Untitled Texas Attorney General Opinion

Eon. John C. Xarburger Opinion Bo. v-386 county Attorney Fayette County Be: Constltutlonallty of La Grange, Texas IL&.~;7; A~tb or the ., relative to county juvenile boards In certain counties. Dear Sir: You have requested this 0rrm to determlne the cdnstltutlonality of H. B. 257, Acts o? the 50th Legislature, p. 560,~Vernon’s Texas’ SedsioiLaw Service. H. B. 257 Is an Act amending Article 5139, V.C.S., so as to create Couqty Juvenile Boards In certain counties. The provisions vhlch were added to Article 5139 by II. B. 2.576re as r0ii0ws: “In any county having a population 0r less than seventy thousand (70,000) inhabl- tants according to the lest preceding Federal Census, which county Is Included in, and forms a part of a Judicial District of aeven (7) or more counties having a combined populstion of more than fiity-two thousand (52,000) inhsbi- tank, or which county is included in and forms a part of a Judicial District or five (5) or more counties having a combined population of more than seventy-two thousand 72 000 and lesa than ninety-five thousand 1,95,000 1 lnhabl- tants according to the last preceding Federal Census, or which county Is included In and forms a part or a Judicial District of five (5) or more counties, in one (1) or more or, which counties the civil and criminal jwis- diction vesting by General Law in the County Court has been or hereafter shell be trans- ferred to the exclusive jurisdiction of the Dis- trict Court of such county or counties, and having a comblned~populationln such Judicial District of more than thirty-five thouaand (35,- 000) inhabitants, according to the last preced- ing Federal Census; or which county is included in and forms a art of a Judicial District com- posed of four ( $ ) counties having a combined i Hon. John C. Wsrburger - Page 2 (v-386) population of not more than sixtytwo thou- sand (62,000) inhabitantsaccording to such last preceding Federal Census, one (1) or more counties In which districts border on the InternationalBoundary between the United States and the Republic of Mexico; the Judge of such Judicial District, to- gether with the County Judge of such county are hereby constituted a Juvenile Board for such county. The members composing such Juvenile Board in each such county shall each be allowed additional compensation of not less than One Hundred Dollars ($100) and not more than Three Hundred x:;1~~4300) or annum, which shall be paid in twelve P12) equal installments out of either the general fund or the jury fund or such county, such additional compensation to be fixed by the Commissioners Court of such county. ” Article III, Section 56, provides in part: ‘The Legislature shall not, except as othervise provided in this Constitution, pass any local or special law, . . . “Regulating the affairs of counties. . ., “Creating ofrlces, or prescribing the powers and duties of officers, in counties. . .” Article V, Section 1, provides: “The judicial power of this State shall be vested in one Supreme Court, in COUrta Of Civil Appeals, in a Court of Criminal Appeals, in District Courts, in County Courts, In Com- missioners’ Courts, in Courts of Justlces of the Pesce, and in such other courts as may be provided by law. II. . . “The Legislature may establish such other courts as it may deem necessa.ry and prescribe the jurisdiction and organization thereof, and may conform the jurisdiction of tht District and other inferior courts thereto. .. Eon. John C. Marburger - Page 3 (V-386) ' It may be contended that this Act is governed by Article V, Section 1 of the Texas Constitution, and therefore is not subject to the provisions of Article III, Section 56, (See Harris County v. Crooker, 224 S.W. 792, affirmed 112 Tex. 459, 248 S.W. 652; Garvey v. Matthews, 79 S.W. (2d) 335, error refused; Jcnes v. Anderson, 189 S.W. (26) 65, error refused. and Tom Green County v. Proffit, 95 S.W. (26) 8451; however, the Supreme Court, citing numerous authorities of analogous situations, held in the case of Jones v. Alexander, 59 S.W. (26) 1380, that the county juvenile boards do not have, nor do they exercise, any judicial power or func- tion. It was further held that the Legislature, when authorizing additions1 salaries to be paid to the mem- bers of juvenile boards for such services, may take into consideration the population and size of the county,~its taxable values and general conditions existing therein, but in any event, the cla.ssificationmust be based upon a real distinction. See 81~0 Clark v. Finley, 93 Tex. 171, 54 S.W. 343. In view of the foregoing, it is ap- parent that R. B. 257 is subject to the provisions of Article III, Section 56. Thereforz, the question for declzign iz whether the classifications present a reasonable relation to the objects and purposes of the law snd are founded upon ra- tionsl differences in the necessities and conditions of the countlez effected by the Bill. In the csze of County of Bexar v. Tynen, 97 S. W. (2d) 467, the Supreme Court of Texas announced the prin- ciple which controls the matter herein: "votwithztending it is true that the Legislature may ola.szifycounties upon the basis of population for the purpose of fix- ing compensation of county and precinct officers, yet in doing so the classlfica- tion must be based upon a real distinction, and must not be arbitrary or R device to give what is in substance a local OF zpe- cial law the form of a~generel law. We quote the following cram Oakley v. Kent, 181 S.W. (26) 919: . ;: / .. i Hon. John C. lIarburger- ?age 4 (V-386) p o p u la tio n a s l besls for “‘B a o a u a e olaaslfioatlonhaa been sustainedb7 the co&t8 ln rerpeot to leglsfatlonon certain subjeots,It has been aasimed, erroneously, that population braokets ~111 serve in all Instanceato avoid the oondemnatlonof the differeiicesin population afford uo rstlonal basis for dlscrimInatingbetveen groups of the same natural clam, claasiiicatlonon the ba8i8 Of pOpti8tIonhas been termed arbitrary selectlon,and the lav haa been held to be special and local. Randolph v. Sthte, supra." (Rmphasisours) For additional authorities,see HIllor, et al, 0. El Paso County (Su Ct.) 150 S.Y. (26) 1000; Xx ?arte App.7'159 S.U. (26) 126; Jameson v. Smith, 520; Clt of Ft. Uorth v. Bobbitt, 121 Tex. 1 S.Y. (26) 228; Supreme Lodge 26) 470, 3; Benevolent ~ss'n. v. Johnson, g8 Tex. 1, 81 S.W. 18; Smith v. State, 49 S.W. (26) 739; Rand01 h v. State, 36 S.Y. (26) 464; Fritter v. Weat, 65 9.W.~P26) 414, writ refused; State v. Hall, 76 S.Y. (26) 880; Wood v. MsPfa Ind. School Diet., 123 3.W. (26) 429; Leonard v. Road MaintenanceDlst. Ro. 1, 187 Ark. 599, 61 S.W. (26) 70. In the case of Jones v. Alexander, supra, the CoUPt VaB PSBSiIlg Upon the ~OllStitUtiOMlft~ Of &tiOlS 5139, V.C.S., which provides that In a county having a population of 100,000 or over the judges of~the several district court8 and crlmIna1 district court8 of such county, together vIth the county judge of such county, are.constI- tutcd s juvenileboard, and fixes the annual salary of each of such district judges as members of said Board at $1500 In addition to that paid the other bistrlct judges of the State. There vas no couuty of 100,000 popul8tionor over oaitted, and the court held that this vas a reasonable claB8Iflcrtion. It is of co10n Lnovledgethat In the larger olties and counties of our State juvenile delinquen- cy is more prevalent than in the smaller tovne and coun- tfis3, Therefore,there oould be a reason for having such . Bon. John 0. Narburger'- Page 5 +386) a Board In all of the large counties of the State. Hovever, the olassIfIcatIon8contained In the pro- visions vhich were added to Artlole 5139 by H. B. 257 are not based on populstlon or any other condition of the countiee alone, but are based upon population of judICla1 districts and other condltlonswhich lie out- Bid0 the boundaries of the counties affected. The classlflcatlonado not bear a reasonable relation to the object8 and purposes of the lav and nre not found- ed upon ratlonal differences in the neoessltles or conditions of groups subjectedto different laws. It is our further oplnlon that even If the clas3Iflcationsshould bear a reasonable relation to the object8 or purposes of the law, they me e@bItiw because there are numeroue oountles VIthIn this State with a much greater populetlon than those Included In the provisions vhIch were added to Article 5139 by II.B. 257 and coming vIthIn the same category vhIch have no such juvenile board. Belpg arbitrary clasal- ficatlons, the Bill I3 ln substance a local and spe- cial law In violation of Article III, Section 56, of our State Constitution. It 13 our opinion that the new portion of Article 5139 which was edded by B. B. 257 is unconstItutIonaland VOIU. SUMMARY H. B. 257, Regular Session, 50th Leg- islature, providing county juvenile boards In certain special counties within certain brackets, Is a local and special law with arbitrary clas3IflcatIon3and therefore un- constItutIonal. Art. III, Sec. 56, Texas Constitution. SR:dja Assistant