Untitled Texas Attorney General Opinion

THE ATTORNEYGENERAL OF TEXAS Au- aa. - _.._.+- WILL WILSON A'ITO- ‘XENEILAL July 26, 1960 Mr. Raymond W. Vowel1 Executive Director Board for Texas State Hospitals and Special Schools Austin, Texas opinion NO. ww- 896 Re: Whether the Board for Texas State Hospitals and Special Schools may le- gally adopt appropriate rules and regulations pro- viding for the restraint of patients who have volun- tarily committed themselves to the Board's care, when such patients attempt to leave the hospital while in an active, contagious and communicable state and re- Dear Mr. Vowell: lated question. We are in receipt of your letter dated June 27th in which you requested an opinion from this office concern- ing the following questions: "1 . May this Board legally adopt appropriate rules and regulations pro- viding for the restraint of patients who have voluntarily committed them- selves to our care when such patient attempts to leave the hospital while in an active, contagious and communi- cable state against medical advice? "2 . If your answer to the above is in the affirmative, would the heads of the hospitals, in carrying out the rules and regulations adopted by the Mr. Raymond W. Vowell, page 2 (ww-896) Board, be responsible in damages there- for?" In Attorney General’s Opinion O-7131 (1946) this office passed on substantially the same question, that is, the validity of the State Board of Health's passing rules and regulations covering the detention for treat- ment of persons having those communicable diseases which in the opinion of the State Health Officer con- stitute a real menace to public health. In that opinion we held: "The power of the Legislature to pre- vent the introduction and spread of lnfec- tious and contagious diseases cannot be questioned, and, accordingly, health authori- ties are usually empowered to take such action as may be considered expedient to prevent the outbreak of epidemic and communicable diseases. Thus all rules and regulations adopted pursuant to legislative authority, which are reasonably calculated to.preserve the public health, are valid The power to make quarantine regulations is one of the most important conferred upon health authorities and such regulations consti- tute a proper exercise of the police power. These general principles are so firmly entrenched in our system of jurisprudence as to admit of no con- jecture, and we therefore cite no cases to sus- tain them. Your attention is directed to the annotations in 2 A.L.R. 1539 and the legion of cases there cited." Section 2 of Article 4477-11 of Vernon's Civil Stat- utes, which is styled as the "Texas Tuberculosis Code" states as follows: "It is the purpose of this Code to pro- vide care and treatment for those afflicted with tuberculosis, to facilitate their hos- pitalization, and to enable them to obtain ,needed care." The Legislature of the State of Texas in Section 4 of such statute provides that: Mr. Vowell, page 3 (ml-896) Raymond !,f. "Tuberculosis in a contagious, infec- tious, or communicable state is hereby de- clared to be dangerous to public health." In providing the duties of the Board for Texas State Hospitals and Special Schools, the Legislature enacted among other provisions Section 12 (b) which states as follows: "(b) The Board shall prepare and adopt by-laws, rules,and regulations for the government, control, and management of all State tuberculosis hospitals, prescribing the duties of all officers and employees, and for enforcing the necessary discipline and restraint of all patients." (Emphasis added). You state in your letter to us that your Board, which is charged with the responsibility of caring for tuber- culous patients, has become aware of the fact that many patients who voluntarily admit themselves through the county courts to tuberculosis hospitals and after re- ceiving some treatment will absent themselves from these hospitals while in an active, contagious and communi- cable state and against medical advice. You mention that the problem has become so acute that during the present fiscal year, 541 or 44.5 percent of all discharged patients have so absented themselves. In seeking to ascertain the intent of the Legislature at the time that House Bill 421, 56th Legislature, Regular Session, which is now codified as Article 4477-11, Vernon's Civil Statutes, was enacted, we must look to Sections 2 and 4 previously cited, as well as Section 5 of thi.sAct. Section 5 Sets out in detail what is'to be done upon re- ceipt of a report of a case of.tuberculosis to any local health authority and the measures for protection of other persons from infection by such diseased persons. It pro- vides that such diseased person must place himself under medical care from a licensed physician, hospital, or clinic for treatment until such time that a certificate can be furnished from such health authority that such person is free from tuberculosis in an infectious or contagious state. Mr. Raymond W. Vowell, page 4 (Ww-896) Subsection (c) of Section 5 provides as follows: "(c) Any person who violates the provisions of Section 4 (d), or who fails to follow the directions of the local health authority, or who fails to follow the directions of his attending physician pursuant to Section 4 (c), or who in the opinion of the local health authority can- not be treated with reasanable safety to the public, at home, may be quarantined, as that term is hereinafter defined,'and the local health authority may direct, pur- suant to rules and regulations promulgated by the Department, the removal of the person to a suitable place for examination, and if such persan is found to be infected with tuberculosis in an infectious and contagious state, then such person may be quarantined, as that term is hereinafter defined, until such person Is no longer in an infectious and contagious state. (Emphasis added). "Quarantine, as used in this Section, means the limitation of movement and separa- tion, duri,ngthat period of time while in- fectious and contagious, from other persons not so infected, In such places and under such conditions as will prevent the direct or indirect conveyance of such Infectious or contagious condition to others not so infected. "A person found to be infec'tedwith tuberculosis in an infectious and contagious state and quarantined under the provisions of this Section may be placed in any place suitable for the detention 'and segregation required under the provisions of this Set- tion. If suitable facilities are not avail- able within the jurisdiction of the local health authority, then in such event, the person so quarantined may be transported to a State tuberculosis hospital designated by the Board. The Board is hereby empowered and directed to provide suitable facilities for detention of such individuals. . . .#I I, Mr. Raymond W. Vowell, page 5 (W-896) Subsection (6) of Section 5 provides: "(d) It shall be the duty of all per- sons infected with tuberculosis, or who, from exposure to tuberculosis, may be liable to endanger others who may come in contact with them, to strictly observe 'such instruc- tions as may be given them by any local health authority of the State in order to prevent the spread of tuberculosis.' Section 6 provides as follows: 'Any person violating the provisions of Sections 4 or 5 of this Act shall be guilty of a misdemeanor and upon convic- tion shall be punished by a fine of not less than Fifty Dollars ($50.00) nor more than Five Hundred Dollars ($500.00) and/or by imprisonment in the county jail for not more than thirty (30) days." It Is our opinion that the provisions of the Act to fight and control the disease of tuberculosis are clear. While the Tuberculosis Code provides a method for volun- tary admission by persons in a contagious condition with this disease to State hospitals, this does not mean that such persons remain in these tubercular hospitals as guests and free to leave at their discretion, It Is our opinion that the mode of admission to such hospitals is only ancillary, for only one class of persons are eligible to gain admittance and they are those who have tuberculo- sis in an active, contagious and communicable state and who cannot be treated safely in the community from which they come. Once these persons are admitted either voluntarily or involuntarily, your Board is charged with the duty and the responsibility of caring for such persons until such time as they can be pronounced free from this contagious disease. It is our further opinion that the Board for Texas State Hospitals and Special Schools has the authority by virtue of Subsection (b) of Section 12 of this Act to pro- mulgate such rules and regulations for the restraint of "all" patients as they think necessary. The general rule is that where statutes delegate to subordinate governmental Mr. Raymond W. Vowell, page 6 (m-896) agencies and authorities the power to enact, establish and enforce health regulations, they are to be liberally construed in order to effectuate the DurDose of their enactment. 25 Am. Jur.,Health, Sec. 8, p. 291. So long as such regulations are reasonable and impartial and not against the general policy of the State, they must be submitted to by individuals for the good of the public. Regulations by an agency authorized to promulgate them will be sustained if upon a reasonable construction there appears to be some substantial reason why they will pro- mote the public health and if they are reasonably adapted to or tend to accomplish the result sought. To this end, the constitutional guarantees of due process and equal protection of the law were not intended to limit the subjects from which the police power of a state may law- fully be exerted. 25 Am. Jur., Health, Sec. 21, pP. 299, 300. - Your second question concerns the liability of the heads of the hospital for damages in carrying out the regu- lations adopted by the Board. It is the general rule that the agents of the State shall not be personally held liable for their acts when done pursuant to statute or Official acts Derformed in the administration of their official duty - Chester Ra Morris v. Arno Nowotny, et al, 323 S.W. 2d 3d cases cited therein. When acting within the scope of a statute or valid rule promulgated by your Board,.it is our opinion that officials so acting would fall within this general rule of immunity as to personal llablllty. SUMMARY The Board for Texas State Hospitals and Special Schools may legally adopt ap- propriate rules and regulations provid- ing for the restraint of patients who have voluntarily committed themselves to their care when such person attempts to leave the hospital while in an active, contagious and communicable state and against medical advice. The general rule Is that the agents of Mr. Raymond W. Vowell, page 7 (W-896) the State shall not be held personally liable for their acts when done pursuant to statute or official acts performed In the administration of their official duty. Your3 very truly, LFP:mm:ms APPROVED OPINION COMMITTEE: Houghton Brownlee, Jr. Robert T. Lewis Thomas Burrus Bob Eric Shannon REVIEWED FOR THE ATTORNEY GENERAL BY: Leonard Passmore