Untitled Texas Attorney General Opinion

- . . R-788 T~~EA~~ORNEY GENERAL QFTEXAS PRICE DANIEL AUWI-IN U.WS ATTORNEY OENERAL January 13, 1948 Hon. George B. Butler Chairman ,Boardof InsuranceCommissioners Austin 14, Texas Opinion No. V-474 Rc: The constitutionalityof Section 2(A), House Bill 85, 50th Legislature, prohibitinge.nyconncc- tions between burial as- sociations. Dear Sir: Your request for an opinion regarding the above subject is two-fold: 1. The constitutionalityof Section 2(A), of House Bill No. 85, 50th Lcgisla- turc; and 2. Whether this Section of the Act applies to Burial Associationsorganized both before and aftcr the effective/ date of the Act. These questionswill be discussed in the order stated. Section 2(A) of House Bill 85, 50th Leglsla- turc, reads as follows: "There shall be no connectiondirectly or Indirectlybetween two (2) or more Burial Associations.No member, director, or offi- cer of one Burial Associationshall be a mem- ber, director, or officer of any other Burial Association. No person whose husband, wife, or employee is an officer or director of one Burial Association shall be an officer or director of.any other Burial Association. No funeral director,undertaker,or funeral home directly or Indirectlyconnectedwith or designatedby one Burial Ass;~clation as Hon. George B. Butler, Page 2 (V-474) Its funeral director,undertaker or fu- neral home shall be connectedwith or designatedby any other Burial Association as Its funeral director,undertaker, or funeral home to furnish Its members with its services and/or merchandiseor to service its policies or to be in any man- ner connectedwith Its affairs." The caption of the Act oro<;tlng a Burial As- sociationRa$c Board contains,among other things, the following: , . . making it unlawful for there to be any connectionbetween two (2) or more Burial Associa- tions; . . .' Prior to the passage of this Act, Article 4875-a-4,v.c.s., which prohibited in general terms any connectionbetween Burial Associations,read as follows: "Art. 4875a-4. IndependentAssoclatkons.-- There shall be no connectionbetween any two associationsoperating under this law and no one associationshall contributeany- thing by way of salary orcompensation to any executive officer for the purposes of such other associations." In a former opinion, O-2879, by this Department,the fol- lowing connectionswere held lawful under this Article: (a) Where two Burial Associationsdesignatedthe same fu- neral home in their policies; (b) where there was a family relationshipbetween the officers of the two associations; and, (c) where approximately150 persons held policies In both associations. Later, another opinion, O-6956, rc- affirmed the legality of almost identical connectionsin addition to these situations: (a) Where two associatlcns appoint one agent to write policies In both associations; and'(b) where two associationsoccupy the same quarters and share personnel as well as operatingexpenses. In a third opinion, 0-5018, rendered after O-2879 and before O-6956; the connectionof,interlockingor common of,f;f;; and directors for two associationswas condemned. rulings were each made In the light of Article 50684, Section 23, v.c.s., which limits to $150.00 the value of benefits allowed by Burial Associations. The two asso-, oiations involved in O-2879 admitted that their purpose was to provlde benefits in excess of $150.00. Such were the views of this Departmentconcerningthe purposes of Article 4875a-4, supra, up to the time of the enactment of House Bill 85 of the 50th Legislature. Hon. George B. Butler, Page 3 (V-474) It has been contended In briefs filed in sup- port of the propositionthat this Act is unconstltution- al that this section of House Bill 85 violates Section 35 of Article III of the Constitutionof Texas, which provides: "No bill, . . . shall contain more than one subject, which shall be expressed In Its title. But If any subject shall be embraced in an act, which shall not be cx- pressed in the title, such act shall be void only as to so much thereof, as shall not be so expressed." The first sentence of Section 2(A) Is admltted- ly germane to the caption of the Act. The argument Is aimed at the last three sentences of Section 2(A), which declare unlawful the very connectionsheld lawful by this Departmentunder Article 4875a-4, supra. The crux of the argument is that the wording of the caption fail- ed to signal or Inform the members of the Legislature or the public that such connectionsbctweon burial as- sociationsheld innocentby the Attorney General in the former opinions under Article 4875a-4, were on the threshold of being declared Illegal in the body of the Act. The general rule of constructionharmoniously applied by all of the courts In these matters Is that the title or caption of lcglslatlveacts shall be libcr- ally construed so as not to violate the constitutional revisions. Gulf Insurance Company v. James, 143 Tcx. 24, 185 S.W. (2d) 966; Board of InsuranceCommisslon- fi ers v. Sprolcs Motor Freight Lines (Civ. App.), 94 S.W. (26) 769; 39 Tex. Jur. 95. It is also a common rule In construingcaptions or titles of legislativeacts that where the provisions of the act are in any degree rc- lated or germane to the title or caption, the act will not be held unconstitutional. City of Beaumont v. Gulf States Utility Company (Clv. App. ,.163 S.W. (2d) 426; Phillips v. Daniel (Civ. App.), 91 S.W. (2d) 1193, cr- ror refused. In the last-citedcase It was stated: "The law is settled that under the con- stitutionalprovisionsreferred to any num- ber of provisionsmay be contained in the same bill or act, however diverse they may be; the only requirementbeing that they arc conslstcntwith the general object or subject, Hon. George B. Butler, Page 4 (V-474) and have a mutual relation and connec- tion, directly or indirectly,with the gcn- era1 subject or object of the act or bill." Many cases were cited to uphold this ruling. WC cannot agree that any part of Section 2(A) ia wholly unrelated or foreign to the caption of the Act. The connectlonscondemned in this section are not indi- rectly, but directly, related to the subject of the Act. The real subject of this Act is the regulation of Burial Associationsthrough the creation of a Burial Associa- tion Rate Board. As a part of this subject the Leglsla- ture has made it unlawful for there to be any connection between two or more Burial Associations. The first sen- tence of Section 2(A) is an almost word-for-worddupli- cation of the related wording in the caption. The last three sentences of this Section simply specify certain particular connectionswhich are unlawful. The 50th Legislaturein so specifyingthese connectionsit dccm- ed unlawful avoided the dilemma created under the old Article, 4875-a-4, supra. If the Legislaturehad done In that Article what the 50th Legislaturehas done In Section 2(A), there never would have been any necessity for questioningthe purpose of Article 4875-a-4. And simply because the Attorney General In the prior opln- ions held certain connectionsto be lawful under that general statute Is no reason for holding unconstitution- al House Bill 85 of the 50th Legislature,which declares those same connectionsunlawful. It affords no basis for holding that Section 2(A) violates Section 35 of Article III of the Texas Constitution. Section 2(A) applies to all Burial Associa- tions without regard to whether they were organizedbc- fore or after the effectivedate of the Act. The lan- guage Is broad, clear and conclusive;no exemptions,cx- ccptlons, or conditionsare contained therein. But con- ceivably, it may be urged that Insofar as this Section applies to assoc,lationsand their contractualrelations existing prior to the effectivedate of the Act, it vio- lates Article I, Section 16 of the Texas Constitution, prohibiting the making of any law impairing the obllga- tlons of a contract. We recognize the limitationsplaced upon the State in the exercise of Its police power to regulate an act or contractwhich affects the health, ,goodmorals, or the public welfare. Lone Star Gas Company v. Kcllcy, Hon. George B. Butler, Page 5 (V-474) 140 Tex. 15, 165 S.W. (2d) 446; Nichols, Labor Commis- sioner v. Hart, 119 S.W. (2d) 1068. At the same time the authoritiesare uniform that if the regulation is a reasonableone and results in a benefit to the pub- lic, it does not violate the safeguardsprovided in the Constitutionas to contracts. We think a complete answer to this assertion is found in the case of Daniel v. Tyrrell and Garth InvestmentCompany, 127 Tex. 213, 93 S.W. (2d) 372. There, a title insurance company contractedwith Tyrrell and Garth to insure titles to its land. Later, the Leg- islature passed a law granting to the Board of Insurance Commissionerspower to promulgate rates to be charged by title companies. Exercising this authority,the Board fixed a rate which materially changed the rate contracted for between the title company and Tyrrell ana Garth, who contended in the suit that the previous contract could not be affected by such action of the Board. The Supreme Court's language which disposed of that contention is deemed'appropriateto a disposition here. It was said: "It is the rule that the contracts,and rates to be charged, by those engaged in a business affected by public Interests,may be regulated. Munn v. Ill., 94 U.S. 113, 24 L. Ed. 77; Union Dry Goods Company v. Georgia T.S. Corporation,248 U.S. 372, 39 %;i;"me .Court, 117,,63 L. Ed. 309, 9,A.L.R. . "The business of Insurance generally is now recognizedto be one affected by public interests. 14 R.C.L. page 857, and authorl- ties there cited. II . . . The police power of the State to regulate the business of title insurance,as to forms of contractsand rates, cannot be contractedaway by the title companies. Shaw vs. Lone Star Building and Loan Association, supra." Moreover,,it Is well establishedthat parties who make contracts,affectingthe public interests,do so subject to the State's right to limit~or prohibit the making of such contracts. See: InternationalBrother- hood v. Huval, 140 Tex. 21, 166 S.W. (26) 107. Hon. George B. Butler, Page 6 (V-474) From what we have said, we do not wish to be understoodas ruling that associationsunlawfullycon- nected should be disposed of without regard to the vested rights and interests of the lndlvidualpollcy- holders of such associations. It 18 our understanding that the Commission will promulgatereasonableregula- tlons and requirementsthrough th& new Burial Associa- tlon Rate Board which will give adequate protection to such policyholders. This can be achieved by permittlng such association,under proposed rules by the Rate b3m'f,st;;e ;;;s~r+ice Its deceased members until its ; or (2) to reinsure its business In some other company (not a burial 'association) for cash benefits only; or (3) to convert all such associations wherein the benefits will be cash only. In this manner, the vested rights of Individualpolicyholdersof such associationswill not be distrubednor vitiated. It is our o inion~,thatthe regulationscon- tained in Section 2(AP are reasonableand that they result in a benefit to the public. The Legislature in the same Act, Section 2(B), specificallydeclared that such connectionsare against the public policy of this State as follows: "It is against the public policy of this State for a Funeral Home or for those who own it in whole or in part to be connect- ed directly or indirectlyor affiliatedwith more than one Burial Associationand the pro- visions of this Act shall be liberally con- strued and the Board of InsuranceCommission- ers shall make such rules and regulationsas may be necessary to carry out the spirit and purpose of this Section. Thus it will be.seen that the Legislaturewlsely'declar- ed the clear purpose of the regulationsand made liberal provisions for the Board of InsuranceCommissionersto exercise the authority grantedtherein in a spirit of high regard for the welfare of the public. We are con- fident that In the exercise of this authority,the Board of InsuranceCommissionerswill exercise sound discre- tion in carrying out the spirit and purpose of this Act. It is therefore our opinion that Section 2(A) of House Bill 85, 50th Legislature,does not violate any provision of the Texas Constitution,and that such Section applies to all burial associationswhether or- ganized before or after the effective date of the Act. - , ,- .,, hon. George B. Butler, Page 7 (V-474) SUMMARY 1. House Bill 85, Section 2(A), 50th Legislature,does not violate Section 35 of Article III of the Texas Constitution, nor does it unconstitutionallyImpair ex- isting contracts. 2. Such Act applies to all burial associationsorganizedbefore or after the effectivedate of the Act. Daniel v. Tyrrell and Garth InvestmentCompany, 127 Tex. 213, 93 S.W. (2d) 372. Very truly yours ATTORNEXGRNERAL OFTEXAS Charles E. Crenshaw Assistant CEC:wb/JCP APPROVED: