Untitled Texas Attorney General Opinion

4710 THE ATTO R&Y GENERAL AUS-ITN 11.- WI&L W-ON Am- GWIZECAL Octobv z9 lg60 Honorable A. W. Walker Opin-ionNo. WW-952 County Attorney Dickens County Re: Voting rights of Spur, Texas persons who have resided in the State more than one year but have-changed their residence from one'county to another less than sti months before the election. ,DearMr. Walkers: Youhave requested an .opinlonon the following 'question: Is it legal for a person who has been's residen.tofthe State of'Texas'formore than 12'months but who has resided in Dickens County for only one month to vote on State and National offices in 'theGeneral Electlon'inNovember In -the election precinct of his residence In Dickens County, Texas? In the brief accompanyingyour request you refer to Attorney General's Opinion No. o-2666, dated August 31, 1940, and ask in effect whether that opinion is still a correct statementof the law. Citing Article VI, Section 2 of the Texas Constitution,Article 2967 of the Revised Civil Statutes, and the case,of Little v. State ex rel. Parsell, 75 Tex. 616, 90 Oii N 0 2bbb 1 th ~v~swfrZ~50~~8coLL.ypt~o~ot~~~%!?ii3~~~~s t~t~asFZZ~~ of the election may vo~teIn the helectionprecinct of his new residencefor all state offices and for all district offices whose districts Include both counties. The reason,for your questioningwhether this holding is still correct Is explained in the foliowing quotation from-your brief: "My concern in this matter is based'on the fact that Article 5.~15of the Election Code Is worded differentlyfrom Article 2967 of the Re- vised Civil Statutes, which was in force in 1940. You will notice that Article 5.15 of the Code Honorable A. W. Walker, page 2 (WW-952) provides that the voter must make an oath that he has resided in the county where he offers to vote for six months, while Article 2967, which Article 5.15 replaced,provided that the voter must make an oath that he has re- sided in the districtor county where he of- 'fers to vote for six months. In other words, the words 'districtor' were left out of Ar- ticle 5.15. However, Article VI, Section,2 of the Constitutionstill reads the same old way. Also, see 15-B Tex.Jur. 387-388, Sec. 31, footnote 20. In addition, see said 1940 opinion and Attorney General's letter opinions, JULY 11, 1932 (Vol. 336, p. 518), July 1, 1936 (Vol. 372, ynwO), and August 6, 1938 (Vol. 382, Pi.617 . At the outset it should be observed that the only -placeat which.a person may vote 3s eat the place of his resl- dence at the time of the election. (Throughoutthis opinion, residencemeans legal residenceor domicile;8s~distinguished from actual 'placeof abode while absent from one's domicile.) When a person changes his residencefrom one.countyto-another, he immediatelyloses his right to vote In the county of his former residence,either by absentee~ballotor by.returning to the county to vote~on election day, even thoughhe.may not be able .to.votein the county of.hls new,resldenceuntil he has fulfilled'therequisite length of residence to permit ~h$mto vote,there., Art. VI,.Sec...2,.Tex..,Cons,t.,;. Arts. 2.06 and 5.05,.'ElectionCode; Sartwelle.v~.Bunn;120~~S~W.2d~130 (Tex.Civ.App.,lg38). .Thenature of the rlght.of.suffrage~~ (frequently called a privllege~ratherthan .a right)'@ stat&in the.fol- lowing -.uotationfromthe..oplnion InSolon v; &ate, 54 -Tex. ,Cg.ni. &! 1, 114 S.W. ; 349,.352~(1908),~wj1ic+&Jso cites~numerous other support$ng~.authorlties:::..~ 1,~ '. ,"#&; &&;,;mre is It& & ;&& ,;tio '~$& ,;& ~:.not.a necessary or~flxed'In&den% of~,.diti$&shippo .- oti:lnhereht:dm each and every individual,:,but::~that_ voting is the.exercise, of.p.ol.itical- .power,..arid hog. one Is entitled to vote,~unlessthe people .in their sovereign capacity,have conferred on hlmthe right to do .so. .Itmay be 1ald;down asa~general proposi- tlon'thatthe rightof suffrage.may.beregulated and modified or withdrawnby the.:au~thorlty~,whlch,con-. ,. ferre~dIt,.*.+ * ,In the,:case :of.State,~v~."Dil~on,.32 Fla. 545i 14~'So:. 383; 22 .!L.R.A.' ~,124,~~,,.~n~,~treatrng : this general subject, the court ~say:;:',~'The: wrightto ! 4711 Honorable A. W. Walker, Page 3 (WW-952) vote Is not an inherent or absolute right found among those'generallyreserved in bills of rights, but Its possession is dependentupon constitutional or statutory.grant. Subject to the limitationscon- tained In the.federalConstitution,the elective franchise is under the control of the sovereign power of the states, expressed in Constitutionsor statutes properly enacted. Where a Constitutionhas conferred the right and prescribedthe qualifications of electors, it of course is paramountuntil amended, and the'heglslaturecannot change or add to~them In any way; 'but,where the.Constitutiondoes not fix the right of.suffrageor prescribe the qualificationsof voters, it is competent for the Legislature,as the representativeof the lawmakingpower of the state, to do so. These principlesare well recognizedand fully established by authority in this country.'" The extent to which the Federal Constitutioncontrols the right of suffrage is summarizedin the following uotatlon rrom Voting and Election.Laws,by ConstanceE. Smith 9Oceana Fublicatlons.InC.~, Em 11 (see, also; 18 Am. Jur., :Xlectlons,gg 46, &';-2g C.J.S., Elections, gg 5-8): '* * * !IheConstitutiongrants to the state legislaturesthe power to prescribe 'the times, places and manner of holding electionsfor senators and representatives,'and also the.power to~deter- mine the manner of appointingpresidentialelectors. These two grants of power coupled with each state's unquestionedauthority to control all elections for state offices endow the states with decisive control . over all elections; for, while it is true .thatthe Constitution,reservesto Congress the right to make or alter regulationsfor congressionalor senatorial elections, Congress has only rarely exercised this power and then only in very limited ways. * * * "One reads the ConstitutionIn vain for a con- crete definition of who shall have the right to vote; there is only the declarationof the 15th and 19th Amendments that a citizen may not be denied the right to vote because of race, color, previous condition of servitude,or sex. A section of the 14th Amend- ment defining citizens as 'all persons born or nat- uralized in the United States and subject to the jurisdictionthereof' is relevant, since citizen- ship Is inall states a requisitefor suffrage. With the exception of these broad restrictions,full responsibilityfor determiningvoter qualifications comes within state jurisdiction;** *.' Honorable A. W. Walker, page 4 (WW-952) Subject to the foregoinglimitations,It is thus seen that in electionsfor federal offices as well as for state offices, the State may,grant or withhold suffrage as it sees fit and may impose whatever voter qualifications It chooses. Article VI, Section 2 of the Texas Constitution provides: "Every person subject to none of the fore- going dlsquallficatlons fiontained In Section 1 of Article Vg, who shall have attained the age of twenty-oneyears and who shall be a citizen of the United States and who shall have resided in this State one year next preceding an election and the last six months within the district or county in which such person offers to vote, shall d a qualified elector;** *." (Emphasis Prior to 1951, Article 2955 of the Revised Civil Statutes, which Is now Article 5.02 of the ElectionCode, contained this identicalprovision. Article 2967,:.R:C.S., ~, which is now Article 5.15 of the Election Code,~provlded that a voter who moved to another~county after receiving his poll taxreceipt or-exemptioncertificatecould vote in the precinct.ofhis new residenceby making oath "thathe then resides.in the precinct where he.offers.tovote..and.has re- sided for the last six months in the district 'orcounty in which he offers to vote and twelve months In the .State." When the Election Code was adopted in 1951;.the words "dis- trict or" were dropped from Articles 5.02 and 5.15 of the Code. (In the historical comment under Article 5.02 of Ver- non’s Election Code, It is stated that the word "district" was omitted becaus~ethe word district is too indefinite.) The Constitutionfixes the qualificationsof an elector, and the Legislatureis powerless to add to or take from these quallfic&.ions. Solon v. State supra. Ko Schneider, 110 Tex. 369, 218 S W 479 221'S W ,8b07f&); Texas Power and LightCo. v. Brownwoo: Publil Service Go., 1sw 1 5 (Tex.Civ.App.lg.37 &<&*2~de~&dent School District' $?Gefe fj6; )' WW 2 2d 08 (1956). Accordingly,~the - _. Constitution &d no; the stai- utes‘must.belooked to in determiningwhat residence require- ments are Imposed upon voters, and forthis purpose the omls- sion of the words "districtor" ~fromArticles 5.02 and 5.15 of the Election Code may be disregarded. Your question, therefore, is to be answered on the basis,of the 'residence requirementsset out in Article VI, Section 2,of the Constitu- tion. 4712 Honorable A. W. Walker, Page 5 &W-952) Voters who have moved from one county to another within less than six months precedin an election must be broken down into two categories: (17 those who have re- sided for six months within a district which Includes the county of their former residence and the county of their new residence (under present governmentalorganization, the district may be either a congressional,senatorial, representative,judicial, supreme judicial, or State Board of Educationdistrict);,and (2) those who do not have six months' residence in any one of these various types of dls- tricts. (Throughoutthis opinion it is assumed that the voter has resided in the State for one year and is other- wise qualified to vote.) Little v. State ex rel. Parsell, 75 Tex. 616, 12 S.W. 965 (1tQC) d fines the voting rights of.persons In the first categ&ye In that case, complainthad been made to~the followingjuryinstructlon: !By~the language 'who shall have resided In. the State one year ~nextpreceding an election, and the last six months in the dlstrict,orcounty in which.he offers to vote,' is meant at.any State or district election a person would be ,qualifledto vote for State or district officers if he possessed none of the dlsqualif$cationsmentioned in paragraph 2'of this charge, and had lived one ~year'inthe State next preceding such election, and'.thelast six ,monthsin thendistrict in which he offered to vote; but at an election held for the purpose of~locating a county seat, and to elect county officers only, the test as to residence in order to be.a qualified elector would be one year in the State next preceding such election, and the last six months in the county ,ln which he offered to vote." The Supreme Court held that the instructionwas not erroneous, saying: 'We think the court correctly interpreted the language quoted in the charge. It is found fin section 2 of Article 6 of the Constitution.In our opinion it admits of no other reasonable con- struction. When construed as meaning that a resi- dence for six months in the district should qualify an elector to vote for district officers, we have no difficulty in determiningwhich district Is meant; but if we should say that such residence gives a right to vote for county officers, we should be at a loss to know whether It Is the congressional, judicial, senatorial,or legislativedistrict in which the voter was to reside in order to acquire the Honorable A. W. Walker, Page 6 (WW-952) qualification. If such had been the intention, the kind of districtwould have been named, or there would have been some language in the pro- vision indicatingsome rule by which the question could be determined. Besides, the construction claimed by appellant that six months' residence in the district entitr ed the voter to vote for county offices alsg WOUld have rendered the words *or county' superfluous,because every county in the State is, and will in all probabilitycontinue to be, a part of some district. Since the dls- trict Includes the county, it was unnecessary to have used the word county if it had been intended that a residence in the district should give the, qualificationto vote for county officers." Article VI, Section 2 of the Constitutionwas also construed in United States v. Slater, 6 Fed. 824 (Clr. Ct., D. Tex. 1881). which held that a voter who had resided for six months in a congressionaldistrict but less than six months in the county could legally vote for congressmanand for all state officers. The Court said: "Dut if, being a citizen of the United States, a residence of one year in the state, and the last six months next before the election within the dis- trict, will give him a right to vote in the elec- tion precinct in which he resides, for what officers can he vote? Cur present constitutionprovides, (article6,.~ 3:) 'All qualified electors of the state, * *~* who shall have resided for six nionths Immediatelypreceding an electionwithin-the limits of any city or corporate~town,shall have the right to vote for mayor and all other elective officers.' It is clear that a residencein the district for six months does not give the right to,vote for city or town officers,unless the residencehas been In said city or town;'and,by parity of reasoning, such resl- dence would not give the right to vote for county.of- ficers unless said six-monthsl~residence had been ', within the county; and, by a like parity of reasoning, such residence would give the privilege of voting for district officers and for state officers, he having the other qualifications, and having resided the re- quired six months in the district,and the required one year In the state, next before the election, and duly presenting himself In the election precinct in which he resides. And this rational conclusion is made irresistlbl~ystrong by the previous uniform practice of permittingqualified electors~of.the State to vote for state and district offices, where 4713 Honorable A. W. Walker,~page'i' (WW-952) their residence was not such as to authorize them to vote,forkcounty offices at the time and place of ,thelroffering to vote." Later decisions of our courts have establishedthat voters who have resided In the county for six months may vote in elections.of political~subdivlslons within the county .whlch'aredenominate.d,:~~as~ "districts"without having six ,months ~I. residence:~ln:.lthe pollt.ical ~s'ubdlvls,ion: ~': Warren v. Robinson,'32“:S.W.~2d 871 '(,Tex:Civ'.App. 193O);'Shawv. Taylor, '14bS W.2d 452(Tex.Civ.App. 1940); Cranier v. Graham, 2b4 S.W.2h 135 Texc;Civ.App. 19%; error ref Duncan v. Willis, 157 Tex. 31 ; 302.S.W.2d 627 (1957). In-&e last-cited case, which Involved a'school'dlstrictelection, the Supreme Court clarified the meaning of "district"in Article VI,,Sectlon 2 of the'Constitutlon,~8s follows:- "Petitioners'.asslgnmentagain raised the mooted constructionof the word 'district8ap- pearingin ~the-con~stltutional section..'In Little v..State..~exirel. Parsell,~:"j'5Tex. 616, 12 S.W. 965, this~Court construed the term 'dlstrictl~ :asmeaning, a.pol~itidal subdivis~ionembracing&e. ormore' counties and'%& 6ne..~referring a"county such to subdivisions..of., as the school districthere involved~.".:,This.,construc- tlon ~w~~~. .Creme,r ~&LB~,~ssi?d~~~ln vt Graham;',Tex:Civ.App. 264 S.W.2d~l35;'136'wherein~it'was stated't@t .~%vhether .~ .‘.” rightly or wrongly, ithas,been decided~fiy.,th-e‘Supreme .‘_ Courg-,thatthe word "district"asused finthe..phrase, disJunctively..withrthe 'word,"county.~is ..me~anlngless, ' and that the ~authorltles supportthe.rule,that tan .electormust be a resident of the..State for one year, resident of the county for six months;..,and a resident of the subdivisionof the county fiuch:as a'schoal' districg,whereln he votes at the time'he Votes, but 'notnecessarilyforsix months.' 'Applicationfor writ of error.ivis 'refused~in the Graham case and we regard the constructlon"of.theconstltutlonal'phrase as set- tled. See Cremer.v. Graham, supra, and authorities cited therein. This constructionundoubtedly ac-~ counts for the deletion of the words 'districtor! from Artlcle~,5.02 of~the Election Code: Under the rule above~,set forth the courts below were correct In holding that the'five persons above ,mentionedwere entitled to vote at the election in question.although they may not have resided In the Glenwood School Dis- trict for a period of six months prior to.the date of the election." In Duncan v. Willis the Court 'tooknote of the deletion Of "districtor" from Article 5.02 of the Election Code without expresslypassing on what effect it had ondlstricts.,embracing Honorable A. W. Walker, page 8 (W-952) one or more counties. The Court's use of the expression "mooted construction"might suggest that it thought the con- structionof "district"had become moot by virtue of the deletion, but this evidentlywas not the Intended meaning. By discussingthe constructionwhich should be placed on the constitutionalprovision,the Court recognizedthat the word "district"continues to have force despite its deletion from the statute. It is our opinion that, under the foregoing decisions, a person who has resided for six months In a defined,district of the State which includesmore than one county, but has re- sided less than six months in the county of his residence at the time of the election,may vote for offices of the distrift and for all offices which are voted on throughout the State, but he may not vote for offices of districts in which he does not have the six,monthst residenceor for county and precinct offices. The second category of voters--thosewho do not-have six months' residence in a defined district--presentsthe ques- tion of ~whetherby virtue of one.,year'sresidence In the State they are entitled to vote'for~statewideoffices, although they may not vote for district, county or precinct offices. Several Attorney General’s letter opinions between 1930 and -19&Cheld that they may vote for state offices, while others rendered during the ssme period held that they-cannotvote for any of- fice. ~The only authoritiescited In support of the holding that : they could vote for state offices were Little v. State and United States v. Slater., There 1s strong argument in favor of the view that this should be the rule, but we are faced with the fact that the Constitutionstates the residence qualificationscvn- junctlvelyas one year's residence in the State and six months' residence In the district or county. To be a qumfled elector for any~office or for sny,election,a person.mustfulfill both conditionsof residence. Neither the language of the Consti- tution nor the statementsmade in the cases',construing this provision justify the concluslon,thatthe six months' residence :; in the district or,county is waived as a qualificationfor Voting: in state elections. 1If the~voterhas the six months' residence in the district,he will be entitled to vote 'forstatewlde,offlces : regardlessof whether an office of that district is being voted on at the,electlon.:,For example, a person,who has resided In a;state senatorialdistrict for six months may vote for statesoffices in a year for,which no election for State Senator Is held In the district. 4714 Honorable A. W. Walker, page 9 (WW-952) Texas is not alone in denying a voting right to persons who do not meet both state and local residence re- quirements. In every other State, in addition to residence in the State one must also have resided within a county or an election precinct for a required length of time ranging from 30 days to one year, with approximatelyhalf of the States requiring 3 months or longer.2 Smith, Voting and Election Laws, supra, pp. 15-19. That,author makes the 7?ollowingcomment: "Althoughno one would recommend abandon- ment of residence requirementsaltogether, It is often contendedby responsiblecritics that some state regulationsare overly stringent. It is estimated,for instance, that over five percent of the American voting population is unable to meet the residence requirementIn most elections and the implicationsof such widespread disfranchisementin a democratic society cannot be ignored. One has only to look at the statisticsof populationmovement In the United States, especially during and since the second World War, to know that the problem of disfranchisementof sizable portions of the electoratecan only become more acute unless residence requirementsare reduced to reasonabletime limits." We are keenly aware of the seeming inequity of denying to citizens who meet the state residence requirement the right to vote for statewideofficers because they have not resided in some one locality within the State for a period of six months. Rut to hold that a person may vote for statewide of- fices on the basis of one year's residence'inthe State with- out regard to the length of residence in the district or county, it would be necessary to Ignore the second residence condition. However harsh or unreasonablethis conditionmay be, the plain .requlrementsof the Constitutioncannot be ignored. Relief 'mustcome through amendment of the Constitution. It is our opinion, and you are so advised, that a person who does not meet the requirementfor SIX months' residence In the district or county is not entitled to vote for any office in the general election. 2Californiaand Wisconsin permit new residents of the State to vote In presidentialelections with less than the normal residence requirements,and Connecticutpermits former residents to vote by absentee ballot in presidential elec- tions until they become electors in the State of their new residence. Honorable A. W. Walker, page 10 (WW-952) Advertingto the category of voters who have six months' residencein a district but not in the county,we have noted that Article 5.15 of the Election Code omits the words "districtor" in making provision for voting by persons who have changed their residence since obtaining their poll tax receipts or exemption certificates. This statute now reads as follows: "Art. 5.15. Removal to another county 'or election precinct "If a citizen after receivinghis poll tax receipt or certificateof exemption,removes to another county or to another election pre- cinct in the same county, he may vote at an electl.on;general,special, or primary, In the precinct of his new residence in such other county or precinct by presentinghis poll tax receipt or certificateof exemption or his af- fidavit of Its loss to the precinct judges of election,and state in such affidavitwhere he paid such poll tax or received such certificate of exemption,and by mating oath that he is the identicalperson described In such poll.tax re- ceipt or certificateof exemption,and that he then resides In the precinct where he offers to vote and has res1de.dfor the last ~slx.(6)months in the county in which he offers to vote and. twelve (12) months in.the State. But no such person shall be permitted to vote in a city of ten thousand (10,000)inhabitants,,or more, unle~ss he has first presented to the tax collector of his residencea tax receipt or certificate,not less than four (4) days prior to such election orprimary election or made affidavit where he paid such poll tax or recelved'suchcertificate of exemption;and~the collector shall,thereupon add his name to the list of qualified voters of the precinct of his new residence; and unless such voter ha,sdone this and his name appears in the certified list of voters of the precinct of his new,residence,he shall not vote." The.deletlonof'referenceto residence,in the dis- tr~lctraises two questions: (1) what form of oath shall the election judge requfre of the voter, and (2)must the. voter who has moved Into e city of lO,OOO.ormore Inhabl- tants comply with the requirementfor~havinghls~name placed on the list of qualified voters. On the first question; it is-our .op,inion.'that the election judge should require the voter to make the oath 4715 Honorable A. W. Walker, page 11 (WW-952) required in this article, substituting"district"for "countyn. The electionsjudge should mark out on the voter's ballot all offices for which he Is not entitled to vote, before per- mitting the voter to mark his ballot and.casthis vote.3 In electionswhere voting machines are used, the clerk attending the machine should lock out the offices for which the voter is not entitled to vote before permittinghim to close the curtains'and~casthis vote. (Section 2 of Articles7.14, Elec- tion Code, requires that the machine "be so constructedthat a voter cannot vote for a candidate or on a propositionfor whom or on which he is not lawfully entitled to vote.") On the second question, it is our opinion that the tax collector should add the voter's name to the list of quall- fled voters upon the voter's request and upon being satisfied that the voter has resided for six months in some district of which the county Is a part. 'Whilethe oath which the voter makes at the polllng.placewill disclose that he does not have six months' residence In the county, the tax'collectormay properly place a notation to this effect alongside the voter's name on the list of qualified voters. With the deletion of "district",this statute leaves the tsxcollectors in a state of doubt as to their authority to add the names of voters who have not resided in the county for six months. It also leaves the voters In doubt as to whether this statute Is applicableto them. "No such person" refers to any citizen who has moved to another county or elec- tion precinct after receivinghis receipt or certificate,but it could be taken to refer only to such persons who have re- sided In the county for six months efter the removal. If the voter has attempted to comply with the requirementbut the tax collectorhas refused to add his name in the belief that the statute does not authorize this action, we think it is clear that the election judge should neverthelessallow him to vote upon satisfactoryproof of his qualificationsas an elector and of the reason why his name does not a the list of qualified voters. Att'y Gen. Op. V-1@3106;2). Election judges have authority to administeroaths for the purpose of obtaining such proof, and It would be advisable 3This procedure necessarilygives the election judge an opportunityto see the number on the ballot which the voter receives, contrary to the provision in Article 8.11 of the Election Code that the voter shall be allowed to take his own bal1o.twithout the number being known to the election JUd43e.However, we are of the opinion that the voter should not be furnishedwith a ballot which would enable him to vote a full ticket, and he must surrender this safeguard to the secrecy of his ballot if he wishes to vote. Honorable A. W. Walker, page 12 (WW-952) for the election judge to preserve In affidavit form the voter's statementof the reason why his name Is not listed. Where the voter has made no attempt to have his name added to the list, the question becomes more difficult, While the failure of the Legislatureto define Intelligibly the requirementsimposed upon the voter should not deprive him of his constitutionalright to vote, we have come to the conclusion that persons with less than six months' residence in the county are reasonablyput on notice that they must comply with this requirement,and a voter who fails to make applicationto the tax collectorIs not entitled to vote. In order to be a qualifiedelector of this State, a person must meet both conditionsof residence set out in Article VI, Section 2 of the Constitution;namely, residenceof one year Snthe State next precedingthe election, and residence the last six months in the district or county in which he offers to vote. A person, otherwise qualifiedto vote, who has resided for six months in a defined district of the State which includes the county of his .former,residenceand the county of his new resi- dence, but.,hasresided less than six months In the county of his residenceat the time of the election,may vote for offices of the district and for all offices which are voted'on through- out the'state,but he may not vote for offices of districtsIn which he does not have the .slx months' residenceor for county and precinctof- flees. A~personwho does not mee.tthe require-, mentfor six months' residence in the.distrlct or county is not,entitledto vote for any office. The only place a person may vote is in the .county of his~residenceat the ,time..ofthe elec- tion. Upon change of residencefrom.one county to another;a person loses his right to vote.in the county of his former res$dence,evan,though he may.~beunable to vote in the county of his new residence. Yours very truly, wILI.WILSOW AttorneyGeneral~of Texas 4716 Hbnorable A. W. Walker, page 13 (WW-952) MKW:bh APPROVED: OPINION COMMITTEE W. V. Geppert, Chairman J. C. Davis, ,Jr. ,.,Rilqy EUgene.Fietcher. Robert H. Walls Iola Barron Wilcox RETIEWED FOR TH&Al'TORN~ GENERAL BY: Leonard Passmore