibition,but the court did not directly address its validity because the plaintiffs had not challenged it.In dicta, however,the court stated that this provision,coupled with residents'ability to refuse to converse with unwelcome visitors,"provides ample protection for the unwilling listener." [Watchtower,supra at 6694.]In support of this proposition,the court cited the following statement from an earlier case invalidating a charitable solicitation ordinance:"[T]he provision permitting homeowners to bar solicitors from their property by posting [no solicitation]signs ...suggest[s]the availability of less intrusive and more effective measures to protect privacy."[Schaumburg v.Citizens For Better Environment,63 L.Ed.2d 73,89 (1980).] Because the Watchtower decision invalidated the requirement that a permit must be obtained before a charitable solicitation can occur,which was similar to the City's process of obtaining a letter of authorization that was required by former Chapter 5.20,the City Council amended the Municipal Code and repealed the Code provisions requiring a letter R6876.0001/1444091v2 4-3 Regulation of Solicitation April 17,2012 Page 4 of authorization. One question that Watchtower did not decide was whether permitting regulations that apply to non-commercial solicitation where a donation is requested,but not to "pure" noncommercial speech that does not include a request for a donation,would withstand judicial scrutiny.Subsequent judicial decisions have held that this type of regulation also is invalid because it impermissibly distinguishes between types of non-commercial speech, and because the request for the donation is inextricably intertwined with the non- commercial message that is being communicated. On the other hand,the courts have continued to uphold the distinction between commercial speech and non-commercial speech and have upheld permitting requirements that are applicable only to commercial transactions. DISCUSSION In response to concerns from residents about peddling from catering trucks within the City, in 2006,the City Council adopted Chapter 5.28 of the Municipal Code.That Chapter established comprehensive regulations governing any commercial sale that is conducted within the City,which is not conducted from a fixed location.Accordingly,those regulations govern commercial sales of items that are conducted on foot,door-to-door,or from a vehicle.The provisions of Chapter 5.28 do not include the non-commercial dissemination of information because that Chapter only governs solicitations when an item is presented for purchase at the time that the solicitation is made and exempts sales by nonprofit organizations,as defined by the Internal Revenue Code,which are registered as such with the California Secretary of State. Based on the Court's decision in Watchtower,the City Council amended the provisions of Chapter 5.20 governing solicitation as follows: The entire process for issuing letters of authorization to those wishing to conduct a solicitation within the City was eliminated.This complied with the decision in Watchtower because anyone seeking to solicit within the City,including those who simply wish to disseminate information,no longer is required to obtain a letter of authorization from the City.However,all commercial solicitors or peddlers,as defined in Chapter 5.28,still will have to obtain a business permit prior to selling their wares in the City.By adopting those requirements,the City advanced its goal of protecting the public from fraudulent commercial transactions arising from the sales of goods and wares. Although one can argue that someone who is attempting to collect a donation to raise money for a non-profit corporation also should be regulated,the City Attorney's Office has recommended against this approach.The recommendation was based upon the concern that the regulation of non-commercial donations would impermissibly distinguish between different types of non-commercial speech,meaning those seeking donations and those who simply wish to disseminate information,because this would be a content-based restriction that is presumptively invalid under the case authority. R6876.0001/1444091v2 4-4 Regulation of Solicitation April 17,2012 Page 5 [See,City of Renton v.Playtime Theaters,Inc.,475 U.S.41,46-47 (1986),supra;see also,City of Fresno v.Fresno Press Communications,Inc.,31 Cal.App.4th 32 (1994).] Indeed,subsequent to the Court's decision in Watchtower,two federal district courts (one in New Jersey and one in Ohio)have struck down ordinances that required non- commercial solicitors who were soliciting for funds to obtain a permit while exempting those who were simply disseminating information from the permit requirement.One court held that the ordinances impermissibly regulated the type of solicitation based on the content of the speech by not requiring all noncommercial solicitors to obtain a permit from the local entity.[See New Jersey Environmental Federation v.Wayne Township,310 F.Supp.2d 681,692-694 (D.New Jersey 2004)(political campaigners were not required to obtain permit before canvassing).]The other court extended Watchtower's reasoning to activities involving both issue advocacy and fundraising. [Ohio Citizen Action v.City of Mentor-on-the-Lake,272 F.Supp.2d 671 (N.D.Ohio 2003).]That court found that a permit system was an impermissible prior restraint on speech on persons and entities that "incorporate the solicitation of funds for their cause during [informational or advocacy]campaigns."(Id.at 680.) Those courts analyzed the purpose of those ordinances,to protect the privacy of the residents,and concluded that if that was the goal,the privacy of the resident was disturbed as much by a person seeking only to disseminate information as by a person who also was seeking a contribution: The local public entity]gives absolutely no explanation as to why visits from those door-to-door canvassers are in any way less annoying or less of an invasion of privacy than those by the individuals and groups required to obtain a permit under the Ordinance. [New Jersey Environmental Federation,310 F.Supp.2d at 696-97.] In the 2007 amendments to the Municipal Code,the City Council retained the provisions of the Code (Section 5.20.040)that preclude the placement of handbills on unoccupied parked vehicles and the placement of unsecured handbills upon private residential property,as valid restrictions that prevent littering.[See Jobe v.City of Catlettsburg,409 F.3d 261 (6 th Cir.2005).] The City Council also retained the preclusion against entering upon any residential property where a "do not disturb"or similar sign is posted,which is set forth in Section 5.20.030 A of the Municipal Code.This provision maintains the privacy of any individual who does not want to be disturbed by a solicitor or vendor who comes upon his or her property. Again,although not part of the express holding in the Watchtower case,the Court's opinion indicated that such a provision would be narrowly tailored to an individual's privacy interest.[Watchtower at 168;see also,Schaumburg v.Citizens for a Better R6876.0001/1444091v2 4-5 Regulation of Solicitation April 17,2012 Page 6 Environment,444 U.S.620,639 (1980)("[T]he provision permitting homeowners to bar solicitors from their property by posting [no solicitation]signs ...suggest[s]the availability of less intrusive and more effective measures to protect privacy.);Hynes v. Borough of Oradell,425 U.S.610,619 (1976)("There is,of course,no absolute right under the Federal Constitution to enter on the private premises of another and knock on a door for any purpose,and the police power permits reasonable regulation for public safety.").] Further,the two federal district court decisions discussed above that considered solicitation issues subsequent to Watchtower reasoned that "no solicitation"signs were one method to address resident privacy.The public entity in New Jersey Environmental Freedom had adopted a "no-solicitation list"ordinance and an ordinance enforcing "no- solicitation"signs,which the court observed was "an adequate means to address the privacy problem."The court in Ohio Citizen Action agreed that enforcement of "no solicitatiqn"signs would be acceptable: As to the resident's privacy concerns,the posting of "No Solicitation"signs and enforcement taken against any organization or individual who disregards such signs provides ample protection for the resident's privacy. It also allows residents who are amenable to receiving information, participating in surveys and contributing to charitable causes to decide for themselves who they wish to talk to,listen to,and contribute to.Further, an un-licensed solicitor has no less effect on a resident's privacy than does a licensed solicitor. [Ohio Citizen Action v.City of Mentor-on-the-Lake,272 F.Supp.2d at 683.] To comply with the recent judicial decisions,Section 5.20.030 A was amended to allow solicitors to securely place written materials on a property in a way that won't cause litter so that the solicitor still can distribute information without intentionally disturbing the resident by knocking on the door,ringing the door bell or other similar conduct.By allowing the placement of secured materials at a residence where a "do not disturb"or similar sign is posted,an alternative method of communication is still available to those who are seeking to go door-to-door to communicate a message or to seek funds,which is an important component in evaluating if a regulation will pass constitutional muster. Other content-neutral provisions of Section 5.20.030,which govern the manner of solicitation,were retained.In addition to the preclusion against soliciting at a residence where a "do not disturb"sign is posted,those provisions also prevent solicitors from: intentionally touching the person from whom the solicitation is being made;restricting someone's movement;repeatedly approaching the same person after the person has expressed his or her wish not to be approached;accepting food stamps as a contribution;and misrepresenting his or her physical or mental condition. R6876.0001/1444091v2 4-6 Regulation of Solicitation April 17,2012 Page 7 Because several cases have invalidated restrictions on the time when door-to-door solicitations can occur,City Council deleted Section 5.20.110,which prevented solicitations between the hours of 8:00 p.m.and 8:00 a.m.(See Alternatives for California Women,Inc.v.County of Contra Costa,145 Cal.App.3d 436 (1983).) Additional Information In a recent case entitled Comite de Jornaleros de Redondo Beach v City of Redondo Beach,657 F.3d 936,942 (9th Cir.2011 )("Comite"),the federal district court found Redondo Beach's street solicitation ordinance to be an unconstitutional restraint on speech and thus barred that City from enforcing provisions of its ordinance.The Redondo Beach ordinance barred individuals from "stand[ing]on a street or highway and solicit[ing],or attempt[ing]to solicit,employment,business,or contributions from an occupant of any motor vehicle,"and it had a reciprocal provision to prevent the motorists from "stop[ping],park[ing]or stand[ing]a motor vehicle on a street or highway from which any occupant attempts to hire"another person.(.!Q.at 941.) The Court assumed the ordinance to be content neutral and applied a test that allows the government to impose "reasonable restrictions on the time,place,or manner of protected speech,provided the restrictions 'are justified without reference to the content of the regulated speech,that they are narrowly tailored to serve a significant governmental interest,and that they leave open ample alternative channels for communication of the information.'"(.!Q.at 945.) The Court held that the ordinance was not narrowly tailored because it regulated significantly more speech than necessary to achieve Redondo Beach's purpose of improving traffic flow and safety,and because Redondo Beach could have achieved these goals through less restrictive measures.(Id.at 940-41,947.)The Court found that the ordinance applies to children selling lemonade on the sidewalk and Girl Scouts selling cookies;it prohibits food vendors from advertising to passing motorists,and it applies to charity car washes.(Id.at 948.)Second,although Redondo Beach only introduced evidence of traffic problems in a small number of major streets and medians,its ordinance applied to all streets and sidewalks in the City,which the Court called "geographically overinclusive."(.!Q.at 949.)Third,the ordinance did not distinguish between lawfully parked cars and those moving in traffic.(.!Q.)Although the Court found that Redondo Beach was not required to employ the least-restrictive means necessary to achieve its goals,Redondo Beach had many less-restrictive options to address its concerns,including enforcing jaywalking and other traffic laws and portions of its municipal code regarding interference with traffic.(.!Q.at 949-50.) This case again illustrates the constant evolution of the case law regarding the protections afforded by the First Amendment;it may require Staff to bring forward to the City Council an amendment to portions of Chapter 5.20 of the Municipal Code. R6876.0001/1444091v2 4-7 Regulation of Solicitation April 17,2012 Page 8 CONCLUSION Staff recommends that the Council receive and file this staff report and direct Staff to continue to provide information to the City's residents about the availability of the City's "do not disturb"signs at City Hall,and that it is a misdemeanor for a person to disturb an individual who has posted such a sign at his or her residence.The City's newsletter and Channel 33 are methods by which this information can be disseminated to the residents. By so doing,City residents will be aware of their rights under the Municipal Code,and that they can contact the Sheriff's Department when these Code provisions are violated. Attachment Chapter 5.20 -Solicitation R6876.0001/1444091 v2 4-8 Municode Page 1 of4 Rancho Palos Verdes,California,Code of Ordinances»Title 5 -BUSINESS TAXES,LICENSES AND REGULATIONS»Chapter 5.20 -SOLICITATION*» Chapter 5.20·SOLICITATION* Sections: *Prior ordinance history:Ords.290 and 297. 5.20.010 -Definitions. 5.20.020 -Exemptions. 5.20.030 -Manner of solicitation. 5.20.040 -Distribution of handbills. 5.20.050 -Effect on other ordinances. 5.20.060 -Penalty for violations. 5.20.010 •Definitions. As used in this chapter: A."Charitable"means and includes the words patriotic,philanthropic,social services,welfare,benevolent,educational,religious,civic or fraternal,either actual or purported. B."Charitable association"means and includes any organization,whether or not incorporated,that is organized and operated exclusively for charitable,religious, fraternal,educational,cultural,civic or other tax exempt purposes or functions as specified in Article I of Chapter 4 of the California Revenue and Taxation Code (commencing with Section 23701),or any successor thereto,and which has been determined by the Franchise Tax Board to be exempt from taxation,or which has established its exemption under Section 501 (c)(3)of the Internal Revenue Code or any successor thereto. C."City"means the city of Rancho Palos Verdes. D."Contributions"means and includes the words alms,food,clothing,money,or property,subscription or pledge,and also donations under the guise of loans of money or property. E."Person"means any individual,firm,business,partnership,corporation, cooperative,company,association,joint stock association,church,religious sect, religious denomination,society,organization,or league and shall include any trustee,receiver,assignee,agent,solicitor,or other similar representative thereof. F."Solicit"and "solicitation"mean the request,directly or indirectly,of money, credit,property,financial assistance, patronage or other things of value; hawking,peddling,vending,offering for sale or taking orders for any goods, services,or merchandise for charitable (as defined in this section)or commercial purposes or otherwise,or the distribution of information or opinion (including without limitation,advocating for or against a person,cause or organization), conducted door-to-door in residential neighborhoods,in any place of public http://library.municode.com/print.aspx?clientlD=16571 &HTMRequest=http%3a%2:f0102f1i...4/12/2012 4-9 Municode Page 2 of4 accommodation,in any place of business open to the public generally,on the city's streets and sidewalks,in public parks,on public beaches,or in any other public place."Solicit"and "solicitation"also shall mean and include the following methods of distributing information or opinion,securing money,patronage, credit,property,financial assistance,or other thing of value,when conducted in the following manner: 1.By oral or written report; 2.By the distribution,circulation,posting,or publishing of any handbill, written advertisement or other publication,unless such handbill or written advertisement has been placed on the premises of a business open to the public generally with the consent of the owner or proprietor of such business; 3.The sale or taking orders for any goods,services,merchandise,wares or other tangible items. A solicitation shall be deemed made at its inception,whether or not the person making the same receives any contribution or makes any sale referred to in this subsection. G."Street or highway"means all of those areas dedicated as public thoroughfares, including,but not limited to,roadways,parkways,medians,alleys,sidewalks and public ways. (Ord.453 §1 (part),2007) 5.20.020 -Exemptions. The provisions of this chapter shall not apply to: A.Solicitations made upon premises owned or occupied by the organization or person on whose behalf such solicitation is made; B.Payments required by law to be collected or paid; C.Payments to or for governmental agencies; D.Solicitations made by an association or its authorized agents and employees to its own members and employees; E.Solicitations made by telephone,mail or electronic mail; F.Persons customarily calling only on businesses or institutions for the purposes of selling products for resale or business or institutional use; G.The distribution of items or printed materials for which consideration has been paid by the person receiving such items or materials; H.Solicitations made to a person who has requested or consented to the solicitation. (Ord.453 §1 (part),2007) 5.20.030 -Manner of solicitation. A.No person shall solicit at any dwelling,including,but not limited to,a house,apartment, mobile home or condominium where there is clearly displayed a sign stating "Do Not Disturb."This subsection shall not prohibit the distribution of written material that is properly secured to a residential dwelling in such a way as to eliminate the hazards of randomly scattered litter,provided that the person does not intentionally disturb the http://library.municode.com/print.aspx?clientID=16571&HTMRequest=http%3a%2fUi02fli...4/1212012 4-10 Municode Page 3 of4 resident of such dwelling by knocking on the door,ringing the doorbell or otherwise engage in any act that is intended to attract the attention and disturb the privacy of the occupant. B.No person shall intentionally touch,intentionally come into physical contact with or affix any object to the person of any member of the public without first receiving consent from that member of the public while soliciting. C.No person shall persistently and importunately solicit any member of the public after such member of the public expresses his or her desire not to be solicited.The intent of this provision is not to prohibit future attempts to solicit such member of the public, when separated by a period Of time of no less than twenty-four (24)hours,so long as a reasonable person would not view those subsequent attempts to solicit as persistent and importunate. D.No person shall intentionally or deliberately obstruct the free movement of any person on any street,sidewalk or other place or in any place open to the public generally while soliciting. E.No person shall threaten any injury or damage to any member of the public who declines to be solicited. F.No person shall accept food stamps as a contribution while soliciting. G.No person shall misrepresent his or her physical or mental health while soliciting. H.No person shall,while an occupant of a temporarily standing or moving vehicle on a street or highway,attempt to hire or hire for employment another person or persons. I.No person shall,from any public street,sidewalk,alley,way or other public property, solicit or attempt to solicit employment,business or contributions,vend,peddle,sell and/or offer for sale any merchandise,goods,wares or services to the occupants of vehicles standing or moving in or upon any public street or highway,except that nothing in this subsection shall be construed to prohibit solicitation of the occupants ofany vehicle that is lawfully parked. (Ord.453 § 1 (part),2007) 5.20.040 -Distribution of handbills. A.Distribution upon Residential Property.No person shall drop,throw,scatter,or cast upon any residential property in the city without the consent of the owner or occupant thereof any newspaper,handbill,pamphlet,circular,leaflet,or any other advertising sheet or other printed matter.This subsection shall not be construed to prevent the delivery of newspapers,handbills,or other materials that are individually delivered and secured to the property in such a way as to eliminate the hazards of randomly scattered litter. B.Distribution upon Public Property and Vehicles.No person shall drop,throw,scatter,or cast upon any public street or sidewalk,or place upon any unoccupied vehicle,any newspaper,handbill,pamphlet,circular,leaflet,or any other advertising sheet or other printed matter. (Ord.453 § 1 (part),2007) 5.20.050 -Effect on other ordinances. Compliance with the provisions of this chapter shall not relieve a person from complying with any other applicable provision of the Rancho Palos Verdes Municipal Code,including, http://library.municode.com/print.aspx?c1ientID=16571 &HTMRequest=http%3a%2flIo2f1i...4/12/2012 4-11 Municode Page 4 of4 without limitation,the provisions of Chapter 5.28,and such person shall remain subject to those provisions. (Ord.453 §1 (part),2007) 5.20.060 -Penalty for violations. Any person who violates any provision of this chapter shall be guilty of an infraction for the first violation,and of a misdemeanor for each subsequent violation. (Ord.453 §1 (part),2007) http://library.rnunicode.comiprint.aspx?c1ientID=16571&HTMRequest=http%3a%2fOIo2fli...4/12/2012 4-12