Untitled Texas Attorney General Opinion

-’ - THEATITORNEY GENERAE OFTEXAS A-RN- DsLCNF,-L . . .,...... _ _.- . . -._.-.-.--_.-._ Hoa..T. M. Trlmble Opinion m:o-905 First Assistant Ret (a) From what fund, school or State SuperInt endent county, should court costs and attor- Austin, Texas ney’s fees incIdent.to foreclosure by county of vendor’s lien on county school lands, be paid. (b) From what fuud, school or county, should delin- quent and current taxes on county school lands be paid by county owning same. (c) Should the County Schol- astic 4pportIontnent be first taken from the County Available School Fund before other allowable disbursements Dear Slrt are made therefrom. By your letter of June 13 1939, you request the opin- Ion of this Department upon the foliowing questions which we uote from letter to you of date June 12,1939, from the County 8 chool Superintendent of At~ascosa County: “In 1927 our Commissioners’ Court sold a part of our school lands In LaSalle County, Texas, constituting the Permanent School Fund of our county. $5312.91 was paid in cash and balance of consideration being evidenced by a vendors lien note for $53,1.29.16. The principal of this note was reduced by payments to $37,500.00 and the Interest at 6% was kept paid up to 1935, when default was made in further payments and purchasers also allowed taxes to be- come delinquent. “The land has been ‘subdivided and sold to purchasers ,In Texas and other states. Our Commissioners declared the entire debt due for default and instituted Inquiries to locate the parties so that citation might be served upon them in suit to foreclose our lien. This cost amounted to $200..00. “Our Commissioners’ Court will shortly make requisi- tion upon school authorities and the County Board for ap- y $3 000.00 to pay delinquent and current taxes, 750.60 attorneys fees and court’costs estimated to $500.00. Hon. T. M. Trimble, page 2 ~(0-985) “All payments on the principal have been credited as made to the Permanent School Fund of our County and all Interest payments as made have been credi.$ed to the ,County Available Fund. “Please advise me if it 1s the duty of the County School Board and County Superintendent to pay this out of school funds. If so, from what fund. Should we not take care of the balance’ of the County Apportionment which is $C& per scholastic before this ~fund is used for ‘any other purpose?” The constitutional and statutory sohool funds are the atate Permanent School Fund,, the State Available School Fund, the County Permanent School Fund, the County Available School Fund, ,Loaal School Funds derived from maintenance taxes levied by the various school districts, and School Bond Sinking Funds of the various districts. The State Permanent School Fund and the County Permanent School Fund are constitutional funds, and it is provided expressly ln the pertinent sections of the Texas, Constitution that lands, or the proceeds thereof, constituting such funds, shall be held ln trust for then public free sohools. With these funds we have no oon- oern beoause the applicable constitutional and statutory provisions dlreot their Investment in oertaln designated bonds, and It is only the interest therefrom which beoomes the State and Count Available School Fund, respeotlvely subjtiot to annual apport f on- ment for the support of the publlo,)ree sohools. Acoordlng to the leading case of Dallas Co. vs. Club.Land and Cattle Co., et al., 66 6.~~294, it is the gross rather than the net proceeds from the sale of school lands whlch.,should go into the~county Permanent ,‘Bohool Fund for investment e Under this case no part of the oash rooeeds from the sale in 1927 of sohool land8 owned by Atasoosa 8 ounty in LaSallr County or subsequent. prlnolpal payments thereon, constituting the County Permanent Sohool Fund of said County, may lawfully or constitutionally be diverted for the payment of our- rent, and delinquent taxes on such lands or ior the payment of lttorney’r fear and oourt oosts InoldenC to the pending foreolor- ure and sale thereof,, and the rohool authorltlrr of Atasoosa County rhould not draw against the County Permanent Sohool Fund for these expenditurea. With equal deflnlteness, can It be said that Looal School Fundo derived from maintenance taxes and Interest and Slnklng Funds derived from bond taxes, levied by t,he various sohool dls- trlote, cannot be called upon to pay any of the costs, expenses or taxes mentioned ln your letter. These expenses and taxes aooryed In conneotlon with the sale, preservatl,on and proteotlon of sohool lands owned by the county in trust for the schools of the county . . Hon. T. M. Trimble, page 3 (O-985) generally, and maintenance and bond taxes of the various school districts of the county are not levied for any such general pur- poses or expenditures but rather for specific local purposes. And to pay the expenses and taxes involved in the instant ques- tion out of a fund derived from taxes levied to pay interest and create a sinking fund for the purpose of retiring bonds voted by a particular district, would constitute, under all the authorl- ties of this State, an unlawful diversion of such funds. It but remains to determine whether or not the taxes and expenses involved in your question are chargeable against and pay- able from the two remaining school funds, to-wit the State Avail- able School Fund or the County Available School l&nd, or if from neither of these, from what funds of the county they might be paid. The disposition of these two funds is governed by Section 1, Articl,e 2827, Revised Civil Statutes of Texas, which provides as follows: “The public free school funds shall not be expended except for the following purposes: “1. The State and county available funds shall be used exclusively for the payment of teachers’ and super- intendents’ salaries, fees for taking the scholastic census, and interest on money borrowed onsh& time to pay salaries of teachers and superintendents, when these salaries become due before the school funds for the current year become available; provided that no loans for the purpose of payment of teachers shall be paid out of funds other than those for the then current year.” In 1930, Chapter 49? General Laws, 4th Called Session, klst Legislature, modified the foregoing pre-existing statute upon this subject by providing that from and after August 31, 1930, the salary and office expenses of the county superintendent of pub- lic instruction and such assistants as he may have shall be paid out of the school funds of the common and independent school dls- trict of the county. It is apparent that with this statute, en- larging the expenditures allowed by Article 2827, Revised Civil Statutes, we have no concern under the facts submitted. But we are concerned with the provisions of ,kticle 7150a, Vernon’s Annotated Civil Statutes, enacted subsequent to said Article 2827, Revised Civil Statutes, and enlarging the scope of same to provide’ that the County Available School Fund, if such there be, may be used to pay county and district taxes on county school lands o This statute provides as follows: “Any county in this State owning any land mentioned and referred to in Section 6a of Article VII of ,the . . Hon. T. M. Trlmble, page 4 (O-985) Constitution of Texas adopted by the people as en amendment to the Constitution under S.J.R. No. 10 of the Regular Session of the 39th Legislature, is hereby authorized to pay taxes duly and lawfully levied on the same out of the CountyPs revenue derived from such land. In the event any County has no such revenue, such taxes shall be paid out of the general fund of the .County, and If any County has sufficient of such revenue to pay only a portion of such taxes the remainder shall be paid out of the general fund of the County.” Under the express authorization of the -foregoing statute, we advise that the county school authoritiesof Atascosa County may, in the mode and manner provided by Articles 2693 and 2830 Revised Civil Statutes, draw and approve vouchers against the Available Sob001 Fund of said county, if any there be, for the purpose of pay- lng,current and delinquent county and district taxes against school laud owned by said county in LaSalle County in the approximate amount of $3,000QO0, subject however to the limit at ions and condi- tions hereinafter discu.ssed. These conditions and limitations are: (1) The only classification of county school lands subject, under the Constltu- tlon of Texas to county and district taxation are “agriculture or grazing school land,” and the County Available School Fund cannot be drawn upon, under Article 7150a, Vernon’s Annotated Civil Stat- utes, to pay such taxes accruing against other classifications of sohool lands such as timber land. This is by virtue of Article 7, Sea, 6a, Constitution of Texas, whiah reads as followsa l’All a riculture or grazing school land mentioned In section % of this article owned by any county shall be subject to taxation except for State purposes to the same extent as lands privately owned. (Sea. 6a, &t. 7, adopted election November 2, 1.926; proclamation January 20, 192;b)” Construlng this section of the Constitution the Court in Childre ss County vs. Morton Ind. School Dlstrlot, 45 S.W.(2d) 1031, spoke pointedly as follows: Wnder seotion 6a, supra, of the Constitution sohool lands belonging to any county are not taxable unless such lands are agricultural or grazing land. Manifestly, there- fore, if a county’s school lands were classified as tlti b,ered lands, they would not be subject to taxation.” It is not made to appear from the facts submitted with your letter whether or not the school land in question is agrloul- tural, grazing or timber land, and we consequently deemed it not . . .., Hone To M. Trlmble, page 5 (O-985) amiss to point out for your guid,ance the ‘fo’regoing limitatj.on of tax liability. (2) A second ~limitation orcondition upon the right and authority oft the county school boar.d to pay current and delinquent county and district taxes against school lands owned by your county, out of the County Available School Fund, ‘under Article 7150a, Ver- non’s Annotated Civil Statutes, is that the county is not liable for such taxes during the tlme~ same was owned by the purchaser thereof In 1927, or until the land shall be reacquired by the county on foreclosure, of Its vendor’s’ lien; but, of course, the taxes which ,accrued-kin this interim would ‘be secured by a lien upon the land which Atascosa County could elect either to .,discharge by pay- ing taxes or to allow s&e- to be sold for taxe’s. This is made plain by the following language of the ‘court In the case of Childress County vs. State, 92 S.W. (2d). 1011: “It Is disputed from the facts certlfled that Enochs ownedY he lend in controversy on Januarylst of the years 1931 1932 and, 1933- Enoch’s ownership there- of on January i, 1933, created a~liabllity on his part for the taxes, levied upon such property for that~ year . s . .“When the land reverted to Childress County, It was reacquired subjaect to the taxes due thereon while it was privately owned. Therefore, Childress County can pro- teat It’s lnte,rest in the land by paying the taxes due Cochran County for the years 1931 and 19,32, or let it be sold for such taxes.” (3) Aaother limitation or condltion’upon the application of Article 7150a Vernon~ls Annotated Civil Statutes considered in connection with Aec. 6a, Article 7, Constitution of’Texas Is that only that portion of the County Available School Fund whiih repre- sents rental or other income or revenue from the m sohoph u Involved In your question while sane was prraed bv Atas- urivately owned, can be used for paying the taxes We rest this conclusion upon Opinion No. O-215, of date February 18,,1939, directed to, Honorable Ralph Logan,’ County Attorney, Tom Green County, wherein the writer made the following well-considered observatlonst “This article was intended to cover the kl.nd of situation you shave in this case. In the facts you have stated you’ say that since October 1, 1935, Tom Green County has received about $24,000 as interest money and lease ‘money from all of its school lands, only a small portion of this being from this particu- lar land 0 We believe that nn1.v’the rev~~+?~e derived . . Hon. To M. Trimble, page 6 (O-985) from the particular land can be used to pay the County and School District taxes due on this land, and this hellef is because this statute says the Commissioners’ Court shall pay the taxes ‘out of the County’s revenue derived from m land.’ “Such land’ means the particular land from which the reve- nue is derived. *IWealso believe that only revenue derived from this particular land after the State owned the land can be used to pay these taxes and this belief is be- cause the statute says ‘any county . . . y any land mentioned and referred to in Section a of Arti- cle VII. . . is hereby authorized to pay taxes. . . levieu on the same. . .I. The land must be actually owned by the State in order for the revenue from it to be so used, and revenue from the land in the form of interest on vendor’s lien notes derived before the county regained title to the land could not be used to pay these taxes. You say that ‘during the latter part of 1937 and the early portion of 1938 this county foreclosed its vendor’s lien,’ and we as- sume it obtained title at that time.” (4) Lastly, Article 7150a, Vernon’s Annotated Civil Statutes, authorizing the payment of county and district taxes upon county school lands out of the County Available School Fund, is hedged about with the limitation or condition that such pay- ment may be made only after the annual apportionment of the County Available School Fund by the county school trustees, act- ing with the county superintendent, on a pro rata basis accord- ing to the scholastic population in accordance with the manda- tory requirements of Articles 2685 and 2692, Revised Civil Stat- utes. The County ,Avallable School Fund is, under controlling constitutional and statutory provisions, held In trust to be applied annually to the support of the public free schools of the county; and, in our opinion the annual apportionment of such fund for the exclusive and dire& .support of such schools, in the pay- ment-of teachers’ and superintendent’s salaries, as provided by Section 1 of Article 2827, Revised Civil Statutes, should not be disturbed by the permissive right given by a subsequent statute, to-wit; Article 7150a, Vernon’s Annotated Civil Statutes, to pay county and district taxes on school lands out of the County Avail- able School Fund or out of the General Fund of the county in the event there is no Available School Fund. All of these statutes should be construed harmoniously, if possible, and this allowable contingent payment of taxes out of the General Fund of the county is, to our mind a legislative indication that the County Avall- able School Fun B to the extent of the annual apportionment there- of, should be fiist devoted to the purposes of such apportionment and note diverted to the payment of taxes on school lands. iion. ‘1’. hi. Wimble , Page 7 /i i ‘. of the publia free schools of the oounty; ad, in our opinion the annual apportioment Of such fund. ior the exclueive and direot sUpPOrt of such sohoola, In the payment oi teachers* ana supar- intenaents’ salaries, as provided by Seotion 1 or Artiole 2~27, Revisal Civil Statutes, should not be disturbed by the permissive right given by a subsequent statute, to-wit: ~rticla 7l5Ga, Ver- non’s Amotatea Cfvll Statutee, to pay county and dlstriot taxes on school lands out of the County Available School Fund or out or the General Fund of the eouuty in the event there is no Available School Fund. All of these statutes should be oonstrued harmoniously, if possible, and this allowable oontlngent payment or taxes out of the General Fund of the county LB, to our mind, a legislative inaioa- tion that the County Available Sohool Fund, to the extent or the annual apportionment thereof, should be first devoted to the purposes or such apportloxunent ana not diverted to the payment or taxes on 6ahOd lands. We oome now to 00daer what partioular rm.8ohool. county or otherwise, may be lawfully ahargea with oertaln axpens& incident to the roreclosure in court by Atasoosa County or the V~INIOP’B lien which it retained on a sale of lte Llohool land8 in XaSalle county, namely, attorney's fees in the approximate sum or #oao.oo and aourt costs ranging rr0m $SSO to $600. The rot-e- going aiseussi0n ie oonrfnea to the proper rund iron whioh oarrent anb delinquent oounty and al&riot taxes on sohool lands may be properly paid. Suah taxea'rest upon a diiferent basis than a0 the expenses enumerated above, and we have seen that payment ,of euoh taxes, In certain aontingenaies, out of the County Available Sohcol , ~&n&, wa8 allowable only by viftue of an express leglelative enact sent upon the oubjeot, to-wit, Article 715Oa, Vernon's Annotated 6ivll Statutes, which beaame erreotive September.7, 1927. We also pointed out one other lnstanoe, an Aat or the 4let Lagislature in 1980, weereby the Legislature enlarged the allowable expenditures from the publia rree sahool tund originally authorized by Seotion 1 of Artiale 2827, Revised Civil Statutes. It ispatent that attorney's fess and aourt coat&, lnoldent to foreclosure of the aoutxty's ven- dor*s lien on sahool lands, ao not, under any tenable aonstruotion, some within the saope of the 0itea etatuts, originally enaoted in 1905, or in subsequent mdifioations or enlargemante thereof in 1989 .ind 5930, hereinabove fully dlsoussed. .And we make the pro+ osltlon that unless such expenses is11 s&rely within the author- Psea expenditures allowed by suoh Etatute, Seotion 1, Artiole 2827, Revised Civil Statut.es, the sahool imthorities of your oouuty would not be authorized to draw or ~‘approve vouohers therefor against the :Publia. tree seh001 rund or the aounty, 4 . . Hon. T. M. Trimble, page 8 (O-985) trust, but in many cases they are impressed with a special trust limiting their use to special educa- tional spheres, and in such case, of course they can be used for no other.’ 24 Ruling Case i aw, p. 594, S 48." To the same effect is the case of San Benito Inde endent School District of Cameron County vs. Farmers State Bank, 7ii S.W. (2d) 741, involving an attempted transfer of funds between four separate school accounts, and holding that “it is too well settled to require citation, or any extended discussion, that a public fund selected and ,allocated for a particular public purpose cannot law- fully be diverted to the use of another particular public purpose.” The case of Dodson vs. Jones, 190 S.W. 253, held that Revised Statutes, 193.1,Article 2772 (being now Article 2827 Re- vised Civil Statutes, above cited uy us) providing that the &ate and county Available School Funds shall be used exclusively fork the payment of salaries of teachers and superintendents and fees for taking the scholastic census, etc. and that the surplus of the State fund may be used to pay janitors and other enumerated pur- poses, does not authorize payments from the Free School Fund to a principal as janitor. Another decision limiting expenditures from the public free school fund of a county to those specifically enumerated by statute is Thompson vs. Elmo Independent School Dis- trict, 269 S.W. 868. This fundamental principle of school law has been recog- nized by successive opinions of this Department. In 1927 an opin- ion to the then Superintendent of Public Instruction held that funds collected from a lease of county school lands, which i-s clearly a part of the County Available School Fund, could not be used to fence said lands. In an opinion of date June 17, 1931, addressed to Honorable V. H. McClintock, County Attorney, Cot’cle County, It was held that the Commissioners’ Court was without au- thority to demand that the county school superintendent issue a voucher on County Available School Funds to pay the proportionate part of the cost of making an audit of the books of county offi- clals. And again on December 7,,1935, in an opinion to Honorable Winfred F. Newsome, it was held that the County Available School Fund could not be used for the purpose of purchasing land at sher- iff sales. Havlng determined that attorney’s fees and court costs incident to the foreclosure of the vendor’s lien retained by Atas- cosa County on the sale of its school lands in 1927, are not pay- able out of any of the constitutional and statutory school funds named at the outset of this opinion, it appears we have fully an- swered your questions, because the only issue involved therein was whether or not it was the duty of the county school board and Hon. T. M. Trimble, page 9 (O-985) county superintendent to pay these expenses out of school funds, and if so, from which school funds. But in holding that these items of expenditures were no t payable out of any of the speci- fic school funds ‘named and discussed, we did not mean to hold that certain statutory court costs accruing in connection with the foreclosure of the ven.dor’s lien in question would not be payable out of the proceeds in the hands of the sheriff on sale of the land under order of sale. Nor did we mean to hold that such items of expense would no.t be payable out of the proper funds of the county. Hence to avoid confusion, we shall briefly discuss these two sources of payment. As regards the payment of the items of expense now under consideration, we point to a distinction between proceeds derived from a sale of county schoo 1 lands a.t private sale and proceeds derived from a sale of such i:ouhty school lands at sheriff’s sales, under order of sale, after foreclosure of the county’s ven- dor’s lien through coil.rt proceedings. In the former instance the Supreme Court of Texas i.n the case of Dallas County vs. Club Land & Cattle Company; 66 S.W. 294, and the Austin Court of Civil Ap- peals in the case of Brazoria County vs. Padgitt, et al, 160 SeW. 1170, have held that certain expenses attending a prlvate sale of county school lands such as surveyorss fees, traveling expenses, commissions, incidental charges, etc. are not payable either from the gross proceeds rea.lized from such sale or by a conveyance of a portion of the land, but rather are payable out of the General Fund of the county; and all of the gross proceeds of the sale must be paid into the County Permanent School Fund for investment In the constitutional manner. But in the latter instance,, that Is to say, where county schoo..7 I.and is sold at sheriff’s sale upon foreclosure p through court proceedings, of the vendor’s lien held by the county, the Supreme Cou.rt of Texas in McLennan County vs* Graves 64 S.Wp R&l., has h,el.d that the funds in the hands of the sherifi by virtu,e c,f s,uc.h sale may lawfu.lly be first applied t!o’payment of costs ir~curred in its collaation the balance to go into the school funds of the i:ounty. In that last case MoLsnnan County made the contention that ,the sta.tutory oommiesion allowed the sheriff on axec’uti.on sales and the statutory court ooats could not be appropriated out of the moneys or Punda realized from such sale, because such moneys bel.onged to the oounty school fundsi but, grounding its decision upon the general rule that the aost of enforcing a claim has prior ri.ght to satisfaction out of money cob lected in the proceeding, the ccurt allowed the sheriff’s commis- sions and proper court costs to be deducted Pram the proceeds of th,e sale, before the transfer of same into the Permanent School Fund of McLennan CourityO In regard to the attorney@s fees and court costs involved in the instant qrxesti~n,~ kcl.u.dir,g such statutory court coats as are embraced in the rule announced above, we are of the opinion that such expenses are payable out of the General Fund of Atascosa County. Hon. T. M. Trimble, page 10 (O-985) Several of the opinions of this Department hereinabove referred to, so hold in connection with the expenses therein in- volved, as well as an opinion of the Department to Hon. J. I-I. Foster, County Judge, RainsCounty, of date May 1 1931. The facts involved In the latter opinion closely para i lel those of the instant question in that the expenses sought to be paid from the County Available School Fund were to protect the county’s rights in school land ,which had been sold on time and default made so as to throw the land back on the county. Assuming that the attorney’s fees and court costs de- scribed in your letter are otherwise lawfully payable (a question upon which we venture no opinion), we believe a statutory duty rests inferentially but squarely upon Atascosa County to pay such fees and expenses from the General Fund of the county under Artl- cle 2826, Revised Civil Statutes, which provides as follows: ‘IIt shall be the duty of the commlssloners court to provide for the protection, preservation and disposition of all lands heretofore granted, or that may hereafter t;o;;nted to the county for education or schools. ., art. 7, sec. 7.)” Concerning expenses incident to a private sale of county school, land .but , in principle, applicable to expenses of a fore- clo’sure sale of such lands as involved here, the Supreme Court, in Dallas County vs. Club Land and Cattle Company, eupra., well stated the reasons justifying the placing of this burden upon the General Fund of the county: ‘1. . . As to the reason of the provision, it may be urged that, since the county is made a mere trustee, ,it is unreasonable to suppose that it was intended to charge it in its individual capacity with the expense of administering the trust fund. The answer is that while, in legal contemplation, ,the county is but a trustee, and the school fund the beneficiary, .the county has an important interest in the maintenance of public schools within its limits; and. that it is not unreasonable that the framers of the constitution should have deemed it politic to make the expense of administering afund set apart for the support of public schools in the county a charge upon its general revenues. Since the lands are the gift of the state for ‘the special benefit of the educational interests of the county, it is not a hardwhip to require the county administration to bear the expense of converting the land into money. . .‘I Hon. T. M. Trimble, page 11 (O-985) Trusting the foregoing adequately answers your several inquiries, we are Yours very truly ATTORNEYGENERAL OF TEXAS By /s/ Pat M. Neff Jr. Pat M. Neff, Jr., Assistant APPROVEDAUG15, 1939 /s/ Gerald C. Mann ATTORNEY GENERALOF TEXAS APPROVED:OPINION COMMITTEE BY: R.W.F., CHAIRMAN PMN:N:wb