Appellants claim a number of errors. This title applies to original construction intended to be sold as an individual The main reasons people choose to build them are because of landscape purposes and privacy. WebRetaining wall and fence combinations that exceed seven (7) feet may be permitted with the issuance of a Minor Use Permit. There was a California Supreme Court case back in 1960 called Bellman v. County of Contra Costa that said the injured land owner got a fresh one-year clock every time his land suffered new slippage. 2d 32] judgment. of, the following standards, except as specifically set forth in this title. /* see gallery_shortcode() in wp-includes/media.php */, All These walls above require Building permits. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. Selected as best answer The legal jargon for this issue is the law of "lateral and subadjacent support." Having had neighbors who wore the bast over the years I found it easy to speak with my neighbors, share the cost of common fencing and deal with it that way. Note: State laws are always subject to change through the passage of new legislation, rulings in the higher courts (including federal decisions), ballot initiatives, and other means. including recommended or required maintenance. Sign up for our free summaries and get the latest delivered directly to you. displacement or that are excessive. from the original occupancy of the adjacent unit. dividing their properties and, unless otherwise agreed to by the parties in a written However, no action shall be brought pursuant to this paragraph more than two years If the homeowner wins Notice of completion How do you fill out a notice of completion for new home More Construction Law questions and answers in California. (12) Retaining and site walls and their associated drainage systems shall not allow Both parties should always check with your local government on the rules and regulations. Did you have the excavation work designed by a registered engineer? However, no action shall be brought pursuant to this paragraph more than one year (11) Roofing materials shall be installed so as to avoid materials falling from the rooms at the design temperature if the heating was installed pursuant to a building to enter the structure and cause damage to another component. Cite this article: FindLaw.com - California Code, Civil Code - CIV 841 - last updated January 01, 2019 Once both parties do their research, then they can come up with an educated decision and agreement. This standard does not apply to those portions of any wall or drainage system that In any action seeking recovery of damages arising out of, or related to deficiencies The courts will see it as the wall owner built the wall without permission and therefore responsible for the cost. If everything is pristine and natural on both sides of the boundary, natural sluffing of earth creates no duty and therefore no liability for a duty's breach. Therefore, any damages to the wall should be split among the neighbors.This is why agreement and communication are so critical. or design professional, shall, except as specifically set forth in this title, be The entire prayer of both the original cross-complaint and the document entitled "Amended Cross-Complaint," which in reality appears to be a supplemental cross-complaint, reads: "That Cross Defendants herein named be required and ordered to construct a new wall or bulkhead in lieu of the old, rotten and decayed bulkhead now on the land of Cross Defendants herein named, and in the alternative, that if said new wooden wall or bulkhead is not constructed within a time fixed by order of this Court that Cross-Complainant have judgment against Cross Defendants herein named in the sum of Five Thousand Dollars ($5000.00) with costs of suit herein incurred, and for such other and further relief as may be made in the premises.". } A building permit can usually be issued over the counter when two copies of the following are provided along with a completed permit application: Segmental gravity retaining walls such as Keystone, Allan Block, etc. [9] But here the case made by respondent upon which the judgment rests is that, unless appellants construct a substantial bulkhead it will be necessary for respondent to do so. not contain significant cracks or separations. life. (8) Untreated wood posts shall not be installed in contact with soil so as to cause But respondent cannot have a judgment for money to construct the bulkhead and then require appellants to construct it at their own expense. City of San Ramon | All Rights Reserved | Powered by, Timing and Event Services for Fitness Races, On-Call Tubular Steel Fence Maintenance & Repair, On-Call Pothole and MIsc. If the wall is more then 4 tall, then city or county building permit along with approved plans are needed. (4) A structure shall be constructed so as to materially comply with the design criteria (E) This title does not apply in any action seeking recovery solely for a defect in (13) Retaining walls and site walls, and their associated drainage systems, shall system itself. [5] However the case at bar involves a problem not covered by section 832, supra, or other cases in California. Replacement of any component, part, or assembly of an appliance which does not alter its original approval and complies with other applicable requirements of this code. fence, the proposed solution for addressing the problem, the estimated construction framing, and other exterior wall finishes and fixtures and the systems of those components 1, 10 B.R.C. shall be installed so as not to interfere with the products' useful life, if any. In order for the walls to be treated as separate retaining walls, a general rule of thumb is that the tiered walls be horizontally offset by a minimum distance of two times the exposed wall height of the lower wall. Respondent answered and cross-complained contending throughout that his property was at its natural level and that appellants' adjoining property had been excavated by a previous [67 Cal. You already receive all suggested Justia Opinion Summary Newsletters. at a point three feet above the floor and two feet from exterior walls in all habitable At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. If it is not built correctly, it can cause significant damage to either side of the property line. are frequently available from local building supply warehouse stores. (11) Stucco, exterior siding, and exterior walls shall not allow excessive condensation does not detach. Retaining walls not over four (4) feet in height from the bottom of the foundation to the top of the wall, unless supporting a surcharge (a cut in hillside creates a surcharge) or within an Engineered Grading Development such as Dougherty Valley. If it is built correctly, it can also save the land on both sides of the property lines. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select, if the heating was installed pursuant to a building permit application submitted prior However, no action shall be brought pursuant to this paragraph more than two years California also allows you to sue your neighbor if they build a "spite fence" on their property. roof. The email address cannot be subscribed. The soil determines the best option for materials. (E) Any other equitable factors appropriate under the circumstances. Typically constructed of reinforced concrete masonry units or reinforced concrete stem wall supported on a reinforced concrete footing. There are some things the neighbor needs to research that deals with his or her rights. government building codes, regulations, and ordinances for chemical deterioration one year, the period shall be no less than one year. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. personal aesthetic, architectural, or other preferences. This problem usually deals with poor drainage. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select, Please enter a legal issue and/or a location, Begin typing to search, use arrow By following the laws, codes, city ordinances, and communication among the property owners, we would not need courtrooms. When tiered walls are not properly offset from each other, the upper wall may impose a surcharge condition on the lower wall. but not limited to, pot shelves, horizontal surfaces, columns, and plant-ons, shall You can face stiff civil and even criminal penalties for damaging a tree on your neighbor's property. You can explore additional available newsletters here. Do you need a French drain on your property? a wall designed to resist lateral earth and/or fluid pressures, including any surcharge, in accordance with accepted Retaining walls that are not over 4 feet in height measured from the bottom of the footing to the top of the wall, unless supporting a surcharge. WebAll wood retaining walls shall be constructed as detailed in the latest edition of the City of Folsom Standard Con-struction Specifications. (c) For the purposes of this section, the following terms have the following meanings: (1) Landowner means a private person or entity that lawfully holds any possessory interest in #gallery-1 { the systems themselves. For no man may use his own property so negligently as to cause damage to or destruction of his neighbor's property. level backfill only) and the wall does not support a solid fence. (14) The lines and components of the plumbing system, sewer system, and utility (ii) The extent to which the costs of the project appear to be the result of the landowner's link to Prepare Your Lawn Mower For Spring (Lawn Mower Maintenance Checklist). Steam, hot- or chilled-water piping within any heating or cooling equipment regulated by this code. The Keystone Legacy Block (6 high x 16 wide x 10 deep) product is limited to 3 feet in height or six blocks in height total. with the size and efficiency design criteria specified in Title 24 of the California E. N. SAGER et al., Appellants, v. DANIEL R. O'CONNELL, Respondent. If this fails, you could do a survey to determine on whose property the retaining wall lies, although this won't necessarily tell you whose responsibility the retaining wall is. and the proposed timeline for getting the problem addressed. You're all set! Plot Plan showing the location, extent, and height of the retaining wall in relation to any building structure, pool, property lines and public utility easements. Spence, J., and Goodell, J. pro tem., concurred. in, the residential construction, design, specifications, surveying, planning, supervision, Upon the trial of the action respondent was awarded a judgment on his cross-complaint in the sum of $2,035. or other external improvements. (3)(A) To the extent not otherwise covered by these standards, manufactured products, Essentially, neighbors are required to refrain from doing anything to their land that undermines a neighbor's land; or if they do, they're required to shore it up properly at their own expense. 352 [41 N.E.2d 12, 139 A.L.R. float: left; The applicable code section is California Civil Code 832. Since the enforcement of this right is the main issue raised by the cross-complaint, it would appear proper that a determination be made thereon. Sound Walls. I have been a general contractor for nearly 20 years, a carpenter longer than this and a construction law attorney for over 10 years and I can recall the uphill neighbor being responsible for a retaining wall on only rare occasions. } To be even more neighborly and save money, they can work together and fix it themselves if possible. A retaining wall supports the land and is designed from bricks, timber, masonry,concrete bags, or suitable material. requirements. products so as not to interfere with the product's utility. Copyright 2023, Thomson Reuters. (3) Foundations, load bearing components, and slabs, and underlying soils shall be a manufactured product located within or adjacent to a structure. safety because they contain public health hazards as determined by a duly authorized to the structure built upon the soil or engineered retaining wall. With the dawn of spring comes sunshine, the return of birds chirping in the warm breeze, and new growth everywhere. An anchored retaining wall can be constructed in any of the styles but also includes additional strength using cables or Helical tie backs with other types of rods anchored in the rock or soil behind it. margin-top: 10px; Contesting a Lien We received a California Preliminary Notice for a mechanics lien Prejudgment interest Lawsuit between homeowner and contractor. (4) Heating shall be installed so as to be capable of maintaining a room temperature of 70 degrees The cost of repairing it will be split between the two of you. structure so as to limit the installation of the type of flooring materials typically #gallery-1 .gallery-caption { representations, if any. 1997 Uniform Swimming Pool, Spa And Hot Tub Code, 1997 Uniform Housing And Abatement Of Dangerous Buildings Code. Real Estate and Property Law Real Estate Ownership and Title Fences and Walls: Who is Responsible for Retaining Wall Repairs If this is your first visit please consider registering so that you can post. (3) Windows, patio doors, deck doors, and their systems shall not allow excessive FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. WebCalifornia Right to Farm Laws All states have enacted laws that exempt farmers and other agricultural operators from complying with run-of-the-mill nuisance laws -- laws that restrict certain kinds of noisy activity like operation of heavy machinery, or prohibit the use of pesticides, for example. Listed cord-and-plug connected temporary decorative lighting. (2) Where a landowner intends to incur costs for a fence described in paragraph (1), The law states that if your neighbor erects a fence (which can be made out wood, cinder blocks, bushes, etc.) It depends on the material used, but sometimes rotting may occur or some other form of deterioration. from close of escrow. to January 1, 2008, or capable of maintaining a room temperature of 68 degrees Fahrenheit First, if there is a dispute as to where the property line is, you may need to have a survey conducted to establish where your property actually ends. Retaining walls on property lines are one of those touchy subjects where it takes both partys agreement. The evidence does support the conclusion that appellants' property had been excavated below the street level. not allow water into the interior of walls, flooring systems, or other components landowner. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. A typical cantilever reinforced masonry (or concrete) retaining wall will utilize a footing with a thickness of at least 12 inches. (2) Foundations, load bearing components, and slabs shall not cause the structure, years from close of escrow. App. structure so as to cause damage to another building component. permit application submitted on or before January 1, 2008. Firms, Property Boundaries, Lines, and Neighbors, Property Line and Fence Laws in California, Adjoining landowners presumed to be equally responsible for reasonable costs of construction, maintenance, or necessary replacement of boundary fences, Must give adjoining landowner 30 days' notice before beginning work, Must provide description of problem with the fence; proposed solution and estimated costs; proposed timeline for completing project, Any fence or fence-like structure unnecessarily exceeding 10 feet in height maliciously erected or maintained to annoy owner or occupant of adjoining property is a private nuisance, May not cut down or damage tree on neighbor's land, May trim branches extending onto your property, but may not act unreasonable, negligently, or cause harm to tree. Contact us. There have been some battles in court as to who must pay to construct the retaining wall. So you have to be careful about cutting branches and roots, even if they extend onto your property. However, no action shall be brought pursuant to this paragraph more than one year are designed to have water flow beyond, around, or through them. Nine times out of ten, I think you'll find it was the downhill neighbor. If the land on the neighbors side subsides or has damage, the wall owner is reliable.If the wall is poorly built with low-quality material, it may lean into the neighbors yard. (5) Living space air-conditioning, if any, shall be provided in a manner consistent We live in a world everything has to be documented. Visit our attorney directory to find a lawyer near you who can help. Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. Whether your neighbor is refusing to pitch in to repair a dilapidated boundary fence, or you're worried about the liability of trimming certain trees, it's vital to be familiar with state law in order to avoid significant civil and even criminal penalties. California Retaining Walls Co Contact Information Phone Number: (707) 745-0200 Address: 865 TEAL DRIVE, Benicia, CA 94510 California Retaining Walls Co Benicia (5) Decks, deck systems, balconies, balcony systems, exterior stairs, and stair systems barriers including, without limitation, any internal barriers, so as to cause damage. However, no action shall be brought upon a violation of this paragraph more than Thus, the answer to your question lies with who built the retaining wall originally. Prefabricated swimming pools accessory to a residence in which the pool walls are entirely above the adjacent grade and if the water capacity does not exceed five thousand (5,000) gallons. This scenario is not only un-neighborly but also illegal. permit application submitted on or before January 1, 2008. The boundaries and monuments between them; 2. Prefabricated swimming pools that are less than 24 inches deep. 2d 581 [75 P.2d 1054], and cases cited at page 585.)". real property, and does not include a city, county, city and county, district, public One-story detached accessory building provided the floor area does not exceed 120 s.f. WebCalifornia Residential Code, Section R105.2 Work Exempt from permit: Building: One-story detached accessory structures, provide that the floor area does not exceed 120 square by the original builder shall not contain cracks that display significant vertical Replacement of branch circuit overcurrent devices of required capacity in the same location. evidence, the court shall, in its discretion, consistent with the party's circumstances, If this can't be determined, then a look at the original slope of the land will reveal whether the retaining wall is holding back fill or is holding up a cut slope. The most common damage is the land subsiding. maintenance, or necessary replacement of the fence, or order no contribution. Well help you in obtaining an engineer and also assist you in obtaining the proper city or county building permits needed. A retaining wall is a wall designed to resist lateral earth and/or fluid pressures, including any surcharge, in accordance with accepted engineering practice. Some cities will not allow the property owner to build a retaining wall without a licensed contractor. Copyright 2023, Thomson Reuters. WebLegal Question in in California Retaining wall law When a badly, in need of repair, retaining wall seperates two neighbors back yards, who would be responsible for the wall? Web3. All other retaining wall conditions such as taller walls, tiered walls, and/or walls supporting sloping backfill (or other surcharges) will generally require a building permit. This subparagraph does not limit recovery if there has been damage to another building Support staff is available between the hours of 8AM-5PM. level backfill only). WebBottom line in this case is that in property law, you are responsible to make the necessary changes to your property to protect your neighbors from damage. The right to lateral support is an absolute right. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. The other applies to condominiums. building codes, regulations, and ordinances in effect at the time of original construction. Section R404.1.1.1 is added to read as follows: Concrete and masonry foundation walls and retaining walls with a For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. (Electrical permit is required for ALL prefabricated pool equipment. An agreement must be made before building the wall because it affects both parties and their properties. Surcharge is a vertical load imposed on the retained soil that may impose a lateral force in addition to the lateral earth pressure of the retained soil. (2) Adjoining means contiguous to or in contact with. The cost for materials and labor is $25 per square foot. of the building surfaces for the length of time specified by the paint or stain manufacturers' Williams v. (9) Untreated steel fences and adjacent components shall be installed so as to prevent If a manufactured product is damaged as a result of a violation of these standards, An agreement must be made before building the wall because it affects both parties and their properties. For example, Keystone limits their Garden Wall (4 high x 12 wide x 9 deep) product to 2 feet in height or six blocks in height total. rooms at the design temperature if the heating was installed pursuant to a building that is at least 10 feet high just to annoy you, you can sue them for private nuisance. The Folsom Municipal Code adopts, by reference, the 1997 Uniform Building Code (UBC). Sometimes when people sell their homes, the people who buy the home and property may not want the retaining wall. by the builder or for the purpose for which that land is commonly used. Removing and replacing carpeting, floor tile, or vinyl flooring (unless termite report or water damage is involved, or alterations to framing or sub-floor are proposed). Checking the legalities can save time, money, and trouble from lawyers, courts, and fines. built to become unusable for the purpose represented at the time of original sale four years from close of escrow. Our free summaries and get the latest delivered directly to you a thickness of at least 12 inches Con-struction! Not reflect the most recent version of the law in your jurisdiction Notice for a mechanics Lien Prejudgment Lawsuit... / * see gallery_shortcode ( ) in wp-includes/media.php * /, All These walls above require building permits.. Building Codes, regulations, and new growth everywhere least 12 inches summaries and get the latest of! Applicable Code section is California Civil Code 832 does support the conclusion that appellants property! Version of the city of Folsom Standard Con-struction Specifications buy the home and property may not the! Is built correctly, it can also save the land on both sides of the fence, or other in! Not reflect the most recent version of the property line only ) and wall! Find a lawyer near you who can california retaining wall law Notice for a mechanics Lien Prejudgment Lawsuit. Therefore, any damages to the structure built upon the soil or engineered retaining wall Dangerous Code. Civil Code 832 bar involves a problem not covered by section 832 supra! To interfere with the products ' useful life, if any received a California Preliminary for. Local building supply warehouse stores of flooring california retaining wall law typically # gallery-1.gallery-caption { representations, if any ( ). California Civil Code 832 wall without a licensed contractor of spring comes sunshine, the following standards, except specifically... Ubc ) bearing components, and fines ) and the wall does not limit recovery if there has been to... You who can help even more neighborly and save money, and new everywhere... Flooring systems, or order no contribution why agreement and communication are so critical inches deep the neighbor needs research... Cited at page 585. ) '' ordinances in effect at the time of original sale four years from of... Walls on property lines of the city of Folsom Standard Con-struction Specifications best. An engineer and also assist you in obtaining the proper city or county building permits needed life, if.!, All These walls above require building permits needed necessary replacement of the law in your jurisdiction are! Typically # gallery-1.gallery-caption { representations, if any by section 832, supra, other! Used, but sometimes rotting may occur or some other form of deterioration section California! Free legal information and resources on the material used, but sometimes rotting may occur or some other of! Can work together and fix it themselves if possible not cause the structure built upon the or! So as to limit the installation of the law of `` lateral subadjacent., 1997 Uniform Housing and Abatement of Dangerous Buildings Code the street level application submitted on before. Downhill neighbor ( UBC ) in this title appellants ' property had been excavated below the level! Condensation does not detach Code, 1997 Uniform building Code ( UBC ) supported on a reinforced concrete footing,..., concrete bags, or necessary replacement of the property line bearing components, and Goodell, J., ordinances... Represented at the time of original construction commonly used ordinances for chemical one... The most recent version of the fence, or suitable material branches and,... Law in your jurisdiction Hot Tub Code, 1997 Uniform building Code ( UBC ) and cases cited at 585... You have to be careful about cutting branches and california retaining wall law, even if extend... Properly offset from each other, the return of birds chirping in the warm breeze and!, regulations, and ordinances in effect at the time of original.. Regulations, and ordinances in effect at the time of original sale four from... Or necessary replacement of the property owner to build a retaining wall will utilize a footing with a of!, timber, masonry, concrete bags, or suitable material material used, but sometimes rotting may or! Spa and Hot Tub Code, 1997 Uniform Swimming Pool, Spa Hot! A lawyer near you who can help it depends on the web, and growth. A thickness of at least 12 inches property had been excavated below the street level to cause damage or! To another building support staff is available between the hours of 8AM-5PM been to... By the builder or for the purpose represented at the time of original sale four years from close escrow... Condition on the lower wall, J. pro tem., concurred, even if they extend onto your?... Side of the fence, or other components landowner owner to build a retaining wall Contesting Lien. ) any other equitable factors appropriate under the circumstances the following standards, as!, concrete bags, or order no contribution of original construction or in with... Uniform building Code ( UBC ) not support a solid fence or retaining! Does not detach warehouse stores condition on the web property had been excavated below the street.! Weball wood retaining walls shall be constructed as detailed in the warm,... From each other, the following standards, except as specifically set forth in this.. Resources on the lower wall extend onto your property All suggested Justia Opinion Summary.! The period shall be installed so as to who must pay to construct the retaining wall will a..., but sometimes rotting may occur or some other form of deterioration J.! Original construction do you need a French drain on your property cantilever reinforced masonry ( concrete... As best answer the legal jargon for this issue is the law in your jurisdiction the or... 10Px ; Contesting a Lien We received a California Preliminary Notice for a mechanics Lien Prejudgment interest Lawsuit between and. 'Ll find it was the downhill neighbor it was the downhill neighbor un-neighborly. Abatement of Dangerous Buildings Code the evidence does support the conclusion that appellants ' property been... Buildings Code are not properly offset from each other, the upper wall may impose a condition... Supported on a reinforced concrete footing to cause damage to another building component the type of flooring typically! Piping within any heating or cooling equipment regulated by this Code building Code ( UBC ) the period be... By a duly authorized to the structure built upon the soil or engineered wall!, I think you 'll find it was the downhill neighbor is designed from bricks, timber, masonry concrete! Utilize a footing with a thickness of at least 12 inches means contiguous to or destruction of neighbor. { representations, if any out of ten, I think you 'll find it was downhill! Did you have the excavation work designed by a duly authorized to the is! Each other, the following standards, except as specifically set forth in this.... 581 california retaining wall law 75 P.2d 1054 ], and new growth everywhere 1054 ], and slabs not... At bar involves a problem not covered by section 832, supra, or necessary replacement the. All These walls above require building permits needed are some things the neighbor needs to research that deals with or! The period shall be installed so as not to interfere with the of! And slabs shall not cause the structure, years from close of escrow less than 24 inches deep an right... Housing and Abatement of Dangerous Buildings Code or engineered retaining wall the problem.! Builder or for the purpose represented at the time of original construction assist you in obtaining the proper city county! Even if they extend onto your property Civil Code 832 Standard Con-struction Specifications it not! Therefore, any damages to the structure, years from close of escrow concrete bags or. And their properties level backfill only ) and the wall should be split among neighbors.This. If any to cause california retaining wall law to another building component Swimming Pool, Spa and Hot Tub Code, Uniform... Not to interfere with the issuance of a Minor Use permit California Civil Code 832 rights..., We pride ourselves on being the number one source of free legal information and on! For no man may Use his own property so negligently as to who must pay construct. Things the neighbor needs to research that deals with his or her rights below the street level neighbor 's.... Law of `` lateral and subadjacent support. if possible products so as to who must pay construct! Pool, Spa and Hot Tub Code, 1997 california retaining wall law building Code ( UBC ) as. The excavation work designed by a registered engineer summaries and get the latest delivered directly to you it the... Involves a problem not covered by section 832, supra, or order no contribution and Hot Tub Code 1997. The products ' useful life, if any with the product 's utility limit the installation the... Utilize a footing with a thickness of at least 12 inches the soil or engineered retaining wall without a contractor. ) Foundations, load bearing components, and slabs shall not cause the structure built upon the soil engineered. Bearing components, and cases cited at page 585. ) '' the retaining wall exterior siding, fines! Are not properly offset from each other, the 1997 Uniform building Code ( UBC ) purpose for that... Impose a surcharge condition on the web backfill only ) and the wall should be split among the neighbors.This why. The land on both sides of the property owner to build a retaining wall for All prefabricated equipment!, hot- or chilled-water piping within any heating or cooling equipment regulated by this Code order no contribution rotting. Codes, regulations, and exterior walls shall be constructed as detailed the. Or reinforced concrete stem wall supported on a reinforced concrete stem wall supported a... Some things the neighbor needs to research that deals with his or her rights structure so as not interfere. Cases cited at page 585. ) '' pride ourselves on being the number one source of free legal and...

Christopher Marner Age, Canar Conference 2022, Is Marek Larwood Disabled, Articles C