Untitled Texas Attorney General Opinion

THEATTORNEY GENERAL OF TEXAS Honorable Joe Resweber Opinion No. C-114 County Attorney Harris County Re: Duties of the ;ludge Houston 2, Texas of the Probate Court of Harris County, un- der the facts states. Dear Mr. Resweber: Your request for an opinion reads as follows: "During the month of June, 1962, the Grand Jury~~ofHarris County, Texas, returned True Bills O;fIndictment against Clem McClelland (Judge of the Probate Court of Harris County, Texas) and several admln- lstrators and guardltins,charging them with theft and/or embezzlement from certain ea- tatea under the JurisCliction of the Probate Court of Harris County, Texas. "On June 20, 1962,a petition for the removal of Clem McClelland aa Judge of the Probate Court of Harris County waa filed In the 61st Judicial District Court, and on June 25, 1962, the said Court entered an order whereby Clem McClelland was suspended temporarily and Arthur C. Lesher, Jr. was appointed Probate Judge of Rarrla County, Arthur C. Usher, Jr. aerved as Probate Judge of Harris County until January 1, 1963, when Jack Smith having been elect- ed $n the November, 19A2 election) took office as Probate Judge. "Up to the present time Clem McClelland has been tried on only one of the lndict- ments, and said conviction was very recent- ly reversed by the Court of Criminal Appeala. me other lndlctments against Clem McClelland are still pending. -563- Honorable Joe Resweber, page 2 (C-114 1 "In view of the above facts, Jack Smith, 'y- ,ProbateJudge of Harris County, has request- ed sn opinion to the following questions: "1. There are between 5,000 and 10,000 filed in thi.s,Courton estates which have not been closed but are current- ly'open estates with unfinished busi- nesa under the juriadlctlon of this Court; these file,@are located in the office of the County Clerk, Probate Division. Is it the responeibility of the Probate Judge to search each of these filea‘to dacertaln,their status or may the status of each~of these files be ascertained as&they are plac- ed on the docket of the Probate Court for hearing? "2. Is It the duty of the Probate Judge, where a personal representative has been indicted, but not convicted, because of transactions In the handling of an es- tate, to remove such person or to cause an investigation to be made? “3. Is it the duty of the ,Prob,ateJudge where'persons other than personal repre- sentatives in an estate have been in- dicted, but not convicted, for trans- actions involved in an estate, to cause an investibatilonto be made to see whether orpHot a civil cau#e of action should be ffled against 'the indicted person or Is thla the duty of the per- sonal representative? “4. What responsibility does the Probate Judge and bonding company have when he approves annual accounts in whi,chthere are orders by a prior Judge which are suspect? -564- . Honorable Joe Resweber, Page 3 (C-114 ) "Attached hereto Is our memorandum brief. Please furnish us your opinion on the ques- tions presented." Section 36 of the Probate Code provides: "It shall be the duty of the judge of each county court to uae reasonable diligence to see that personal representa- tives of estates being administered under orders of the court, guardians of the per- sona of wards, and other officers of the court, perform the duties enjoined upon them by law pertaining to such estates and wards. The judge shall annually examine into the condition of each of,aiaid eetates, the well-being of each ward of the court, and the solvency of the bonds of personal representatives of estates and guardians of persons. He shall require such repre- sentatives or guardians, at any time he shall find that their bonds are not suf- ficient to protect such estate or wards, to execute new bonds in accordance with law; In each such case, he ahall notify the personal repreaentative or guardian, and the sureties on the bond, as provided by law; and should damage or loss result to estates or wards through the failure of the judge to use reasonable diligence in the per- formance of his duties, he shall be liable on his official bond to those damages by such neglect." Section 222 of the Probate Code states the grounds for removal of any personal representative appointed under the provisions of the Probate Code, both with and without notice. Subdlvlslon'(c)'of Section '222 provides: "Order of Removal. The order of remov- al shall state the cause thereof. It shall require that any letters Issued to the one -565- Honorable Joe Resweber, page 4 (C-114 ) removed shall, if he has been personally serv- ed with citation, be surrendered, and - . that all such letters be cancelled of record, wnether delivered or not. It shall further require as to tillthe estate remaining in the hands~of a removed person, delivery thereof ~to the per- son or’pereons entitled thereto, or to one who has been appointed and has qualified as succekisc+represeritatlve,and as to the person of a,ward, that ‘controlbe relinquished as re- quired in the order.” Section 233 of the Probate Code provides: “Every personal representative of an estate ahall use ordinary dlllg@encetom collect all claims and debts due the estate and to cecover possession of all.property of the estatesto which its otinershave claim dr title, provided there Is a reason- able prospect of collecting such claims or of recovering such property. If he wilfully neglecta to use such diligence, he and the sureties on his bbnd shall be liable, at the suit of any~person interested in the es- tate, for the use of the estate, for the amount of such claims or the value of such property as has been lost by such neglect. Such representatives may enter Into contract to convey, or may convey, a contingent in- terest in any propkrty’sought to be~recover- ed, not exceeding one-third thereof, for seWices of attorneys and incidental expenses, subject only to approval of the court in which the estate is being administered.” In Crouch v. Stanley, 348 S.W.2d 543 (TexiClv.App. 1961), an Injunctive proceeding regarding the appointment t$ the Probate Court of a new adminlstratotipending trial In the Probate Court of an appeal~from a removal proceed- ing of the original administrator, the Court held: -566- Honorable Joe Resweber, page 5 (C-114 ) "Assuming that the order of the Probate Court lmproperly'removed Mr. Stanley as the atilnistrator for the estate it would never- theless be true that his appeal therefrom pre- served his status as administrator and he will continue to be such pending a trial de novo in the District Court, and at least until such time as the judgment of that court shall become final. Power to remove a person from h$s office aa an administrator for the estate of a decedent 'isgiven by law, in the first Instance, to the Probate Court. Such a person who considers him- If aggrieved by such an order of removal is i:ven by law the remedy of an appeal to the District Court for a trial de novo. If the remedy .of.;appea>,wab not ao'give&Lthe District Court would not have any jurisdiction to lnter- fere with the order of removal, for courts of equity will not Interfere to protect a person from removal from office by a man or body of men to whom such power of removal Is given by law. 11 . . . "If the injunction to the extent under consideration be undisturbed, the Probate Court would be helpless to protect the Interests of the estate such court is charged by law to aT- minister, in the event of such a contingency, and the estate's beneficiaries would be left with recourse solely confined to damages against the adm&nistrator and the suretles on his bond. In a situation Such as that hypothesized, 'and where the Probate Court might attempt to ap- point an administrator to bring and prosecute a suit in behalf of the estate, such attempt- ed appointment might be stayed through the office of an appeal from the order of appolnt- ment. Pursuant to such proceedings the Pro- bate Court would be empowered, through require- ment of new or additiollalbond, more adequately -567- Honorable Joe Resweber, page 6 (C-114 ) to protect the interests of the estate in the event it be ultimately determined that the administrator's refusal to Institute such suit actually operated to the detriment of the estate and the beneficiaries thereof." ~Emphasls added). In Heyn v. Massachusetts Bonding Company, 110 S.W.2d 261 (Tex.Clv.App. 1937, error di I th C t in sustain- ing the constltutlonallty of staz%eL irnzos$ the duty on the Judge of the Probate Court to annually examine Into the condition of wards' estates (now ,Sectlon 36 of the Probate Code) held: "Under the foregoing provisions of the statutes, obviously It Is the duty of judges of county courts annually to examine Into the condition of the estates of wards, the suffi- ciencg of guardians' bonds, and, If and when the bonds given are not ample security to pro- tect the estates and the warda' Interest there- in, to require such guardians to execute other bonds In accordance with lath:and further, coun- ty Judges are required to compel guardians to re- turn reports of annual accountings into court (a duty imposed under article 4225), and to exact fines for contempt of court and assess damages on guardians and their bondsmen for nonperformance of such duties; and further, It is the duty of coun- ty judges to remove guardians when they have fall- ed fo give bonds as required by law, or when such guardians have absented themselves from the state, or have failed to file annual accounts, or have refused to obey proper orders of the county judge. ManFPestly, the above mandatory duties are Imposed upod county judges by reason of Inability of rni- nors, idiots, lunatics, persons non campos mentls, and common drunkards to take care of their own ln- terests. The welfare of persons laboring under such disability has always been a matter of deep -568- Honorable Joe Resweber, page '7 (C-114 ) " concern to the state. This state has In a manner made the county judges its fiscal a- gents to confide estates of such persons to the Custody of prudent and safe persons, and have carefully thrown safeguards ardund such trustees, as to require of them a faithful discharge of their trust. The statutes com- pelling guardians to give solvent and suffl- cient bonds in amountequal to~double the es- timated value of the personal propetitybelong- ing to their wards, to file annual accountings as to elicit truthful information as to the condition of such estates, to obey proper or- ders of the county court or judge, and to al- ways remain within the juriadict$.onof suph court or judge, are for the protection of such disabled persona and their estates. These duties are mandatory; the failure of performance oarries~with it penal punishment and civil llabllltjr,and removal of such fiduciaries. So, also, la the above statu- tory duties Imposed upon the county judges of equal force and effect, and the failure of performance 18 negligence per se, for which such county judges are amenable and their official bonds liable for loss due to such negligence." In view of the foregoing, you are advised that the provisions of Section 36 of the Probate Code requiring the judge to annually examine Into the condition of each of the estates Is a mandatory duty and It Is the respon- sibility of the Probate Judge to search each of the files to ascertain their status annually. It Is the duty of the Probate Judge to remove the personal representative in the event that the Court has knowledge of existing grounds for removal prescribed by Section 222 of the Probate Code. Whether a violation of Section 222 by the personal representative has occurred Is a fact ques- tion to be determined by the Probate Jtidgei -569- - . Honorable Joe Resweber, page 8 (C-114 ) In view of the provisions of Sections 36 and 233 of the Probate Code, you are advised that it is the duty of the personal representative to use ordinary diligence to dollect all claims and debts due an estate and to recover possession of all property of an estate to which itB own- ners have claim or title, provided there Is reasonable pros ect of collecting such claim. Irithe event the per- sonaB representative falls to perform such duty, the Pro- bate Judge is authorized to remove the personal repye- sentatlve under the provisions of Section 222 of the Pro- bate Code. Therefore, It is the duty of the Probate,~Judge to use such reasonable diligence as Is necessary to determine whether the"persona1 representative is perform- ing the duties required by Section 233 of the Probate Code. In answer to your fourth question, Sectlbn 401 of the Probate Code provides: "Action Upon Annual Accounts. "These rules shall govern the handling of annual accounts: (a) They shall be filed with the county clerk, and the filing thereof shall be noted forthwith upon the judge's docket. (b) Before being considered by the judge, the account shall remain on file ten (10) days. (0 At any time after the expiration of ten (101 days after the filing of an annual account, the judge shall consider same, and may continue the hearing thereon until fully advised as to all Items of said account. (d) No accounting shall be approved unless possesalon of cash, listed securi- ties, or other assets held In safekeeping or on deposit under order of court has been proved as required by law. -570- Honorable Joe Resweber, page 9 (C-114 ) (e) If the-account be found Incorrect, it shall be corrected. When corrected to the satisfaction of the court, It shall be approved by an order of court, and the court ahall then act with respect to unpaid claims, as follotis: (1) Order for Payment of Claims In Pull. If it shall appear from t~heexhibit, or from other evidence, that the estate Is wholly solvent, and that the representative haB In his hands sufficient funds for the payment of every character of claims against the estate, the court shall order immediate payment to be made of all claims allowed and approved or established by judgment. (2) Order for Pro Rata Payment of Claims. If it shall appear from the account, or from other evidence, that the~funds on hand are not sufflcrent for the payment'of all the said claims, or if the estate Is Insolvent and the personal representative has any funds on hand, the court shall order such funds to be applied to the payment of all claims having a prefer- ence in the order of their priority If they, or any of them, be still unpaid, and then to the payment pro rata of the other claims allow- ed and approved or established by final judg- ment, taking Into consideration also the claims that were presented within twelve (12) months after the granting of administration, and those which are in suit or on which suit may yet be Instituted." In Heyn v. Massachusetts Bonding Company, supra, the Court held on motion for rehearing: II . . . The county judge knew, or should have known, that the $1,000 bond was insufficient, and his failure to re- quire additional security was negligence per se, and ~such failure, along~With the other failures of official duties, as -571- Honorable Joe Reaweber, page 10 (C-114 ) reflected in the record,and pointed out in otiti original opinion, uere the direct and proximate cause of the ward's 106~1." In view of the foregoing, you are advised in ana- wer to your fourth question that the Probate Judge and hi8 bbtiditig oompany atieliable If he le negligent in the performance of hla duty in Approving annual accounts, If such negligence constitutes proximate cause of a loss to the estate. SUMMARY A Probate Judge Is required to annually examine Into the condition of each estate being administered un- der orders of the Court and to use rea- sorbabledPligen&e to determlni that the personal repretientatlveeof estates be- ing administered under orders of'the Court atie. petiformlngtheir duties required by the provisions 6f the Probate Code, Yours very truly, WAGGONER CARR Attorney ffeneral JR:ms:;lh APPROVED: OPINION COMMITi'EE~ W, V. Geppert, Chairman C. L. Snow, Jr. ,Blll Alien APPROVED FOR THE ATTORNEY GENERAL BY: Stanton Stone -572-