Untitled Texas Attorney General Opinion

THE ATTORNEY GENERAL OF -XAS AUSTIN 1% TEXAS WVILI. WILSON ATFORNEY GENERAL July 25, 1960 Mr. Carl C. Hardin, Jr. Executive Secretary Texas State Board of Dental ?Zxaminers Austin, Texas Opinion No. w-893 Re: Does the Texas State Board of Dental Examiners have the authority to prohibit Dentists from advertising In telephone directories by ads similar to the follow- ing : "False Teeth & Repairs Dear Mr. Hardin: - One Day Service." Your request for an opinion reads in part as follows: "We have had several requests to stop the directory advertising of sev- eral dentists in metropolitan areas. These ads are similar to the attached. "!Ihlsdepartment will appreciate your advising whether the attached is in violation and can be stopped by Board action." The advertisement referred to in your request consists of a listing in the "yellow" section of a tele- phone directory in which the dentist has among other things put his name in boldface type in a border along with other Information, as follows: "False Teeth & Repairs - One Day Service" Article 752b of Vernon's Penal Code reads in part as follows: "Article 752b. Unprofessional conduct -_ Mr. Carl C. Hardin, Jr., Page 2 (w-893) "It shall be unlawful for any person, firm, or corporation to engage in or be guilty of any un- professional conduct in the prac- tice of dentistry, directly or indirectly. Any 'unprofessional conduct,' as used herein, means and includes any one or more of the following acts, to wit: 14 . . . "(0) Advertising by means of a display advertisement, display signs or glaring light signs, electric or neon signs, or such signs containing as a part thereof the representation of a tooth, teeth, bridgework, plates of teeth or any portion of the human head, or using specimens of such in display, directing the attention of the public to any such person or per- sons engaged in the practice of dentistry; (Emphasis added) Article 752~ of Vernon's Penal Code provides for the enforcement of Article 752b and reads in part as follows: "Article 752~. Licenses, Refusing, Revoking, Cancelling, and Suspending of "Section 4. The State Board of Ben- tal Examiners shall, and It shall be their duty, and they are hereby authorized to revoke, cancel or suspend any license or licenses that may have been issued by such Board, if in the opinion of a major- ity of such Board, any person or persons to whom a license has been issued by said Board to practice dentistry in this State, shall have, after the issuance of such license, violated any of the provisions of the Statutes of the State of Texas re- lating to the practice of dentistry in Mr. Carl C: Hardin, Jr., Page 3 (~-893) this State,~or any of the provisions of Chapter 7, Title 12 of the Penal Code of the,State of Texas, or any amendments that may hereafter be made thereto. All revocations, cancella- tions or suspensions of licenses by the Texas State Board of Dental Ex- aminers shall be made as hereinafter provided. P,riorto 1947 Section (o), of Article 752b did not Include the first phrase (i.e., advertising by means of a display advertisement). This phrase was added to Section (0) by an amendment in 1947 follow- ing the case of State Board of Dental Examiners v. Blckham, 203 S.W. 2d 363 (no writ history), In which the Court held that newspaper ads were not included in the term "large display signs." On this point the Court.said: "Courts cannot extend subdivision (o), which forbids advertising by means of 'large display signs,' to newspaper advertisements, The statute limiting 'large display' to 'signs,' excludes 'display ads.' 'Signs' are not 'ads.' ,It is unfortunate that the Texas Legls- lature limited such acts of advertising to 'signs,' instead of providing, as is the law of Missouri, Oregon, Wisconsin, and other States to include unlawful ad- vertising by means of ‘large display,' either by 'signs,' or 'ads,' without limitation as to where such advertisement shall be placed." "Display Advertising" as defined by Webster's New International Dictionary is advertising intended to attract by its combination of copy, border, white space, illustration, etc. Webster further defines display in reference to printing as making conspicuous by large or prominent type or by varying the length of lines. In view of the foregoing, It is our opinion that the advertisment referred to in your request is a vio- lation of Subdivision (0) of Article 752b, Vernon's --- . Mr. Carl C. Hardin, Jr., Page 4 @W-893) Penal Code. You are further advised that by virtue of Article 752c, Vernon's Penal Code, the State Board of Dental Examiners Is authorized to revoke, cancel or sus- pend the license of any dentist found guilty of violating Article 752b, Vernon's Penal Code. SUMMARY Advertising in the "yellow" pages of a telephone directory by means of a display advertisement is a violation of Article 752b, Vernon's Penal Code. The State Board of Den- tal Examiners is authorized by Artl- cle 752~ to revoke, cancel or suspend the license of any dentist found guil- ty of violating Article 752b, Vernon's Penal Code, Yours very truly, WILL WILSON Attorney General of Texas Robert A. Rowland Assistant RAR:mm APPROVED: OPINION COMMITTEE Houghton Brownlee, Jr. Robert T. Lewis Thomas Burrus Bob Eric Shannon REVIEWED FOR THE ATTORNEY GENERAL BY: Leonard Passmore