Untitled Texas Attorney General Opinion

The Attorney General of Texas JIM MATTOX July 1, 1985 Attorney General Supreme Coun Building Eouorable Lloyd Cr,l~w Opinion No. JM-329 P. 0. Box 12548 cheirQlan A”,llrl. TX. 78711.2546 Committee on Labor and Employment Re: Authority of a city to 5121475.2501 Relations establish prevailing wage Telex 9101674.1367 ~e,scopier 51214750266 Texas Rouse of Repmaentativea rates under article 5159a, P. 0. Box 2910 V.T.C.S. Austin, Texas 78X9 714 Jackson. Suits 700 Da~hr. TX. 75202-4506 Dear Representative Criss: 2147428944 You have inquired about the propriety of the procedures being u)24 Albd,,~ Ave.. Suit0 160 used by the city elf Rouston to determine the prevailing wage rates to E, paso. TX. 793052793 be paid to workem engaged in the construction of public vorka for 9lY533-3464 that city. You state that 1001 Texas. Suite 700 obvioual.g , the establishment of 5 prevailing wage “ous.,o~, TX. 77002-3111 rate for building construction by the city of 7l312235886 P.ouston will dramatically effect the livelihood of many voxking people in the Earris County area. 906 Broadway. Suite 312 It i~r my understanding thst the city of Eouston ,.ubWck. TX. 79401.3479 806i747-52% city corn~cil intends to adopt an alleged wage rate study recently completed by 5n independent con- tractor ‘to the city in the very near future. The 4309 N. Tenth. Suite B basis I’or the findings and conclu5iona of this McAllen. TX. 78501~1685 512l6S.24547 alleged atudy~ is a veighted average rather than determixlng a general prevailing wage rate. 200 Main Plaza. Suite 400 My concern relates to the methods used ‘by the San An,on,o. TX. 782052797 city’s agent to establish such a prevailing wage 5121225-4191 rate vhen tested by the una.mbiguoua proscriptions and a~:atutox-y directives of article 5159a. An Equal OppOftunilYl V.T.C.S. Affirmalive Aclion EmPbYer The pertinent parts of article 5159s read as follova: Section 1. Not leas than the general pre- vailing rate of per diem wages for vork of a aimilax character in the locality in which the work is performed . . . shall be paid to al1 laborel s, workmen and mechanics employed by or on behalf of the State of Texas, or by or on behalf of anJ’ county , city and county, city, town. p. 1507 llonorable Lloyd Crlar - Paat. 2 (RI-329) district or other political subdivision of the Stste. engaged III the construction of public works . . . . Sec. 2. The public body awarding any coutract for public work . . . or otherwise undertaking any public work, ahat:, ascertain the general pre- vailing rate of per diem wages in the locality in vhich the vork is to be performed for each craft or type of vorkmm or mechanic needed to execute the contract. . . . . . . . Sec.4. . . . . The term ‘general prevailing rate of per diem wages’ shall be the rate deter- mined upon as such rate by the public body avardlng the contract, or authorizing the work, whose decision ia the matter shall be final. It is mandatory thrt the public body state such prevailing wage as a sum certain, in dollars and cents. Nothing 111 this Act, however, ahhall be construed to prohibit the payment to, any laborer, workman or mechanic employed on any public work as aforesaid of more ,than the said general prevailing rate of wages. One of the primary purposes of the statute is to protect workmen, laborers. and mechanics from being required, if they accept employment, to work for leas than the prevailing wages paid . . . for the same class at.d character of work. Southern Prison Co. v. Renuels. 110 S.W.Zd 606, 609 (Tex. Civ. App. - Auarlllo 1937. writ diam’d~, This conclusion “aa quoted 55 authori- tative by the Texas Supreme Court in Texas Righvay Cosmiaaion v. El Paso Building and Conatrwtion Co., 234 S.W.Zd 857 (1941). and has been recently reaffirmed cl a case vhich reiterated that a primary objective of the statute rre.5 “to protect the workman from working at rates below the prevailing; wages in the locality.” Cullipher- v. Weatherby-Godbe Construction Company Inc., 570 S.W.2d 161. 164 (Tex. Civ. App. - Texarkana 1978, writ dism’d). The genesis of the Texas Prevailing Wage Statute, like that of the federal Davis-Bacon Act, 46 Stat. 1494 (codified as amended at 40 U.S.C. 55276a to 276a-5 (13132)). upon which it was modeled, is clearly stated in the act’s “emergancy clause” as follows: Sec. 7. The fact that there 15 uo adequate lav protecting laborers. workmen and mechanics engaged p. 1508 .. ’ * Ronorabla Lloyd Criaa - Paga 3 (J&329) in doing and perfomiug vork on public vorka in Texas and ita political aubdivlalona. and the further fact that many contrqctora are taking advantage of the present iaduatrisl and ccoaomic condition to beat d,wn vages to a lavel far belov that required co mslntain a laborer. vorkman or mechanic in reasonable circumstances, and the further fact that this condltloa has created a social problem dewnding the immediate attention of the legislative department of our State, create an emergency and an imperative public neces- sity. . . . Acts 1933, 43rd Leg., ch. 65, 07, at 93. While the Texas lav did not set out a methodology for t!x determination of the prevailing vage rates for the respective trades, this office very early held that It vas the duty of the appropriate governing body ‘to ascertain the general prevailing vage rates” for the respective trades in the locality in question. Atto,rney General Opinion O-2059 (1944). This opinion simply restated thd straightforward statutory directive to establish what is “the gexral prevailing rate” of pay for each particular craft and trade. The essence of this statutory mandate 1s simply that the governmental entity determine for its locality what actual wage rate is predominant for each craft. Article 5159a requires a governmental body to pay “the general prevalllng rate of per diem Tdages.” but it does not define the term. Although section 4 delegates that determination to “the public body awarding the contract ,” the statute clearly requires that, in making the determination, a methodology be adopted vhich demonstrates compliance with the “prevailing wage” standard. Your question Implies that “prevailing Wage” and “veighted average” constitute different standards. Assuming this ~1s correct, if a city adopts a “veighted average” standard, in cont’rast to a “‘prevailing vage” standard, it has. in our view, failed to c,omply vith the statute. SUMMARY A city is requl,red by article 5159a. V.T.C.S.. to pay “the gene,:al prevailing rate of per diem wages” in avarding a contract for public works construction. - JIH MATTOX Attorney General of Texas ‘,. 1509 Hooorable Lloyd Criss - Page 4 (Jn-329) TO?l GREEN First Assistant Attorney Ceruxal DAViD R. RICHARDS Executive Assistant Attorney General ROBERTGRAY Special Assistant Attorney General RICK GILPIN Chairman. Opinion Committee Prepared by Colin J. Carl 6 Rick Gilpln Assistant Attorneys General APPROVED: OPINION COMMITTEE Rick Gilpin, Chairman Colin Carl Robert Gray Jim noellinger Jennifer Riggs Sarah Woelk p. 1510