Untitled Texas Attorney General Opinion

- TO EACHCOUWY JUDGRIW TEAS: Due to wide interest,a copy of this is sent for your informatton. HE N OF TEXAS AUSTIN. TEXAS April 1, 1950 Hon. J. P. Yllliams Opinion Ho. V-1026 County Attomiey Poakum County Re: Present status bf Plains, Texas Plains Real High School Dlstriot under facts submitted'and S&230, Acts 51st R.S. 1949 (Art. Dear air: 281jL2, v.c.s.) We quote frcln your recent inquiry as folmm: "Plains was originally one of sever- al oommon school distriots of Yoakw Coun- ty, and was known as Plains CommonSohool Mstriot Ao. 1. "In 1931, Plains CommonDistriot and Stanford Valley Comon Bohool Mstriot were oonsolidated by an election for suoh purpose held in eaoh suoh district, and the msult- ing dlstriot beoame kuown as Plains Consol- idated CommonSohool District Ho. 1. "On AprLl 29, 1939, an election was held pursuant to order of the Yoakum County Board of Trustees to vote on the grouping of swh Plains Consolidated district, Cen- tre Point CommonSohool Distriot and Glen Park Common3ohool District for rural hlgb sohool purposes. lhis eleotion oarried in eaoh of swh distriots was so declared by the County Boqd of Trustees, and became known as Plains Rural High School Distrlot Ho. 1. "On Juue 17, 1941, pursuant to order of Yoakum County Board of Trusteea, an eleatl.on was held for groupiug, and assumption of bond Lndebteduess of said Plains district, in-g land and Turner CommonSchool Dlstriots and said Plains Rural High School Dlstrlot. This election carried in each such district, was Hon. J. P. Williams, page 2 (v-1026) so declared by the County Board, and the resulting district became known as Plains Rural High Sohool District Ro. 1. “In July 1948, an election was held, pursuant to call by the County Jud es in the manner provided in ArtLcle 280 g , V.C.S., on question of consolidation of such Plains distriot and LibertyCommon School District. This election carried In each district and was so deolared by the Commissioners’ Court. In August 1948, an election was held in each of said dlstrlots on assumption of Fndebted- ness, which oarrled, and was ao declared by the Commissioners I Court. In August 1948, the Commissioners ( Court entered its order declaring the boundaries of this new oon- solidsted district which becsme known as Plains Rural High School District. “QWSTIOR: Do the provisions of Sec- tion 5 of Article 2815-2, V.C.S. (passed in S.B. 230, Aots 51at Leg., R.S. 1949) consti- tute the above mentioned Plains Rural High School Distriot an Independent sohool dls- trict .~ ‘I Sedate Bill 230, Acts 51at Leg., R.S. 1949, oh. 573, p.1118 (Art.2815~2, V.C.S.), effective July’22,1949, provides in part as follows: “sec. 1. Rural high school districts (whether formed by grouping or annexation), oom~~onschool distrlots, oommon county-line sahool dlstriots, independent sohool dls- trlcts, and county-line independent sohool districts, . . . may be consolidated in the manner provided by Article 2806, Revised Civ- il Statutes, as amended; . . . Provided fur- ther that eaoh such rural high sohool dLs- trict indicated In such oonsolidation shall be oonsidered as one dlstriat for votkng pur- poses in such consolidation eleotion . . . “Seo.4. Any district formed by a oon- soltdatlon under this Act shall constitute an independent sohool distrlot and be governed by the General Laws applicable to independent school distriots and It may thereafter be consolidated with any other district or dis- tricts under the provisions of this Act. Eon. J. P. Willlams, page 3 (v-1026) “Sea. 5,. Any dlstriat heretofore form- ed by oonsolidation in the manner provided in thir Aat ( Iin the manner provided by Artiale 2806’) is hereby validated and deolared to constitute an independent school distrlot. ” The title or caption of Senate Bill 230 reads: “An AQt authorizing rural high school districts, aommon school distciots and in- dependent school districts, inaludiug oouu- ty line distriots of any type, aud iualuding, under oertain oonditions, elementary school distriots wbioh, without a separate majority vote therein, were anuexed to or grouped with other distriots under Chapter 59, Acts of the 39th Legislature, relating to rural high school districts, to be oonsolidated in the manner provided in lultiole 2806, Revised Civil Statutes, as amended; making provl- sions for the Board of ~Trustees to serve such consolidated district until the next regular trustee eleotlon; providing that dis- triots oonsolidated under this Aot shall oon- stitute independent sohool disttiats and be overned by the General Laws relatFng to in- fiependent sohool dlatrlcts ; validating dis- triots heretofore consolidated in the manner protided ln this Act but providing that swh valldatlou shall not apply to any district involved Ln litigation brought by a taxpay- ing voter therein questioning the valldlty of such oonsolidation; enacting other pro- viaLoms relatLng to the subjeot; and tleolar- ing an emergemy. ’ Section 35 of Article III of the Constitutlou of Texas provides: “Ro bill . . . shall contain more than one subject, which shall be expressed in its title. But if any subject shall be embrao- ed in an eat, whioh shall not be expressed in the tLtle, such act shall be void only as to so much thereof, as shall not be so expressed. ” The oaptlon of Senate Bill 230 apprises that “di.striots oousolldated uuder this Act shall aonstitute Hon. J. P. Williams, page 4 (v-1026) independent sohool dlstrlota and be governed by the @n- era1 Laws relating to independent sahool distrlats.” But with respect to distriots heretofore consolidated in the manner provided in this Act, it purports only to validate them. It does not apprise that ‘districts heretofore con- solldated” shall oonstitute independent sohool districts. on the other hand, Seotion 5 of the body of the Aot contains certain provisions which purport to declare districts heretofore oonsolldated in the manner provided by this Act to constitute independent school districta. It not only validates suoh districts but in addition pur- ports to constitute them independent school districts.The subject deolaring suoh districts as independent districts ia not expressed in the tLtl@. A8 a general rule, a title should be neither broader nor narrower than the body of an Aot. Abernath C. Line Cousol. etc. v. New Deal R.R.S. Dist.,-T7?xuF T A 1939 error di sm., jtigm.cor.); 39 Tex.Jur. ggex&kk~~' seo'46. When the title of an Act is too &row or r&trl&ve to cover the body thereof, those portions of the Act not embraoed~ ins the title are void. Siherland v’. Board of Trustees 261 S.W. 48s (T~.Clv. . , error ref.); Abernathy C. Lin&Consol. etc. v. I\TevDeal R.H.S. Dist., supra; 39 Tex..Jur. 100, Statutes, Qec.46. In view of the fact that the title of Senate Bill 230 is restrioted to the subjeot providing that “districts consolidated under this Aot shall constitute independent sohool distriot : . ‘I, it is our opinion that the provision In Se&Lou i of the body of the Bill whioh purports to declare "any distriot heretofore form- ed by consolidation in the manner provided in this Act an independent school district” Is unoonstitution- * ' 'Tex.Const. al. Art. III, S,ec.35. Therefore, Senate Bill 230 is not to be oon- strued as constituting any district heretofore formed in the manner provided in this Act as an independent school distriot. Specifically, the provislon of Seotion 5 of Article 2815-2, Vernon’s Civil Statutes, (Sec.5 S. B. 230, Acts 51st Leg., R.S. 1949, ,oh. 573, p.lll8j may not be construed to constitute the Plains Rural High School . Hon. J. P. Williams, page 5 (v-1026) Distriot an independentschool dlstriot. Of course, any school district formed from two or more oommon school distriots, from a common school dlstrlot and a rural high sohool district, or from any combination of districts enumerated in Section 1 of Senate Bill 230 as a result of a consolidationelection ordered and held in the man- ner provided in Article 2806 after the effeotive date of Senate Bill 230 (July 22, 1949), is an independent school district. SUMMARY Insofar as Senate Bill 230, Acts 51st Lee., R.S. 1949, ch.573, p.1118 (~rt.2815-2, V.C.S.) purports to constitute any district heretofore consolidated in the manner pro- vided in this Act as an Independentschool distriot, it is Ln violation of Section 35, Article III of the Constitution of Texas ln- asmuch as such portions of the Act am not embraced within the Title, but any dlstrlot formed from a combination of districts enum- erated in Section 1 of Senate Bill 230, af- ter the effective date thereof (July 22, 1949) by a ConsolidatLoneleotion held In the manner provided In Artiole 2806, V.C.S., is an independent school district. Under the facts submitted the Plains Rural High School District is not constltut- ed an independent school dtstrlot under the provisions of Senate Bill 230. Yours very truly, PRICR DARIRL APPROVED: Attorney General J. C. Davis, Jr. County Affairs Dlviaion Charles D. Mathews Chester E. Ollison Rxeoutlve Assistant Assistant CEO :mw