Untitled Texas Attorney General Opinion

OFFICE OF THE ATTORNEY GENERAL OF TEXAS AUSTlP+l Honorable George W. Cox State Health Officer State Board of Health Austin, Texas Dear Sir: Opinion Iloa7131 Re: Authorltr of the S Health to pas8 Nl tlons ooverlng the We h8ve your letter quest the opinion of this office tuberculosismight be detained treatment center for such pur- ternnight be not unlike to the disease treatment program. . ." '1 E&i& Biblical tlmes when the Lepers were commanded to dwell alone, "Without the camp shall his habitation be" (Levltl- CUB 13:46) all civilized communltleehave recognized the necessity of quarantine regulations. Among all the objects sought to be se- @red by governmentallaws, none la more important than the pre- servation of the public health; and an imperativeobligationrests Honorable Qeorge W. Cox, page 2 upon the State, through Its proper lnstrumentalltlssor agenoles, to take all neoessary steps to promote this object. The police power, which 1s Inherent In the State, may be invoked for this purpose and the most extensive powers may be conferredon local health officers. The paver of the legislature to prevent the lntro- duatlon and spread of infectious and contagiousdiseases caanot be questioned,and, accordingly,health authoritiesare usually empovered to take such action as may ti consideredexpedient to prevent the outbreak OS epldemlo and oommunloablediseases. Thus all NleS and regulationsadopted pursuant to legislativeauthor- ity, vhloh are reasonably calculated to preserve the public health, are valid. The power to make quarantine regulationsIs one of the most important oonSerredupon health authoritiesand such regula- tlonr oonatltute a proper exercise OS the police power. These general prinolplesare ao firmly entrenched in our system of jur- isprudenceas to admit of no conjecture,and we therefore cite no oases to sustain them. Your attention Is directed to the annota- tion in 2 A. L. R. 1539 and the legion of cases there cited. With these general prlnolples in mind, we proceed to a considerationof the question betore us. An exeminatlonof - Vernon's Annotated Revised Civil Statutes reveals the following pertinent statutoryprovisions: qArtlole 4419. The State Board of Health shall have general supervisionand control of all matters pertaining to the healtii‘ofcltleena of this State, as provided herein. It shall make a study of the oauses and prevention of lnteotlon of contagious diseasesaffecting the lives of citizens vlthin this State and except as othervise provided In this cbap- ter shall have direction and oontrol of all matters of quarentlneregulationsand enforcementand shall. have full power and authority to prevent the entrance of such diseases from points without the State, and shall have direction and control over sanitary and quarantinemeasures for dealing with all diseases vlthin the State and to suppress same and prevent their apread. The president of the board shall have charge of and superintend the admlnlstratlonof all matters pertaining to State quarantine. Acts 1909, Honorable George W. Cox, page 3 1st‘C. s., p. 340; Acta 1913, p. 147." 'Article 4427. Each county health officer shall perform such duties as have been required of county physicians,with relation to caring for the prisoners ln county jails and in caring for the in- mates of county poor farms, hospitals,discharging duties of county quarantineand other such duties as may be lavf'ully required of the county physician by the oommlsslonerscourt and other officers oS the county, and shall discharge any additional' duties vhlch It may be proper for county authorl- ties under the present lava to require of county physlclans;and, in addition thereto,he shall dls- charge suoh duties as shall be prescribed for him under the rules, regulationsand requirementsof the Texas State Board of Health, or the president there- of, and Is empowered and authorlted to establish, maintain and enforce quarantine vlthin his county. lieshall also be required to aid and assist the State Board of Health In all matters of local quar- antine, Inspection,disease prevention and suppres- sion, vital and mortuary statisticsand general san- itation vithin his county; and he shall at all times report to said State board, in such manner and form as It shall presorlbe, the presence OS all contagious, iniectlousand dangerous epidemic diseases within his jurisdiction;and he shall make such other and fur- ther reports in such manner and Sorm and at such times as said State board &all direct; touching on such matters as may be proper for said State board to direct; and he shall aid said State board at all times In the enforcement of lta proper NleS, regu- lations, requirementsand ordinances,and in the en- forcement of all sanitary laws and quarantine regu- lations within his jurisdlotlon." "Article 4430. Each city health officer shall perlorm such duties as may be required of hlm by gen- eral law and city ordlnanoes with regard to the general health and sanitation of towns and cities, and perform such other duties a8 shall be legally required of him by the mayor, governing body or the ordinances of his city or town. He shall discharge and perform such duties as may be prescribed for him under the directions, Honorable George W. Cox, page 4 Nles, regulationsand requirementsof the State Board of Health and the president thereof. He shall be re- quired to aid and asslat the State Board of Health In all matters of quarantine,vital and mortuary statls- tiCB, Inspection,disease prevention and BUppIWBBiOn and sanitationulthln his jurisdiction. He shall at all times report to the State Board of Health, In such manurerand form as Said board may prescribe, the presence of all oontagious,inieCtiOUSand dangerous epidemic diseases within his jurisdiction,and shall make such other and Further reports in such manner and form and at such times as Said State board shall direct, touching all such matters as may be proper for said board to direct, and he shall aid said State board at all times in the enforcement Of proper Nle8, regulationsand requirementsIn the enforcementof all sanitary laws, quarantine regulation8and vital statlstlcsoolleotlon,and perform such other duties as said State board shall direct.* 'Ai.tlcle4477. The following Nles are here- by enacted as the 'SanitaryCode for Texas,' adopted for the promotion and proteotlon of the pub110 health and Sor the general amelloratlon of the sanitaryand hygienic condition within this State, for the suppres- sion and prevention OS Infectiousand contagiousdie- eaees, and for the proper enforcement of quarantine, isolationand control of such diseases, to wltt "Rule 1. Physician to report.--Everyphysician in this State shall report in writing or by an acknovl- edged telephone communicationto the local health au- thority, immediatelyaster his or her first professional vlslt, each patient he or She shall have or suspect of sufferingwith any contaglouqdisease. If such disease Is of a pestllentlalnature, he shall notify the Presl- dent of the State Board OS Health at Austin by telegraph or telephoneat State expense, and report to him every death from 8UCh disease Immediatelyafter it shall have oocurred. The attending physician is authorized to and he shall place the patient under restrictionsof the charac- ter described herein In the case of each respectivedisease. "Rule 2. 'Local health authority.'--Forthe purpose of these regulations, the term (localhealth authority' shall be held to designate the city or county _. Honorable George W. Cox, page 5 health officer, or local board OS health, wlthln their Mspectlve jurlBdlctlons. "Rule 3. 'COntagiOUB diEeaSeS.'--The term ‘COntagiOUs diSett8e' as used in these regulationsshall be held to Include the follovlng diseases, whether con- tagious or lnfectlous;and as such Shall be reported to all local health authoritiesand by said authority reported In turn to the President of the State Board of Healths Asiatic cholera, bubonic plague, tJphU8 fever, yellor fever, leprosy, smallpox, scarlet fever (scazQatlna)Tdiphtheria (membranouscroup), epidemic cerebrosplnalmenlngltls, dengue typhoid Sever, epl- demlc dysentery, tlurchoma,tUberCUlOBi8and anthrax. (Emphasis supplied) “.* l l "Rule 5. Rules to quarantineand dlslnfectlon.-- !PheSollovlng rules of instructiOnfor the regulation OS quarantine, Isolation and dlBlnSectlon in the several contagiousdlseases,.herelnbefore mentioned, are to be obsemred by all boards of health, health officers, physl- clans, school superintendentsand trusteea, and others. All health authorities of counties, cities, and towns ln this State are hereby directed and authorized to estab- lish looal quarantine,hold in detention,maintain lsola- tlon and praotlce disinfectionas hereinaster provided for. of all such infected persons, vehicles or premls?s which are mected or are Suspected of being infected with any of the above-nameddiseases vhenever found. "(0) Absolute Isolation inClUdea, first, the confinementof the-patientand attendants to one apart- ment or suite OS apartments, to whleh none but author- ized officers or attendants shall have admission; Second, soreentig of room and entire house if necessary vlth not less than 16-mesh vim gauze; third, the prohibition of paselng out of the sick room of any object or material until the same haa been thoroughlydisinfected; fourth, protection of the air of the house by hanging a sheet, kept constantlymolst~wlth a dl.slnSscQint solution, over the doorway:of the patient's room or rooms and reaching from the top of the door; fifth, If in the Honorable Qeorge W. Cox, page 6 Opinion of the local health authority the patient can- not be treated. vlth reasonablesafety to the public, at home. the removal of the patient and exposures to a contagiousdisease hospital or pest house." (Bnpha~l~ supplied) Construing the above statutory provisions In the light OS our introductoryremarks concerning the authority of the State through the proper agencies to promulgate rules and regulationsfor the protection and preservationOS the public health, It follows that the State Board of Health may adopt rules and regulationsfor the purpose of carrying out the provisions of these statutes;and, these rules and regulations,if reasonableand impartial,vi11 be given the full force and effect of lav. In regard to your hypotheticaloase concerning the validity OS rules and regulationsfor detaining for treatment in treatment centers lndlvldualshaving severe cases of highly con- tagious tuberculosis,It Is our opinion t&at the State Board of Health may adopt rules and regulationsfor the removal of indlvl- duals havlpg any OS the "contagiousdiseases" listed in Rule 3 of the Sanitary Code to treatment oenters. These rules and regulations to be valid must be reas- onable and lmpartlal and ln pursuance of and not In conillct vlth Rule 5(o) of the Sanitary Code. That Is, before an individual -suSSerlng Srom a severe case of highly aontaglous tuberculosismay be .removedagainst his will to a treatment center (contagiousdis- ease hospital or pest house) the loaal health authority must be of the opinion that the patient cannot be treated, with reasonable safety to the public, at home. In cases where the local health authority 1s of the opinion that the patient cannot be safely treated at home he may Issue a warrant by virtue of which a lawful arrest may be made Sor the purpose of removing the individual to a treatment center. Ex. parte Hardcastle, (Court of CriminalAppeals) 208 9. W. 531~ Rx. parte James, 181 9. W. (2dj 83. parte Brooks, 212 9. W. 956; 'Eix. Thus, IS In the opinion of the local health authority, an lndlvldual suffering from a severe case of any of the contagious diseases listed in Rule 3 of the Sanitary Code cannot be treated, with reaSOnable safety to the public, at home, he may be removed to a contagious disease hOEpita or pest house. Rules and regula- tlons made In pursuance of Rule 5(c) of the Sanitary Code must not , Honorable George W. Cox, page 7 be arbitrary, ogpresalveand unreasonable (22 A. L. R. 835). Therefore, the opinion of the local health authority that the patient cannot be treated with reasonable safety to the public, at home," must not be arbitrary but must be based on: (1) a thorough medical examinationemploying the standard tests em- ployed by the medical professionIn diagnosing the various con- ta ous diseases listed In Rule 3 of the Sanitary Code, and (8 a thorough investigationof the surroundingcircumstances to determine whether or not the patient may be safely treated at home. The law Is more aptly stated ln 39 C. J. S., Xealth,. Seotlon 15c, from vhloh ve quoter "A person may properly be quarantined ln his residence,and ordinarilyshould be quarantined there unless the danger la suah as to justify quarantine isolation elsewhere. The mere deteralnatlonthat a disease Is dangerousand communlaabledoes not em- power a health offloer to refuse Isolation ln the home by quarantineand placard notice thereof and to consultthe diseased person to a hospital. A per- son may be quarantinedIn a place other than hls resldenoe vhere the clraumstancesso warrant, In vhlch case an appropriateplace for the confinement Is a hospital and not a jall or penitentiary. . .@' We trust the above fully anavers your l.nqulry. Yours very tNly 25 pJ$F . . .f A n ATTORREY ORRRRAL OF THXAS