Untitled Texas Attorney General Opinion

PRICE DANIEL ATTORNEYOENERAL January 15, 1951 Hon. Charles R. Martin Opinion No. V-1142 County Auditor Harriron coun* Ra: Legality under nepotism Marshall, Texas statutes of continuing county employment of a brother of a newly elected County Com- mirrioner under .eubmitted facts. Dear Mr. bdarfin: You state that for a number of years subsequent to 1932 the Couuty Commissioners Court employed a certain peraon in Precinct No. 2 as an employee in the County Road and Bridge De- partment. Gn October 21, 1948, the employee’resigned his position with the Road and Bridge Department, and accepted employment in December. 1948, with the Harrison County Tarracfn8 Committee, an agency,authorined by the Commin~ionerr Court under Article 2372. V.C.S. The employee in question served ~continuoualy with the Terracing Committee from December, 1948, to June 1.1949. when he returned to the Road and Bridge Department’in Precinct No. 2. Hir employment in Precinct No. 2 has been continuous rince ae date d hi8 return on June 1,1949. At the last General Election in November, 1950. the brother of the employee in queatioa wag elecbd County Commilr- sioner from one of the County Precincts ather than Precinct No. 2. Ho qualified and took office as County Commissioner on Sanu- ary 1, 1951. You amk whether the retention of the county employee in question l ubeequent to January 1,1951, will violate the nepotism dab&e (Article 432, V.P.C.). Article 432, Vernon’s Penal Code, as amended by House Bill 508, Acts 51rt Leg., R.S. 1949, ch. l26, p. 227# provides: “No officer of thimState or any officer of any district. county, city, precinct, school dirtrict, or other municipal aubdfviaion of thir State, or any of- ficer or member of any State, district, county, city, rchool district or other municipal board, or judge Hon. Charles R. Martin, page 2 (V-1142) of any court, created by or under authority of any General or Special Law of this State, or any Member of the Legislature, shall appoint, or vote for, or con- firm the appointment to any office, position, clerkship, employment or duty, of any person related within the second degree by affinity or within the third degree by consanguinity to the person so appointing or so voting, or to any other member of any such board, the Legisla- ture, or court of which such person so appointing or vot- ing may be a member, when the salary, fees, or com- pensation of such appointee is to be paid for, directly or indirectly. out of or from public funds or fees of of- fice of any kind or character whatsoever; provided, that nothing herein contained shall prevent the appoint- ment, voting for, or confirmation of any person who shall have been continuously employed in any such of-- fice. position, clerkship, employment or duty for a per- iod of two (2) years prior to the election or appointment of the officer or member appointing, voting for, or con- firming the appointment of such person to such office, position,. clerkship, employment or duty.’ It will be observed from the above that the retention of the employee in question after January 1, 1951,will violate the nep- otism statute unless he comes Within the proviso added by the 1949 amendment. Certainly the employment of the party in question by the Harrison County Terracing Committee made him a county employee. See Article 2372~. V.C.S. Counting such employment, her has been continuously employed by the county in one capacity or another from December, 1948. to January 1, 1951,a period in excess of two years. Such continuous employment is necessary because as we construe the Act, the Legislature intended that the employment for a period of “two (2) years” be immediately prior to the critical date which brings the nepotism law into operation. The language found in the emergency clause of H.B. 508. supra. to the effect that *numerous employees . . . are required to give up such employment. . . who have continuously served the State” clearly indicates that the pro- viso was not intended to apply to a pe.rson not employed at the time the related official takes office and for two years immediately prior thereto. Our conclusion with respect to the meaning of the -two year period’ as used in the above statute finds support in ~Common- wealth ex rel. Adamn v. Stephens, 345 Pa. 436, 28 A.2d 92=, wherein the Court sad: Hon. Charles R. Martin, page 3 (V-1142) ‘The ‘Act. . . providing for the office . . . sets forth the following qualification for said office: ‘One person who shall be a competent accountant and an elector of the borough for at least four years prior to his election’. (CourPs emphasis.] ‘We are called upon to determine what the Legislature meant by the words ‘four years prior to bis election’. It is contended on the part of the respondentthat,~we can go back any number of years. in order to make up the four year requirement. In other words, that since the respondent was an’elector of the Borough of Wilkinsburg from 1920 to 1925 that he has satisfied the requirements of the Act insofar. as it relates to the four year requirement as an eleti- tar. “We are of the opinion that when the Legislature provided that the prospective officeholder shall have been ‘an elector of the borough for at least four years ~. prlOr to his eleCtion’, it meant immadiately prior to his election. Since it is conceded that the respondent was not’aa elector for four years immediately prior to his election, he is not entitled to hold the office of controller and must be ousted therefrom. . . .v (Em- phasis added.). The only further question to be determined is what was meant by the worda “prior to the clcctisn or appointment of the officer” as used in the ~abwe proviso. If by the use of the word ‘electionv it was intended thst the two-year period would date from the tims of the official’s election at the polls, or from the time of tha canvassing of votes by the, proper officials, then ob- vious1y we do not have’here a trvo-~ear,priod of Coatinuotta rm- ployment. We have concluded that the word ‘election” as used in the above Act should be construed to mean the time of taking of- fice, which in this instance was January 1, 1951. It is to be noted that the Act uses the words “election or appointment.” and clearly the Legislature intended the critical date from which the two-year period was to be computed should be the same in the case of either an appointed official or an elected official, or it would have used language different from that found here. The crption,to House Bill 508 so provider, because it is there stated that the provisions of Article 432, Penal Code, shall not apply to permono holding posi- tion8 for two years *prior to the time an officer or board member related to them takes office.” --. . Hon. Charles R. Martin, page 4 (V-1142) You are therefore .&vised that the retention of the county employee in question st+sr Sanuaiy ,l, 1951,will not vi- olate the fiep&ism law (Articlh 432, V.P.C.). SUMMARY A person who was employed by the county at the time’bis brother first took office as County Com- missioner,,on January 1,1951, and had been continuous- ly so employed for a peripd of ,taroyears immediately prior thereto, m+ be reta&md as a county employee witbout violating tke nepotism’statUt.e (Article, 432. V.P.C., as amended, Acts 51s$.&eg., R.S. 19t9, ch. 126; .p. 227). Yours very truly, PRICEDANIEL . :. . Attorney Gea@tal . APPROVED: &Ldb.S Price Daniel Ckarles D. Matkews Attorney General First Assistant CD&b :’ .