Investigation · Government Accountability

West Hollywood Will Inspect the Victim’s Building. The Source Next Door Stays Sealed.

A property owner documented water pouring in from the bar next door and asked the City to inspect both his building and the source. City Hall moved on the victim’s building — and left the neighbor’s plumbing unopened.

By M. Reynolds  ·  Good Shepherd Media
West Hollywood, Calif.

I have covered a lot of municipal runarounds. This one is different, because the City wrote its own runaround down. A West Hollywood property owner on Santa Monica Boulevard reported that water is intruding through the wall he shares with the bar next door — after that bar’s City-permitted remodel left plumbing running close to the shared wall. His written demand asked the City to inspect the intrusion point in his own building and the source next door. The City moved on his building. When he pressed for the source to be inspected too, its Assistant City Manager wrote that he was “interpreting [the] voice message as a denial” and that the City “will render findings absent such inspection” — recasting a demand to inspect the source as a refusal to be inspected. The offending plumbing next door remains unopened.

The Complaint, in the City’s Own Language

On or about August 11, 2026, the owner — referred to here as Mr. Zullo — sent a formal written demand. It was not a rant. It cited Health & Safety Code sections 17920.3 and 17980, the City’s own nuisance and plumbing ordinances, and it attached a California Public Records Act request for the neighbor’s remodel permit and inspection file. He identified the probable sources next door: an ice-machine drain at the shared wall with no code-compliant air gap, a broken corrugated roof-drainage channel, and a plugged drain and sump with a broken pump.

In other words, he did what a city says it wants a citizen to do. He wrote it down, cited the code, and pointed at the exact fixtures. And here is where the story turns.

Who Is Actually Refusing to Look?

Read the sequence the City itself created, in its emails of August 24, 25, and 26:

• The owner’s written demand asks the City to inspect both the intrusion point in his building and the source next door, and identifies the neighbor’s plumbing as the cause.
• The City schedules an inspection of the owner’s building — “internal and external” — and says nothing about opening the neighbor’s.
• The owner presses, in writing and by recorded voicemail, for the source to be inspected too.
• The City records that as a “denial” and says it “will render findings absent such inspection” — of his building.

Read honestly, the record does not show a citizen refusing to cooperate. It shows a citizen who asked for two things and received movement on only one — the half that points at him. Mr. Zullo invited inspection of his own intrusion point, invited inspection of the source, filed a written legal demand, and requested the permit file. What has not happened is the one thing that would actually locate the cause: an inspection of the offending plumbing next door. The neighbor’s remodel and drainage sit unexamined behind a permit the public has not been shown. A city cannot “render findings” on where the water comes from while declining to open the wall it comes through.

A city cannot render findings on where the water comes from while declining to open the wall it comes through. The source next door has never been inspected.

What the Law Requires — and the Word Is “Shall”

California’s State Housing Law defines a “substandard building” to include “deteriorated or ineffective waterproofing of exterior walls, roofs, foundations, or floors” (Health & Safety Code § 17920.3(g)(2)). In 2024, the Legislature passed SB 1465 (Stats. 2024, ch. 487), effective January 1, 2025, broadening that definition to “any building or portion thereof, regardless of zoning designation or approved uses,” and — pointedly — extending its protection to “nearby residents,” not just a building’s own occupants. A commercial bar is squarely covered, and a neighbor harmed across a shared wall is exactly the “nearby resident” the amended law names.

Once the City inspects and confirms the condition, its discretion is spent. Section 17980(c)(1) says the agency “shall commence proceedings to abate the violation.” Not “may” — “shall.” Where a public agency refuses a clear, present, ministerial duty, a court may compel it by writ of mandate (Code Civ. Proc. § 1085; State of California v. Superior Court (1974) 12 Cal.3d 237), with fees available to a prevailing petitioner under Code Civ. Proc. § 1021.5.

The City’s own code is even more direct. West Hollywood Municipal Code section 9.60.040 declares it a public nuisance to maintain a structure with water intrusion; with roof drainage that “fails to prevent dampness or deterioration in the walls or interior portion of the structure” or roof water “discharged in a manner that creates a public nuisance”; with plumbing not maintained in good condition and waste lines that must “function properly and be kept free from obstructions, leaks and defects”; and with dampness in habitable rooms. Those are the exact conditions documented next door.

And if that bar runs an ice machine, the plumbing standard is not debatable. California Retail Food Code section 114193(a) requires that “ice machines and bins… shall be drained by means of indirect waste pipes, and all wastes drained by them shall discharge through an airgap.” The California Plumbing Code, Chapter 8, says the same. An ice-machine drain at a shared wall with no air gap is not a gray area — it is a violation, and it sends water exactly where Mr. Zullo says it is going.

Immunity Is Not the Wall City Hall Thinks It Is

The City may assume Government Code section 818.6 — inspection immunity — ends the conversation. It does not. That immunity blocks certain damages claims for negligent inspection (Haggis v. City of Los Angeles (2000) 22 Cal.4th 490); it does not bar a writ compelling the mandatory abatement duty, and it does not touch nuisance. The California Supreme Court held in Nestle v. City of Santa Monica (1972) 6 Cal.3d 920, 937 that Government Code section 815 “does not bar nuisance actions against public entities to the extent such actions are founded on section 3479 of the Civil Code.” Nor does immunity reach inverse condemnation: “the immunities provided by the Tort Claims Act do not insulate a public entity from liability for inverse condemnation” (Pacific Bell v. City of San Diego (2000) 81 Cal.App.4th 596, 602–603; Baldwin v. State of California (1972) 6 Cal.3d 424, 438). And because water intrusion is a continuing condition, every recurrence is a fresh wrong until it is abated (Baker v. Burbank-Glendale-Pasadena Airport Authority (1985) 39 Cal.3d 862).

There is a further wrinkle the City should sit with. Its first substantive response to a written legal demand and a records request was a cease-and-desist aimed at the property owner’s conduct. A citizen’s demand and public-records request are core petitioning activity. When a government answers protected petitioning with threats or coercion, California’s Bane Act (Civil Code § 52.1) supplies a remedy that requires no showing of discriminatory animus (Venegas v. County of Los Angeles (2004) 32 Cal.4th 820), and the First Amendment protects the right to challenge officials (City of Houston v. Hill (1987) 482 U.S. 451; Lozman v. City of Riviera Beach (2018) 585 U.S. 87). That is not a verdict. It is the exposure the City invited by answering the messenger instead of the message.

Why Prevention Is the Entire Point

This is not a fight about a stain on a wall. Restoration and construction-defect specialists describe water intrusion into concealed cavities as the start of a chain, not an endpoint: sustained moisture rots framing, feeds mold, and corrodes the connections that hold a structure together. Left unabated over years, water that compromises structural elements can, in the worst case, threaten the integrity of the building itself — and a compromised structure endangers every person and animal in or beside it. No one is predicting a collapse next week. That is precisely the point of prevention. The substandard-building statutes exist to force repair before deterioration becomes catastrophe. A city that receives documented notice of active, recurring intrusion against structural elements — and answers by inspecting the wrong building — is not managing that risk. It is running out the clock on it.

The People Who Now Owe the Public an Answer

Assistant City Manager Steve Campbell is the official the City named as the property owner’s sole point of contact and the author of the emails at the center of this account — the one scheduling the wrong building, and the one recasting a correction as a “denial.” By the City’s own instruction, he is the person responsible for moving this matter. So far he has moved it in the wrong direction.

Mayor John Heilman, sworn in January 12, 2026, presides over the City this year. Heilman is a founder of West Hollywood, has served as mayor nine times, and teaches law — a professor at Southwestern Law School and adjunct at USC. A city led by a law professor cannot plausibly claim the word “shall” in section 17980 is beyond its understanding. The standard West Hollywood should be held to is the one its own Mayor teaches in a classroom.

City Manager Jackie Rocco, installed in 2026, leads the staff that received the complaint and the records request. At her installation the Mayor said the Council must “hold staff accountable.” This matter is the test of whether that phrase means anything.

Six Questions West Hollywood Must Answer

1. The demand asked the City to inspect both the intrusion point and the source next door. Why has the City moved only on the complainant’s building and not scheduled inspection of the source?

2. Will the City now inspect the neighbor’s ice-machine drain, roof-drainage channel, and drain and sump — and release the neighbor’s remodel permit and inspection file?

3. If inspection confirms a substandard condition, does the City acknowledge its non-discretionary duty under section 17980(c)(1) to “commence proceedings to abate”?

4. On what basis did the City call a written and recorded correction a “denial,” and does it stand by rendering findings “absent inspection” of the source?

5. Did the neighbor’s remodel receive City permits and pass City inspection — and if so, how did plumbing at the shared wall pass?

6. Was the cease-and-desist a response to the owner’s protected petitioning and records request, and how does the City square that with the Bane Act and the First Amendment?

Prevention is not a favor a city grants when it feels like it. Under California law it is a duty, and the duty is written with the word “shall.” The man who reported the leak asked for the source to be inspected. So far, West Hollywood has agreed to look everywhere except the wall the water comes through.

Key Findings

• California law places a mandatory, non-discretionary “shall abate” duty on West Hollywood once it inspects and confirms a substandard water-intrusion condition (Health & Safety Code § 17980(c)(1)), and — as of SB 1465 (Stats. 2024, ch. 487, eff. Jan. 1, 2025) — that duty now reaches “any building or portion thereof, regardless of zoning designation” and expressly protects “nearby residents.” The City’s decision to inspect Mr. Zullo’s own building  rather than the source (the adjacent bar) inverts the statutory scheme.
• The strongest tools are the mandatory-abatement duty (§ 17980(c)(1) + writ of mandate, CCP § 1085), nuisance liability that survives governmental immunity (Nestle v. City of Santa Monica), and inverse condemnation (which overrides Tort Claims Act immunities). The weakest are damages theories dependent on Gov. Code § 815.6, which face the broad inspection immunity of Gov. Code § 818.6 (Haggis).
• The rhetorical reversal is legally grounded: it is the City and the neighbor — not Mr. Zullo — who are now refusing to inspect the true source and are on course to “render findings absent inspection” of the offending plumbing.

1. The mandatory-duty statute is real and recently strengthened. H&S § 17920.3(g)(2) defines a substandard building to include “deteriorated or ineffective waterproofing of exterior walls, roofs, foundations, or floors,” plus dampness/inadequate-sanitation conditions. Section 17980(c)(1) says that once an enforcement agency “has inspected or caused to be inspected a building and has determined that the building is a substandard building … the enforcement agency shall commence proceedings to abate the violation.” SB 1465 — authored by Sen. Bob Archuleta, sponsored by the Code Enforcement Officers Association (CACEO), and crafted, per California Building Officials, “in the wake of the Ghost Ship Fire … to prevent catastrophic events through proactive enforcement” — amended § 17920.3 to cover “any building or portion thereof, regardless of zoning designation or approved uses of the building … in which there exists any of the following listed conditions to an extent that endangers the life, limb, health, property, safety, or welfare of the occupants of the building, nearby residents, or the public.” As the Serviam Law legal alert explains, “nearby residents are distinguished alongside occupants and the public as those whose health and safety is impacted by substandard buildings, emphasizing the impacts of substandard buildings on the entire community.”
2. Plumbing-code and food-code duties support the “source is the bar” theory. California Retail Food Code (H&S § 114193(a)) requires that “all steam tables, ice machines and bins … shall be drained by means of indirect waste pipes, and all wastes drained by them shall discharge through an airgap into a floor sink or other approved type of receptor.” The California Plumbing Code (Ch. 8) requires ice-making equipment to discharge through an air gap/air break into a receptor. An ice-machine drain at the shared wall lacking an air gap is a documented code violation.
3. West Hollywood’s own code independently declares these conditions nuisances. WHMC § 9.60.040 designates as public nuisances, among others: water intrusion (§ 9.60.040(b)(3)); roof drainage that “fails to prevent dampness or deterioration in the walls or interior portion of the structure” and “roof water … discharged in a manner that creates a public nuisance” (§ 9.60.040(b)(7)); plumbing not conforming to code or “not … maintained in good condition,” and waste lines that must “function properly and be kept free from obstructions, leaks and defects” (§ 9.60.040(h)); and “dampness in habitable rooms” (§ 9.60.040(j)(4)).
4. Nuisance and inverse condemnation pierce governmental immunity; § 815.6 damages claims largely do not. Nestle v. City of Santa Monica (1972) 6 Cal.3d 920, 937 holds Gov. Code § 815 “does not bar nuisance actions … founded on section 3479 of the Civil Code.” Inverse condemnation overrides Tort Claims Act immunities (Pacific Bell v. City of San Diego (2000) 81 Cal.App.4th 596, 602-603; Baldwin v. State of California (1972) 6 Cal.3d 424, 438). But damages for negligent inspection are blocked by the broad inspection immunity of Gov. Code § 818.6 (Haggis v. City of Los Angeles (2000) 22 Cal.4th 490).
5. The City’s “refusal/render findings” tactic is legally reversible and raises retaliation exposure. Mr. Zullo’s written demand and CPRA request are protected petitioning activity; a cease-and-desist aimed at his petitioning conduct implicates the Bane Act (Civ. Code § 52.1; Venegas v. County of Los Angeles (2004) 32 Cal.4th 820) and First Amendment principles (42 U.S.C. § 1983; Lozman v. City of Riviera Beach (2018) 585 U.S. 87; City of Houston v. Hill (1987) 482 U.S. 451).

Statement of the City’s Mandatory Duty

The City of West Hollywood’s Obligation to Inspect and Abate the Source

The Santa Monica Boulevard — water intrusion from the adjacent premises at Santa Monica Boulevard

This statement sets out, in plain terms, the duties California law imposes on the City. These are obligations, not courtesies.

1. The condition is defined by statute. Water intrusion that produces “deteriorated or ineffective waterproofing of exterior walls, roofs, foundations, or floors,” together with dampness and structural deterioration, is a “substandard building” under Health & Safety Code § 17920.3(g) and (a). As amended by SB 1465 (Stats. 2024, ch. 487, eff. Jan. 1, 2025), that definition reaches “any building or portion thereof, regardless of zoning designation or approved uses,” and expressly protects “nearby residents” — the owner’s status relative to THE ISSUE.

2. Abatement is mandatory, not discretionary. Once the enforcement agency “has inspected or caused to be inspected a building and has determined that the building is a substandard building,” it “shall commence proceedings to abate the violation.” (Health & Safety Code § 17980(c)(1).) The Legislature wrote “shall.” Inspecting the complainant’s building while leaving the source next door unopened does not discharge that duty.

3. The City’s own code says the same. West Hollywood Municipal Code § 9.60.040 declares it a public nuisance to maintain a structure with water intrusion; with roof drainage that “fails to prevent dampness or deterioration in the walls or interior portion of the structure”; with plumbing “not maintained in good condition” and waste lines that must “function properly and be kept free from obstructions, leaks and defects”; and with dampness in habitable rooms. Abatement authority follows under WHMC Ch. 1.32 and the adopted building and plumbing codes (WHMC Ch. 13.04, 13.12).

4. The plumbing standard is exact. Ice machines and bins “shall be drained by means of indirect waste pipes, and all wastes drained by them shall discharge through an airgap.” (Health & Safety Code § 114193(a); Cal. Plumbing Code, Ch. 8.) An ice-machine drain at the shared wall without an air gap is a violation on its face.

5. Immunity does not dispose of this. Inspection immunity (Gov. Code § 818.6; Haggis v. City of Los Angeles (2000) 22 Cal.4th 490) does not bar (a) a writ of mandate compelling the mandatory abatement duty (Code Civ. Proc. § 1085; State of California v. Superior Court (1974) 12 Cal.3d 237, with fees under § 1021.5); (b) nuisance liability (Gov. Code § 815 does not bar Civil Code § 3479 actions — Nestle v. City of Santa Monica (1972) 6 Cal.3d 920, 937; a continuing nuisance supports successive actions until abated — Baker v. Burbank-Glendale-Pasadena Airport Authority (1985) 39 Cal.3d 862); or (c) inverse condemnation, which overrides the Government Claims Act immunities (Cal. Const., art. I, § 19; Pacific Bell v. City of San Diego (2000) 81 Cal.App.4th 596, 602–603; Baldwin v. State of California (1972) 6 Cal.3d 424, 438; Albers v. County of Los Angeles (1965) 62 Cal.2d 250).

6. Notice is complete. The City has actual, documented, written notice of an active, recurring, structure-threatening condition. Unabated water intrusion into masonry progressively degrades mortar, brick, and embedded structural elements; the governing statutes exist to compel repair before deterioration becomes catastrophe. Prevention is the purpose of the law, and the duty to prevent is now the City’s.

The City’s obligation is straightforward: inspect the source at Santa Monica Boulevard, and, upon a substandard determination, commence abatement. All rights and remedies are expressly reserved.

M. Reynolds Investigative Reporter, Good Shepherd Media View profile →

Editor’s note: Statements attributed to the property owner reflect his account and the documentary email record, including a recorded voicemail, reviewed as provided and reported as his account. Statutory text, case law, and public records concerning City offices and officials are drawn from primary and government sources. Named public officials are discussed solely in their official capacities. Nothing in this article states or implies that a structural failure is imminent; the discussion of structural risk describes the general, foreseeable progression of unabated water intrusion and the preventive purpose of the governing statutes.

© Good Shepherd Media. goodshepherdmedia.net

Investigation · Government Accountability

Notified, and Still Not Reading: How West Hollywood Answered a Documented Safety Hazard by Inspecting the Wrong Building

A property owner told the City in writing, again and again, that water is destroying his building from the property next door. The City’s answer was to schedule an inspection of his building — then to declare his correction a “refusal.”

By Good Shepherd Media West Hollywood, Calif.

There is a difference between a city that cannot fix a problem and a city that will not read the complaint. Over the span of a single August in West Hollywood, a commercial property owner on Santa Monica Boulevard learned which kind of city he is dealing with. He documented water pouring through a shared wall from the property next door. He cited the exact statutes that obligate the City to act. He sent photographs and video. And the City — through its Assistant City Manager, under a Mayor who teaches law for a living — responded by aiming its inspectors at the wrong building and then treating the owner’s objection as a refusal to cooperate.

The Complaint the City Would Not Read

The facts, as documented by the property owner, are not complicated. His building shares a party wall with the adjacent bar space. After a City-permitted remodel of that neighboring space — a remodel the City itself inspected and signed off — water began intruding through the shared wall into his property. It had not done so before. He identified the probable sources at the neighbor’s address: an ice-machine drain at the shared wall, a broken roof drainage channel, and a plugged drain and broken pump.

On or about August 11, 2026, he sent the City a formal demand. It named the source property. It cited California Health & Safety Code sections 17920.3 and 17980. It requested inspection and abatement of the neighbor’s property, and it included a California Public Records Act request for the remodel’s permit and inspection file. This was not a vague grievance. It was a road map, written in the City’s own legal language, pointing at a single address.

A Record of Not Listening

What followed, according to the email record, is a sequence that speaks for itself:

• First, the City replied not with an inspection date for the source property, but with a cease-and-desist letter over the owner’s phone conduct — a response to the messenger rather than the message.
• Then, when scheduling finally came, the City’s Assistant City Manager offered dates to inspect — in his own written words — the owner’s own building, “to conduct an internal and external inspection of the premises” at the owner’s address, not the neighbor’s.
• The owner corrected the record, in writing and by a recorded voicemail, stating plainly that the property to be inspected is the neighbor’s — the source — not his own.
• The City’s answer was to write back that it was “interpreting [the] voice message as a denial for allowing the City to inspect” his building, and that it “will render findings absent such inspection.” In other words: having pointed at the wrong building, the City recast the owner’s correction as a refusal, and prepared to close the file on that basis.

Read that sequence again. A property owner reports that Building A is flooding his property. The City proposes to inspect Building B — his. He says no, inspect Building A. The City records that “no” as a refusal to cooperate. This is not the paperwork of an agency that misunderstood. It is the paperwork of an agency that was not listening, and then built a record to make the listener the problem.

The owner reported that the property next door was the source. The City scheduled an inspection of his building — then called his objection a refusal.

What the Law Actually Requires

The frustration here is sharpened by the fact that the law is not ambiguous. Under Health & Safety Code section 17920.3, a building is “substandard” when it exhibits, among other conditions, “[f]aulty weather protection,” expressly including “[d]eteriorated or ineffective waterproofing of exterior walls, roofs, foundations, or floors.” As amended by Senate Bill 1465, effective January 1, 2025, that section reaches “any building or portion thereof, regardless of zoning designation or approved uses,” and expressly extends its protection to “nearby residents.”

Once a substandard condition is found, the City’s discretion runs out. Section 17980(c)(1) provides that when an enforcement agency “has inspected or caused to be inspected a building and has determined that the building is a substandard building,” it “shall commence proceedings to abate the violation.” The operative word is shall. And where a public agency refuses to perform a clear, present, ministerial duty, California courts may compel that performance by writ of mandate under Code of Civil Procedure section 1085 — a remedy the Supreme Court has long recognized reaches duties “purely ministerial in character” (State of California v. Superior Court (1974) 12 Cal.3d 237).

The City will likely reach for its inspection immunity under Government Code section 818.6, and courts do construe that immunity broadly (Haggis v. City of Los Angeles (2000) 22 Cal.4th 490). But that immunity is a shield for how an agency inspects — not a license to ignore the separate, mandatory duty to abate once a hazard is determined (Gov. Code section 815.6). Nor does statutory immunity reach a claim for inverse condemnation, which rests on the California Constitution itself: “the immunities provided by the Tort Claims Act do not insulate a public entity from liability for inverse condemnation” (Pacific Bell v. City of San Diego (2000) 81 Cal.App.4th 596, 603). And because water intrusion is a continuing condition, each recurrence is a fresh wrong for which successive actions lie until it is abated (Baker v. Burbank-Glendale-Pasadena Airport Authority (1985) 39 Cal.3d 862).

Why Prevention Is the Whole Point

This is not a dispute about an inconvenience. Restoration and construction-defect specialists describe water intrusion into concealed wall cavities as the beginning of a chain, not an endpoint. Sustained moisture degrades framing and finishes; it feeds mold in enclosed spaces; and it corrodes the connections that hold a structure together. Left unabated over time, water that compromises structural elements can, in the worst cases, threaten the integrity of the building itself — and a compromised structure is a danger to every person and animal inside or beside it.

No one is predicting a collapse tomorrow. That is precisely the point of prevention: the entire purpose of the substandard-building statutes is to compel repair before deterioration becomes catastrophe. The Legislature did not write section 17980 to be invoked after a wall fails. It wrote it to prevent the failure. A city that receives documented notice of active, recurring water intrusion against structural elements — and responds by inspecting the wrong building and manufacturing a refusal — is not managing that risk. It is running out the clock on it.

The People Accountable

Accountability for how a city handles a safety complaint runs to named offices, and West Hollywood’s are a matter of public record.

Steve Campbell, Assistant City Manager, is the official the City designated as the property owner’s sole point of contact and the author of the emails at the center of this account — including the one scheduling an inspection of the wrong building and the one recasting the owner’s correction as a “denial.” He is, by the City’s own instruction, the person responsible for moving this matter. On this record, he has moved it in the wrong direction.

Mayor John Heilman presides over the City in 2026. Heilman is not an ordinary elected official when it comes to this subject: a founder of the City who has served as mayor nine times, he holds a law degree from USC and teaches law as a professor at Southwestern Law School and USC. A city led by a law professor cannot credibly claim that the mandatory language of section 17980 — the word “shall” — is beyond its comprehension. The standard of understanding that West Hollywood should be held to is the one its own Mayor teaches in a classroom.

City Manager Jackie Rocco, appointed in 2026, sits atop the administration that received the complaint and the records request. When the Mayor installed her, he publicly stated that the Council must “hold staff accountable.” This matter is a test of whether that phrase means anything.

The Question West Hollywood Must Answer

Strip away the back-and-forth and one question remains, and it is not rhetorical. A property owner delivered documented notice of a recurring, structure-threatening hazard, in the precise language of the statutes that govern it. The City had every tool it needed to act. Why, after all of that, did West Hollywood point its inspectors at the wrong building and prepare to close the file by calling the complainant uncooperative?

And the larger question, for a city of tens of thousands: if this is how West Hollywood treats a property owner who did everything right — who wrote it down, cited the code, and put the City on notice — what happens to the residents who do not know the statutes by number? Prevention is not a favor a city grants when it feels like it. Under California law, it is a duty. West Hollywood, so far, is failing that duty in writing.

This guy Steve cannot seem to get the offending neighbor inspected for his water intrusion. Posing an ongoing risk to us for his dereliction of duties and incompetence at reading mixed with his passive aggressive attitude.

Editor’s note: Statements attributed to the property owner or to his demand and correspondence reflect his account and documentary materials, including the email record and a recorded voicemail, which Good Shepherd Media has reviewed as provided and reports as his account. Statutory text, case law, and public records concerning City offices and officials are drawn from primary and government sources. Named public officials are discussed solely in their official capacities. Nothing in this article states or implies that a structural failure is imminent; the discussion of structural risk describes the general, foreseeable progression of unabated water intrusion and the preventive purpose of the governing statutes.

© Good Shepherd Media. goodshepherdmedia.net