Untitled Texas Attorney General Opinion

The Attorney’ General of Texas S~zptember22, 1986 JIM MATTOX Attorney General Supreme Court Building Mr. Joseph C. Gagen Opinion No. JM-549 P. 0. Box 12546 Austin. TX. 76711. 2546 Chairman 51214752501 Texas Industrial Acc.LdentBoard Re: Whether the Industrial Accident' Telex 9101674-1367 105 W. Riverside Drive Board is entitled to interest Telecopier 5121475-0266 Austin, Texas 78700 earned in the Compensation to Victims of Crime Fund 714 Jackson, Suite 700 Dallas. TX. 75202-4506 Dear Mr. Gagen: 2141742-6944 Article 8309-I., V.T.C.S., the Crime Victims Compensation Act, creates at section 14 the Victims of Crime Compensation Fund "in the 4624 Alberta Ave., Suite 160 El Paso. TX. 79905.2793 state treasury," which is to be used by the Industrial Accident Board 915/533-3464 for the payment of compensation to claimants. Revenues for the fur.d are derived from additional court costs imposed by the act upon persons convicted of certain offenses. The act specifically prohibits 91 Tex’as, Suite 700 the payment of general revenues to persons seeking compensation under ,ston, TX. 77002-3111 the act. You ask tne following question: , ,Y223-5666 Is the Industrial Accident Board entitled to have 606 Broadway. Suite 312 the interest earned on the Compensation to Victims Lubbock, TX. 79401.3479 of Crime Fund deposited in the Fund? 6061747.5236 We answer your qc,estion in the negative; we conclude that such 4309 N. Tenth, Suite B interest must be deposited in the General Revenue Fund. McAllen, TX. 76501~1666 512l682-4547 Article VIII, section 7, of the Texas Constitution provides the following: 200 Main Plaza. Suite 400 San Antonio, TX. 76205.2797 The Legislature shall not have power to borrow, or 512/225-4191 in any manner divert from its purpose. any special fund that may, or ought to, come into the Treasury; An Equal Opportunity/ and shall make it penal for any person or persons Afflrmatlve Action Employer to borrow, withhold or in any manner to divert from its purpose any special fund, or any part thereof. Article VIII, section 7, has been construed to require that interest on constitxionally dedicated funds may be spent only for the purposes for which the funds were created; a diversion of such interest to other purposes would violate the constitution. Lawson v. m, 220 S.W. 26t1,272 (Tex. Civ. App. - Austin 1920, writ ref'd). Consequently, interest earned on a constitutional fund must be credited to that fund, UdSSS the constitution itself otherwise directs. Attorney General Opinions JM-323, JM-321 (1985); M-468 p. 2430 Mr. Joseph C. Gagen - Page 2 (JM-549) (1969). The interest on state funds dedicated by statute, however, may be legally severed and placed in the general fund. -- See Gulf Insurance Co. v. James, 18!5 S.W.Zd 966 (Tex. 1945) (article VIII, section 7, of the Texas Constitution applies only to special funds created by the constitution, not by--statute);- Attorney General Opinions JF-323, JM-321 (l!l85);Mw-338 (1981); see also Brazos River Conservation & Reclamation~District v. McGraw, 91 S.W.2d 665, 674 (Tex. 1936) (article VIII, section 7, does not apply to general revenue funds). Article 2543d (since repealed and re-codified as section 3.042(a) of article 4393-1, V.T.C.S.) effects such a severanqe of interest on statutory funds as a general rule. Section 3.042(a) of article 4393-1, V.T.C.S., the article that sets forth the powers and duties of the state treasurer, provides the following: Interest received from time deposits of money in funds and accounts in the charae of the treasurer shall be allocated as follows: to each constitu- tional fund there: shall be credited the pro rata portion of the i&rest received due the fund; the remainder of thi interest received, with the excention of that nortion required bv other statutes to be credited on a pro rata basis to protested tax payments, shall be credited to the General Revenue Fund. The interest received shall be allocated on--a monthly basis. (Emphasis added). The funds about which you inquire are not constitutionally dedicated funds; rather, they are statutory funds. Consequently, pursuant to section 3.042(a), the interest on such funds would normally be credited to the General Rerenue Fund. However, the rule with regard to the disposition of intere:stearned by the deposit of trust funds is different. This office previously has determined that the provisions of what is now section 3.042(a) of .article4393-1, V.T.C.S., do not apply to interest earned on trust funds that are not the property of the state and that the state treastrcer holds as trustee out of the state treasury. Opinions issued by this office consistently have maintained that interest on such trust funds becomes part of the principal and, consequently, part of the fund that generated the interest. See Attorney General Opinions :I+306, JM-300 (1985); MU-82 (1979); H-1040 (1977); M-468 (1969). Cf. Attorney General Opinions MW-338 (1981); H-1187 (1978). The adopxn of such a doctrine is strongly supported by language set forth in section 4.003 of article 4393-1, V.T.C.S., setting forth exemptions to the reach of the act and providing at subsection (b) the following: "This chapter does not apply to: . . . (2) funds held in trust or escrow for the benefit of a person or entity other thm a state agency." The issue, then, is p. 2431 Mr. Joseph C. Gagen - Page 3 (JM-549) whether the funds about which you inquire are trust funds, as opposed to statutory funds. We conolude that they are statutory funds. The opinions cited abrre indicate that in order to be charac- terized as trust funds, the funds in question should reflect, among other things, (1) that they are administered by a trustee or trustees, (2) that the funds neither are granted to the state in its sovereign capacity nor collected for t~hegeneral operation of state government, and (3) that they are to bsz spent and invested for specific, limited purposes and for the benefit of a specific group of individuals. Being in the nature of a trust, such funds are entitled to retain the proceeds from their investment. Attorney General Opinions MW-481 (1982); M-468 (1969). It :.E; clear from a reading of article 8309-1, V.T.C.S.,.that the funds atout which you inquire fail to exhibit the requisite trust characteristics and are thereby statutory funds whose earned interest must be cretllited to the General Revenue Fund. Section 14 of the act :)rovidesthe following in pertinent part: Sec. 14. (a) The Compensation to Victims of Crime Fund is created in the State Treasury to be used by the board-for the payment of compensation to claimants under this Act and other expenses in administering th& Act. The Compensation to Victims of Crime &xiliary Fund is created in the State Treasury tc-be used by the board only for the payment of '%mpensation to claimants under this Act. The board shall make no compensation payments which exceed the amount of money in the combined funds. 30 general revenues may be used for payments unde:Lthis Act. (b) A person s!aallpay $20 as a court cost on conviction of any felony, $15 as a court cost on conviction of a misdemeanor punishable by impri- sonment or by a fine of more than $200, and $3 as a court cost, <'IIconviction of a misdemeanor punishable by a fine of not more than $200, other than a misdemeanor that regulates pedestrians and the parking of motor vehicles. . . . The court shall require a pIerson convicted of an offense listed under this section to pay the court cost whether or not the court grants the person a probated sentence. If a person is granted deferred adjudication under Article 42.12, 42.13, or 45.54, Code of Criminal Procedure, 1965, as amended, at the time the court grants deferred adjudication, the person shall pay as a court cost the amount that the person would have otherwise been required to 'payunder this subsection had the p. 2432 Mr. Joseph C. Gagen - Page 1; (JM-549) adjudication not 'lee*deferred and had the person been finally conv:.ctedof the offense. (c) Court costs under this section are collected in the .same manner as other fines or costs. (d) The officer collecting the costs in a municipal court case shall keep separate records of the funds collezted as costs under this section and shall deposft the funds in the municipal treasury. The officer collecting the costs in a justice. county, or district court case shall keep separate records DE the funds collected as costs under this sectlo:;and shall deposit the funds in the county treasmy:. Text of (e) as amended by Acts 1983, 68th Leg., p. 1739, ch. 335,12 (e) On receipt, the custodian of a municipal or county treasur]'may deposit the funds collected under this secticn in interest-bearing accounts. The custodian sha:tl. keep records of the amount of funds on deposit rollected under this section and shall remit to the comptroller of public accounts before the 10th day of each month the funds collected under this section during the preceding month. The city and the county may retain five percent of the fuais collected under this section as a collection fee. The city or county may also retain all intereritaccrued on the funds. , Text of (e) as amended by Acts 1983, 68th Leg., p. 2764, ch. 475.11 -- (e) The custodian of a municipal or county treasury shall keep records of the amount of funds on deposit collec,:edunder this section and shall remit to the comptroller of public accounts before the last day of each calendar quarter the funds collected under this section during the preceding quarter. The city and the county may retain 10 percent of the furds collected under this section as a collection Eoe. If no funds due as costs under this sectien have been collected in a quarter, the report required for the quarter shall be filed in the regular manner, and the report must state that no funds due under this section ---. were collected. p. 2433 Mr. Joseph C. Gagen - Page 5 (JM-549) (f) The compt:rollerof public accounts shall deposit the funds received by him or her under this section in y:he Compensation to Victims of Crime Fund. Funis collected are subject to audit by the comptrolle; and funds expended are subject to audit by the State Auditor. (Emphasis added). Unlike, for example, the funds created under articles 1066c, 1118x, lllSy, 5221b-7. and 6243e. V.T.C.S. (which govern local sales and use tax, metropolitnn rapid transit authorities, regional transportation authoritier., unemployinent compensation, and fire fighters' relief and retirement, respectively), the funds created under the Crime Victims CclmpensationAct do not manifest sufficient trust fund characteristics;. See Attorney General Opinions JM-539 (19861,;JM-323, JM-321, JM-,306(1985). The act does not provide that the funds are to be administered by a trustee or trustees or by any public officer "in trust"; rather, the act specifies that the fund "is created in the State Treasury." It is the case, of course, that the act does not specify that the funds are granted to the state in its sovereign capacity, that the act specifies rather that such funds be paid only as compensation to claimants under the act; but the language so earmarking the funds Liffers in no material way from language typically found in the Appropriations Act directing the expenditure of state funds. Further, the act does not specify that the funds be held for a specific or identifiable group of individuals; in this instance, the group entitled to claim compensation consists of an open-ended, indefinite class. We conclude that the funds created pursuant to article 8309-1, V.T.C.S., the Crime Victins Compensation Act, are statutory funds. Accordingly, we conclude that the Victims of Crime Compensation Fund is not entitled to be cred:.tedwith interest earned by deposit of its funds; article 4393-1, sect,ion3.042(a), V.T.C.S., requires that such interest be credited to the General Revenue Fund. SUMMARY The Victims o:i Crime Compensation Fund is not entitled to be credited with interest earned by deposit of its funds; article 4393-1, section 3.042(a), V.T.C.S., requires that such interest be credited to the General Revenue Fund. d Very truly yours, A.-k JIM MATTOX Attorney General of Texas p. 2434 Mr. Joseph C. Gagen - Page j (JM-549) JACK HIGHTOWER First Assistant Attorney Ge:wral MARY KELLER Executive Assistant Attome:{ General RICK GILPIN Chairman, Opinion Committee Prepared by Jim Moellinger Assistant Attorney General -.. p. 2435