Circuit Court for Multnomah County Parking Tag Office

PO Box 78

Portland, OR 97207-0178

Re: Parking Violation #HA00696951

On October 5, 2006, I returned to my car after an evening class to find I had been issued a parking citation for 90% blocking the crosswalk on NW Overton Street at 23rd Avenue.

Since there are no crosswalk lines painted on the street at that location, and the curb carries no yellow markings, I used my best judgment to determine whether I could park in that location. Reasoning that the wheelchair ramp must define the location of the crosswalk, I made sure that my car was in no way obstructing the ramp. To the best of my knowledge, it appeared that my car was parked appropriately.

After discovering the citation and before moving the vehicle, I took the enclosed photographs. View #1 shows the location of the wheelchair ramp (the scored section of pavement) in relation to the rear bumper. The other two photographs were taken from other angles which, combined with the first, should make it clear to the viewer that the rear of my vehicle was definitely outside the bounds of the wheelchair ramp.

Since the ramp itself must, for reasons of safety, be entirely inside the limits of the crosswalk, and since the deputy issuing the citation stated that the crosswalk was 90% blocked by my vehicle, one must assume that the ramp falls within the 10% of the crosswalk that was not blocked. Although I did not have a tape measure handy, by conservative estimate I would say the wheelchair ramp at that location is approximately 3.5 feet wide. This means the crosswalk would have to be 35 feet wide in order for 90% of it to be blocked without obstructing the wheelchair ramp. My vehicle would have to be over 31 feet long to accomplish this. I am contesting this citation, therefore, on the grounds that it is physically impossible for me to have 90% blocked the crosswalk with my 12-foot-long ’91 Mazda Protegé without blocking any portion of the wheelchair access ramp.

Thank you for taking the time to consider my explanation.