Untitled Texas Attorney General Opinion

_‘^ R-852 OFFICE OF THE ATT RNEY GENERAL AUSTIN,TEXAS PRICE DANIEL ATTORNEYGENERAL November 15, 1947 Eon. Ernest Guinn Opinion No. V-432 County Attorney El Paso County Re: Constitutionality of H. B. El Paso, Texas 796, Acts 50th Leg., 1947, as it relate3 to juvenile officers in El Paso County. Dear HP. Quinn: Your recent request for an opinion of this office relates to the constitutionality of H. B. ,796, Acts of the 50th Legislature, 1947. It is assumed that your request pertains to El Paso County; and, therefore, this opinion will be limited to that portion of the Act relating to those counties with a population of eighty thOUsend 80,000) and less than one hundred and fifty thousand t150,000) inhabitants. H. B. 796 is an Act amending Article 5142, V.C.S., and is in part as fol- lows: "Provided that in counties havin a population of eighty thousand (80,0007 and less than one hundred and fifty thousand (150,000), the county judge may appoint a juvenile officer subject to the approval of the County Juvenile Board for a period not to exceed two (2) years from date of appoint- ment at a salary not to exceed Three Hundred and Fifty Dollars ($350) per month and ex- penses as recommended by the Board a;tc;p- proved by the Commissioners Court. juvenile officer may select such assistant juvenile offlcers~,asare necessary to carry out the provisions of this Act, subject to the approval of the county judge and the County Juvenile Board; provided the number may not exceed ten (10). The salaries and expenses of suoh assistant juvenile officers shall be in amounts recommended by the Board subject to approval of the Court. "Provided that in counties h8Vlng 8~ opulatlon of one hundred and fifty thousand P150,000) or more, and containing a city of ’ . ‘. I Hon. Ernest Guinn - Page 2 (v-432) one hundred thousand (100,903) or more, the County judge may eppoint-8 juvenile officer, subject to the approve1 of the County Juve- nile Board, to serve for 8 period not to ex- ceed two (2) years from the dete of appoint- ment, and whose extre duties shall be to make investigations for the Commissioners Court on appllc8tlon3 for charity, or edmittance into detention home3 or orphsn homes Cre8ted by such counties. The salary of such juvenile OfficeP shell not exceed Three Hundred Dol- lars ($300) per month, his allowance for ex- penses not to exceed Two Hundred Dollars ($200) a yesr. Such juvenile officer mey select aa- slatant juvenile officers, subject to the ap- prove1 of the county judge and the County Juve- nile Board, the number of such assistant juve- nile officers not to exceed one (1) assistant to each twenty-five thousand (25,300) popula- tion. The selariea of such assistent juvenile officers ah811 be the same as that fixed by the General L8w in Article 3902 of the Revised @vi1 Stati& af Texas, 1925, for assistants to othez.eopqty orficials. Such assistant juvenile officers msy be allowed ex enses not to exceed Two Hundred Doll8rS ($200P per year esch." &ti,cle III, Section 56, constitution of Texas.' provides in part as follows: "The Legislature aball not, except as otherwise provided in this Constitution, pass any local or special lew, euthorising:. . . "Regulating the affairs of counti.es,cit%es, towns, election or sahool districts; . . . "Creating offices, or prescribing the psw- era and duties of officers, in counties. . . The question for determination is whether this Act purporting to fix the compensation of juvenile Offi- cers of counties in certain population brackets ViOlate the above constitutional provision relating to 10~81 or SpeCi8.118W3, In 8n spproach to this question, the COUrt In Oakley v. Kent, 181 S.W. (26) 919, steted as follows: -. Hon. Ernest Guinn - P8ge 3, (V-432) "'A law which epplles only to 8 part of 8 nAtUral cl883 of persons or things must predicate its inclusi,onof the p8rt end ex- ClUSiOn of the balance upon ChRracteriatics peculisr to the pert, which, considering the objects 8~ndpurposes of the law, afford ree- 3On8ble ground for restricting the applica- tion of the law to the pert, Gl83'3ifiC8tiOn must be reaaoneble and netur8.1,not arbitrery 8nd C8priciOua. ArbitrRry designation is not clasaificstion. The vice of locel or special laws is that they rest on arbitrerg designe- tiOn; th8t they do not embra~ce8nd sffect 811 of the class to which they sre naturally re- lated. . . . "'Because population 83 * basis for clas- aificetion hea been SU3t8ined by the courts in respect to legislation on ce.rtainsubjects, it has been 88SUmed, erroneously, th8t population brackets will aerve in all instances to avoid the condemnation of the Constitution. This misteken assumption proceeds from 8 feilure to note th8t population h33 been austsined aa 8~ besis for claaaificetion only in those Instances where it bore 8 reasoneble relation to the ob- jects 8nd purposes of the law and ~8s founded upon rational difference in the necessities or conditions of the groups subjected to different laws. Where it has been determined tkRt, con- sidering the objects 8nd purposes of the lew, differences in population afford no rational basis for discriminating between groups of the acme nstura1 Cl833, cl8saific8tion on the b8sia of population has been termed a,rbitPe,ry aelec- tion, and the law has been held to be specie1 end lOC81. . . .'II In the case of Clark v. Finley, 93 Tex. 171, 54 S.W. 343,the Supreme Court recognized the fact that the Legisleture could resort to populetion br8ckets for the purpose of fixing fees of officers in certain cases. But there must be a subatential re8son for the classification. It must not be 8 mere 8rbitrflrydevice resorted to for the purpose of giving what is in f8Ct 8 lOC81 18W the 8p- pear8nce of a gener81 18w. Miller v. El P8ao County, 136 Tex. 370, 150 S.W. (2d) 1000; Anderson v. Wood, 137 Tex. f;;, 152 S.W. (2d) lOo4; Ex psrte Csrson, 159 S.W. (28) Hon. Ernest Guinn - Page 4 (V-432) In the case of Bexar County v. Tynan, 128 Tex. 223, 97 S.W. (26) 467, the Court stated: 'Conversely, we think it true that if the Legislature ignores the obvious fact that the work of county officers Is pro- portionate to population and classifies counties in such way that the compensation Of OffiC8PS Of a COUIltyhaving a large pOpU- lation is fixed far below the compensation allOWed like officers In small counties, such action amounts to fixing a classlfica- tion which is arbitrary and which has no true relevancy to the purpose of the legis- lation. we think that it necessarily fol- lows from all the circumstances that the Legislature Intended to single out Bexar County as being the only county intended to be e,ffectedby the legislation, and the act was undoubtedly a special lav." H. B. 796 provides, among other things, that the salary of juvenile officers in counties having a population of 150,000 inhabitants OP more and oontain- ing a city of 100,000 inhabitants or more shall not ex- ceed $300 er month with an a.llowancefor expenses not t0 eXCe8d 1200 a year. The juvenile officer In counties in this population bracket may be allowed one assistant for eaoh 25,000 population. In counties with a popula- tion of eighty thousand (80,000) a,ndless than one hun- dred fifty thousa.nd(150,000) Inhabitants, the maxisurs salary of juvenile officers is $350.00 per month and ex- penses 8,srecommended by the Board and approved by the Commissioners' Court. The juvenile officer in COUIIti8S in this population bracket may be allowed a leaXiISUm of ten assistants. By way of comparison a juvenile officer in a county with a population of 150,003 inhabitants would b8 entitled to a salary of $300 per month and Six assistants, whereas a juvenile officer in a county with a population of 14g,OOO inhabitants would be entitled to a salary of $350 per month and ten assistants. It is Well Settled that an Act 8XC8pting Certain COtlnti8SOr fixing salaries arbitrarily is a local or special law within th8 meaning of the COnStitUtion. If, by the terms of an Act, counties are Classifi8d in such a way that the oompeneatlon of a juvenile officer of a oounty hav- ing a large population is fixed far below the compensa- tion allowed the jUV8nil8 Officer in Sl%&llel' COUntiBS, Hon. Ernest Guinn - Page 5 (V-432) the same amounts to fixing a classification which is arbitrary and has no relevancy to the purpose of the Act. It therefore follows that the Act allows 'uve- nil8 Officers in Counties with a population Of 4 0,000 to 150,000 inhabitants larger salaries than those juve- nile officers in larger counties. Such classification is an arbitrary one and is void as a special or local law. Since the classification does not bear a reason- able relation to the object and purposes of the law, it is the opinion of this Department that the portion of H. B. 796 relating to those counties with a population of 80,000 to 150,000 inhabitants is a local or special law and is in contravention of Article III, Section 56, of the State Constitution. SUMMARY That portion of H. B. 796, R. S., 50th Leg.9 1947, relating to the appointment of juvenile officers in El Paso County and re- lated counties In the same population bracket is a looal or special law containing arbi- trary classifications and is in contravention of Art. III, Sec. 56, of the Texas Constitu- tion. Bexar County v. Tynan, 97 S.W. (26) 467; Clark v. Finley, 54 S.W. 343;Oakley v. Kent, 181 S.W. (26) 919; Anderson v. Wood, 152 S.W. (26) 1084, 137 Tex. 201; Miller v. El Paso County, 150 S.W. (2d) 1000. Very truly yours ATTORNEY GENERAL OF TEXAS BYBurn811 Waldrep BW:djm Assistant APPROVED: ATTORNEY GENERAL