Untitled Texas Attorney General Opinion

oili-TEXAS Au~~INH.TEKAS May 10,1965 Mr. J. W. Edgar No- c- 437 Commlsslonerof Education Texas Education Agency Re: Under the stated Austin, Texas facts, what Is the present llmltatlon In a Junlor College Mstrlct on the a- mount of tax which may be levied for Dear Mr. Edgar: all purposes? In your lette? of April 15, 965% you @ve requested ._ that the Attorney Qeneral answer the following questlon: "In light of Art. 2815h-3b, Sec..2 and the stated phrasing,of,the ~votedproposltlons,may the 'Junior College Mstrlct ln question anniaally levy: 1) for q alnteknce,of Its schools--O# on the 6100 valuations;and ln addition, (27 for the servlclng of bonds--notto exceed 504 on the $100 valuation?" The facts giving rise to the query, as reflected In your request, are that ln February 1962 there were submitted to the qualified voters of Hillsboro~JunlorCollege Mstrlct of HI11 and Navarro Counties, Texas, two propositions,pur- suant td the provisions of Article 2815h-3b, Vernon's Civil Statutes,.both of which carried ln the election. These two proposltlonswere as follows: "PROFOSITIONNUMEER1 "SHALL the Board of Trustees of RIILSBORO JUNIOR COLIZGEDISTRICTOFRILLANDNAVARRO COUNTIES, TEXAS, .havethe power to levy and collect an annual ad volorem -2078- .A Mr. J. W. Edgar, page 2 (C-437 ) taxnot to exceed !CRIRTYCENTS,(304) on the one hundred dollarsl valuationof taxable property within the Mstrlct for the maintenanceof schools therein, until the ssme shall be discontinuedas provided by law?"~, "PROPOSI!lTON NUMBER 2 "SRALLthe Board of !Prusteesof RILISl33ROJUNIOR COLLWE DISTRICT OF HILL AND ~NAVARROCOUNTIES, TEXAS, be authorized to Issue the bonds of said Mstrlct, to the ambuntof FOURHUN?~'FIFTY'JXOUSANDDOUiARS ~s$45WJ~;OO),to become due and payable serially : (The specificmaturity schedule was set'fGAh/ . . . . " and shall there be annually levied and colle%d*on all taxable property In said District for the current year and annually thereafterwhile said bonds or any of themare outstanding,a tax sufficientto pay the current.lntereston said bonds and the principal thereof as the same becomes duel"1 With this ln mind, then we turn to the real questions Involved here: (1) whether the maintenancetax and the bond tax provided for by Article 2815h-3b are to be voted separate- ly and independentlyof each, or (2) whetherthe amount voted for maintenancelimits the total taxing power of the district for both maintenance and borirposes, so that any bond'tax voted will decrease the amount availablefor maintenance. This office has written various opinions, the latest of which Is Oplnlon v-364 (1947),to which you refer ln your letter, on essentiallythls same question with regard to. 1 An Identical propositionwas held to authorize whatever tax rate was necessary,up to the legal maximum, Wllkerson v. Otto, 289 S.K2d 411 (Tex.Clv.App.19%) -2079- Mr. J. W. Edgar, page 3 (C-437 ) common and independent school districtsand concluded, based on the specific language of the statutesapplicable thereto, that the second of the above interpretationswas correct, lie., that the amount of the maintenance tax voted limited the total taxing power of the district for both maintenanceand bond purposes. However, the above mentioned opinion, asthe others which reached similar conclusions,Involved the interpretation of statutes other than Article 2815h-3b. The Supreme Court of Texas has construedArticle 2815h- 3b In the case of San Antonio Union Junior College Mstrict v. Daniel ,146 Tex. 241 206 S,W.2d 995,(1956) Theo llrt -Article 2815h:3b Is complete within itsel:. There- fore, that article Is exclusive as to matters regarding which Its own pmvlslons are clear, explicit and self-sufficient. Here we are concerned with the specific language used In Article 2815h-3b. In this regard, a portion 'ofSection 1 and all of Section 2a are pertinent and read as follows: "Section 1. From and after the passage of this Act, the governing boards of all public Junior Colleges organized,,createdand eatabllshedunder the laws of Texas, ln any manner, shall have power to Issue bonds for the constructionand eijutpment of schoal buildings and the acquisitionof sites therefor, and to protide for the interest and shklng ,Z'undfor such bonds by levying of such taxes as will be necessary in thla connection, subject to the limitationshereinafterimposed. Such governing boards shall also have power to 1eVy and collect taxes for theua and maintenance of such Junior Colleges,provided that no bonds shall be Issued and no taxes collecteduntil authorized by vote of the majority of the qualified voters of the Junior College Mstrlct In which such Junior College Is located, at an election called for that purpose In accordancewith the pro- visions of the General Iaw providing for similar elections ln Independent School Mstrlcts. The election for the issuance of such bonds; for the levylngof such tax or.taxes,shallbe ordered by 8UCh governlng boardiiponpetition signed by two hundred and flfty(250), or a majority, of the -2080- . . Mr. J. W. Edgar, page 4 (C-437 ) qualified property taxpaying voters residing in such dlsttict, praying for the Issuance of such bonds and/or the levying of such tax or taxea. . . ." (EInphasls added.) “Set- 2a. The Oovernlmz Hoard of Junior Colleaes. In addition to the levying and collectlngof then- - &ual ad valorem tax not to exdeed One Dollar ,($l) on the One'HundredDollar& ($100) valuation of tax- able property within the dl&lck for the malnten- ance.of schools therein, shall have the power to levy a tax not to exceed Fifty cents (506) on the One Hundred Dollars ($100) valuationof taxable property wlthln the district for the constructlon and equipmentof school buildings and the acqul- sltlon of sltea.thereforwithin the limits of the dlsti%ct.when authorized bv an election as afore- eonthe One HuridredDollars ($100) valuation of tax- able.property." (Rnph~sls fidded) In view of the above language, It Is our opinion that the LsglslatureIn enacting Art. 2815tq-3b clearly contem- plated that under its provisions, junior college districts can (l)vote amalntenancetaxlnan emountupto amaxl- mum of $1.00 per $100.00 valuation;92) that they can separate- ly vote bonds and the taxes necessary for servicing them, not to eziceeda mazd.mumof 509!per $100.00 valuation; and (3) that the amount of maintenancetax together with the amount of bond tax of the dlstrlct shall never exceed One Dollar ($1) on the Hundred Dollars ($100) valuation of taxable property. Accordingly,our answer to your specific question Is ln the affirmative;Hillsboro Junior College Mstrict of Hill and Navaz%v Counties can, under the phrasing of the voted propositions,annually levy (1) 'formaintenanceof Its -208L -- . schools a taxof 304 per $UIO.OO valuationon taxable property: and In addition (2) for the servicingof bonds, taxes not to exceed 506 per $100.00 valuation of taxable property. SUMMARY ------_ In light of Article 2815h-3b and the stated phrasing of the voted propositions,the junior college district in question may annually lev : (1) for maintenance of Its schools - 30# per $100.00 valuation of taxable property; and In addition (2) for the servicing of bonds - not to exceed 50# on the $100.00 valuation of taxable~property. Respectfullysubmitted, WAGGONER CAFfR Attorney General of Texas &--ye James M. Strock Assistant Attofney anera JEGS:nh APPROWBY: OPINION COMNITTEE W. V. Geppert; Chairman Paul Phy BraxidonRldkett Llnward Shivers Malcolm Quick APPROVEDFORTHl!~~A!l!'l9RNEYGENERAL BY: Stanton Stone -2082-