Untitled Texas Attorney General Opinion

Honorable L, W. Pollard County Attorney Kerr County Ksrrville, Texas Dear Sir: Opinion Elumber'O-4939 Re: Whether stihooldistrict may remove building frbm land deeded to dls- trlct for school purposes aft&r abandonment thereof~and reversion to original grantor. We have received your letters of October 19 and 26~, 1942, relative to the above captioned subject. You enclosed therevlth a copy of a letter written by you to the Prssldent' of the Board of Trustees of the Harper Independent School Dls- trlct. We quote the following from that letter: "As requested by you, I have checked into the follovFng proposition. Some fev year8 ago a tract of land was deeded to the Comirion School District in the Harper area, which ha~5been taken inland is now a part of the Harper Independent School DlstrLct, This deed has a reversionary clause in it as to the effect that in the event the property so conveyed was not used for school purposes the title thereto would revert to the original grantors. After that, the property was voted Into the Harper Independent School District by the member8 in the Common School District and is now a part of the Harper Independent School District which takes In a part of Gillespie and Kerr Counties. The property in question being situated in Kerr County, Texas. "As I understand.,the property as originally deeded, was vithout any improvements but that improvements for use were placed thereon by the Common School District before the question of abandonment occurrwd,and the property ts hot now being airectly used for school purposes, although you are storing some equipment in the building, but no active use has been made of the building for the past several years by the Independent School District. 1 . . Honorable L. W. Pollard, page #2 o-4939 "The proposition you have submitted to me was whether or not the Independent School District had a right to remove a building erected thereon by the Common School District. It is my opinion, although I have found no authorities on this ques- tion, that the District would have a right to re- move such improvements which were placed thereon by the Common School District prior to the abandon- ment thereof for school purposes. Therefore, ~the sole question to be determined in this case, aside from the one mentioned above, is whether the prop- erty has been abandoned for school purposes. The information you gave me Is that you have ceased to use the building for school purposes, but equipment of this nature, which has had no active use, has been stored In this buildlng for a number of gears, "In view of the fact, it Is therefore my opinion that the property has been abandoned for school purposes and the title thereto reverts to the original grantor, together with all the lmprove- ments situated thereon, save and except such per- sonal property you may have located ln this bulld- lng which belongs to the Harper Independent School District. As an ordinary proposition at law, it seems to be elementary that improvements built on another man's property goes with the property, But In this case, if the Improvements had not been re- moved before the abandonment occurred, then I don't think there is any question that the District would have any rights to remove the property. This Is merely cormnon reasoning D" The question In which you are Interested Is stated In your letter of October 2&h, as follows: "Whet%r or not the Independent School Dis- trict of arper, Texas as a successor of the Common School District, has a right to remove a bulldlng from the property which was deeded to the Common School by Individuals, with a condition, that If the property ceased to be used as school property, the title thereto would revert to the grantors, their heirs and assigns." We do not have a copy of the deed for examination, nor do we feel that we have sufficient lnformatlon to pass upon the question of abandonment. We surmise from your letters that there seems to be little doubt among the parties concerned that the property has been abandoned. We think It sufflclent to say that it has been held that the use of a building for the stor- Honorable L. W. Pollard, page #3 o-4939 age of school furniture, books, etc., is not for "school pur- poses' and does not prevent an abandonment of the property under a deed specifying that the property was to be used for such purposes and containing a reversionary clause. See Put- ney v:SchoolDlst. No. 4 of Town of Brookfield (Wise.), 255 N.W. 76; Richey v. Corralltos Union SchoolDist. of Santa Crux County (Callf.), 228 P. 348. However,~we think that so long as the property Is being used for school purposes, the school district could make such improvements OP remove the same as would best serve such school purposes. We shall now pass to the question of whether a school district may remove the school building after the-property has been abandoned for school purposes and, therefore, has reverted to the grantor. ~The property as orlginallg conveyed was with- out Improvements, but the school district subsequently built a schoolhouse thereon, We quote the following excerpts from Texas Jurisprudence, pages 950, 951, and 958: "School trustees ordinarily have the exclus- ive control and management of school property and exclusive possession thereof. In exercising this discretion they may locate and construct district buildings upon such sites, and In ac- cordance with such plans and s~eclficatlons as in their judgment seem proper. '* * *~The laws of Texas, by Implication at least, require that the exclusive ownership and control of school buildings of a district shall be In the trustees thereof," After an exhaustive research, we have found only one Texas case precisely on the question of the removal of a school house after the abandonment of property conveyed under a deed for school purposes and containing a reversionar clause there- Such case Is Allen et ux v, Franks et al. TW. E. Ref.), ,'& S.W. 384. Plaintiffs had conveyed certain property to the trus- tees of a school district and their successors, and the deed of conveyance contained the following stipulation: "Conditioned that when the above-described land ceases to be used as school purposes, the same shall revert to us.' Thereaf,ter,with money obtained through contributions by citizens of the school com- munity a schoolhouse was erected on the property. Defendants as successors to the former trustees to whom the deed was exe- cuted decided to consolidate the district with another district, . - Honorable L. W. Pollard, page #4 o-4939 to move the house upon another location, and to abandon the land upon which the house was originally built. Plaintiffs instituted suit to enjointhe .removal of the building and al- leged that the building was part of the realty, that the land had been abandoned, and that by reason thereof the building as well as the land had reverted to them. It was contended that the contributions for the building were mad,ewith the distinct understanding with the trustees that the building was to re- main upon the land permanently,-~The court, after citing Ar- tlcles 2822, 2844,-~2845,2847, and 2849,,R.S. 1911 (Articles 2748, 2752, 2754, and 2756, R.C.S., 19251, denied plalntlffs any relief and h-oldthat the trustees could remove the school building when the land ceased to be used for school purposes. We quote the following from the opinion of the court: "When the funds were donated for the con- struction of the building, the title thereto passed to the trustees, and the building erect- ed with such funds became subject to the pro- visions of the statutes above quoted. When the contributions were made for the erection of the building, persons making such contrlbu- tions must be held to a knowledge of the statu- tory provisions giving absolute control of the bullding to the trustees and prohibiting the fixin: ;f,a+li:n of any character upon the build- -a. * "If, at the time of the erection of the house, the trustees could make it a part of the realty by their intention to make it a permanent lm- provement upon the land, or by erecting the same without forming any Intention at the time that they or their successors In office might remove it from the land In the event of a decision to abandon the land for school purposes, then they could control the title to the house Indefinitely. Under express provision of the statutes title to the house became vested in the trustees and their successors in office as trustees for those to be benefited thereby 'under such FUleB as may be es- tablished by the state superintendent.' To give appellants' deed the construction lnslsted upon would, in effect, be to say that the trustees who received the deed would have the authority them- selves to vest in appellants title to the school- house wlthout receiving any consideration therefor and would have authority to bind their successors in office to do the same. Clearly, this would not be in the Interest of the patrons of the school Honorable L, W. Pollard, page #5 o-4939 and thus deprive them of title to school property would be a breach of trust and contrary to public policy l * *ll. 'Certainly it was not within the spirit or intention of the statute that those who were beneficially interested In the building could be deprived of title thereto without receiving any consideration therefor by any arbitrary act of the trustees who erected it, when the purpose of such act was not to subserve any interest of the beneficiaries." There would be even more reason for the court to hold as it did If the building had been erected with tax moneys. Other states have reached apparently conf~llctingresults. See Steel v. Rural Special School District No. 15 (Ark. Sup: Ct.), 20 S.W. (2d) 316; Webster County Board of Educatlon'v; Gentry (Kg. Ct. App.), 24 S.W. (2d) 910. AN earlier Texas case might be construed as being somewhat inconslstent with the Allen case. In the case of Stewart,v, Blaln (Clv. App.), 159 S.W. 928, the court had before It for consideration a deed whereby certain property was conveyed to the county judge and his successors In office for the purpose of erecting a school- house for the benefit of the school community. The deed con- tained a clause "that in the event of the removal of the school- house therefrom" the land should revert to the grantor or his heirs or assigns. A schoolhouse was builtand the property was used for school purposes for several years; however, thereafter it was not so used, and the county judge, county commissioners, and school trustees attempted to convey the property to defend- ant. Plaintiffs were heirs and assigns of the original grantor. The court held, In part as follows: "It seems to us that these provisions mean, and were intended to mean, that the grantees should own and use and enjoy the property so long as It was so used for the purpose for which It was conveyed, and that when this condition ceased the title and right of possession should at once revert to the grantor, 'or his heirs or assigns' +**** 'I** * This sale and the abandonment of the land for school purposes was to all intent8 and purposes 'a removal of the schoolhouse there- from'. The building may be there yet, but It IS not a schoolhouse." Honorable L. W. Pollard, page #6 o-4939 However, even though the Stewart case has been cited many times as authority by more recent cases, we feel that we are compelled to follow the Allen case. The Allen case was later in time than thenStewart case, and writ of error was refused. Also, the precise question was Involved in the'~Allen case, and not In the Stewart case, and if the Stewartcase 13 inconsistent, it Is only Inferentially so. Therefore, until the opinion of the court In the Allen case is overruled or altered, we feel that we are compelled to follow the holding thereof. You are, therefore, ad,visedthat where, under a deed containing a reversionary clause, land has been conveyed to a school district for school purposes only and thereafter a schoolhouse is erected thereon, the school district may re- move such building when the property has been abandoned for school purpose and has reverted under the deed to the grantor. Very truly yours ATTORNEY GENERAL OF TEXAS By s/George W. Sparks George.'W.Sparks Assistant GWS/s/wc APPROVED NOV 10, 1942 s/Grover Sellers FIRST ASSISTANT ATTORNEY GENERAL Approved Opinion Committee By s/BWB Chairman