Untitled Texas Attorney General Opinion

THE ATTORNEY GENERAL OF TEXAS December 19, 1989 Honorable Jesusa Sanchez-Vera Opinion No. JM-1120 Jim Wells County Attorney P. 0. Drawer 2080 Re: Whether a commissioners Alice, Texas 78333 court may authorize a justice of the peace to retain a por- tion of assessed fines for the purpose of funding addi- tional positions (RQ-1851) Dear Ms. Sanchez-Vera: You ask whether a justice of the peace may, with the authorization and approval of the commissioners court, assess a $50 fine in a Class C misdemeanor "bad check" case and retain a portion of the fine to pay the salary of an additional employee in his office. You advise that a justice of the peace "is swamped with hot checks under $20.00" and the commissioners court refuses to provide additional help for the office. The justice requests the authorization and approval of the commissioners court to assess each hot check violator a fine of $50 and retain a portion of the fine to pay the salary of an addi- tional employee for his office. Section 112.052 of the Local Government Code provides that a fine imposed by a justice of the peace shall be charged against the justice. Subsection (b) of sect:.; 112.052 provides that the justice may discharge indebtedness by filing a county treasurer's receipt for the amount with the county clerk, showing to the satisfaction of the commissioners court that the justice has used due diligence in an attempt to collect the fine, or showing that the fine has been satisfied by imprisonment or labor.1 1. The United States Supreme Court in Tate v. Short, 401 U.S. 395 (1971) held that a defendant may not .be imprisoned because he is too poor to pay his fine. & Attorney General Opinion JM-977 (1988). P. 5888 Honorable Jesusa Sanchez-Vera - Page 2 (JM-1120) Commissioners courts may exercise only such powers as are specifically conferred upon them by the constitution or the statutes. Canales v. Laughlin, 214 S.W.2d 451, 453 (Tex. 1948); see Tex. Const. art. V, § 18. Neither the constitution nor the statutes empower the commissioners court with authority to allow a justice of the peace to retain a portion of fines assessed to hire an additional employee. To permit a justice of the peace to assess a minimum fine of $50 in every Class C misdemeanor hot check case to pay the salary of an employee would also violate the United States and Texas Constitutions. Section 12.23 of the Penal Code provides that a person adjudged guilty of a Class C misdemeanor shall be punished by a fine not to exceed $200. The system under consideration would make the penalty in a Class C misdemeanor hot check case in Jim Wells County a fine of not less than $50 nor more than $200. In Attorney General Opinion JM-880 (1988) a statute allowing a commis- sioners court to set fees in misdemeanor cases was found unconstitutional. Attorney General Opinion JM-880 stated: In Texas, costs in misdemeanor criminal cases are assessed as part of the punishment. Ex Dar-, 159 S.W.2d 126 (Tex. Crim. App. 1942): Ex aarte Mann, 46 S.W. 828 (Tex. Crim. App. 1898). See also Attorney General ",ifh~;n JM-443 (1986). Cf. United States v. 809 F.2d 1504 (11th Cir. (hold&g imposition of costs as punishmeAz8:b be constitutional). A law allowing different costs to be assessed in different counties for the same penal offense would have the effect of allowing the aenaltv for state- defined crimes to varv from countv to county and would violate both 'due nrocess' and 'equal urotection' constitutional rishts. U.S. Const., 5th Amend., 14th Amend.: Tex. Const., art. suora. See Meiet":: iziteEX 6~~'~eW.~~'"~?~ -- (Tex. App. Houston [14th bist.] 1982, pet. ref'd). See also Ex Parte Fercuson, 132 S.W.2d 408 (Tex. Crim. APP. 1939); Ex uarte Sizemore, 8 S.W.2d 134 (Tex. Crim. App. 1928). (Emphasis added.) Id. at 3. Assessment of a minimum $50 fine in every Class C misdemeanor hot check case in order to defray the cost of an additional employee would result in the penalty for a state defined crime to be different in Jim Wells County than it is in other counties and would violate both "due process" and "equal protection" constitutional rights. P. 5889 Honorable Jesusa Sanchez-Vera - Page 3 (JM-1120) SUMMARY A countv commissioners court mav not authorize a-justice of the peace to retain a portion of assessed fines for the purposes of funding an additional employee. JIM MATTOX Attorney General of Texas MARY KELLER First Assistant Attorney General LOU MCCREARY Executive Assistant Attorney General JUDGE ZOLLIE STEAKLEY Special Assistant Attorney General RICK GILPIN Chairman, Opinion Committee Prepared by Tom G. Davis Assistant Attorney General P. 5890