Untitled Texas Attorney General Opinion

OFFICE OF THE AIYTORNEY' GENEIUL AUS~N, Taxis PRICE DANIEL Augus~t8, 3.947 NTORWEV GENERAL Honorable L. A:Woods, State Superintendentof Public Instruction, Austin; Texas Attention: Hon. T. M. Trimble, First Assistant Opinion No. V-334 Re: Is~suanaeof bonds and levy of taxes by Dallas IndependentSchool Dis- triot. Dear Mr. Woods: In'your letter of.August 1, 1947, you state that the~City Council of the City of Dallas on November 14, l945, callea ad election to be,held on December.0, 1945, on the quest&n whether bonds in the,pr,lncipala- mount of ten million aollars should be issued for sohool purposes. The election was duly and regularly lield~,and a majority.votewas cast in favor of the proposition. On July 29, 1947, an election.was.helaunder the authpr- ity of Senate Bill No. 364, Acts Fiftieth Legislature, which resulted in the separation of the school system from the city of Dallas, and the district is now'known as the Dallas IndependentSchool'Distriot. Prior to the separationelection, the city issued two hundred thousand dollars of the authorized ten million dollars, ana in conn+?tionwith the uq-issued balance you ask our opin- ion upon the following question: ?The question concerning the fore- going is whether or not the .saidten mi-l- lion dollar bona issue, heretofore voted, can now be issued ana a tax in payment thereof levied by the Board of Trustees of the Dallas IndependentSchool District without further submittingsame to a vote of the qualified electors? " ~The ordinance of November 14, 1845, to which you refer called an election on separate propositions - . Hon. L. A. Woods - Page 2 (V-334) covering seventeen issues of bonds. The s&o01 bona is- sue was Proposition No. 1. In connectionwith bonds that have been issued, this departmenthas heretofore examined all the prooe.edings relating to this eleotion. We have re-examinedthese proceedingsin connectionwith this opinion request,~andyou are advised that it is~our opinion that the authority to issue the balance,of the ten million dollar issue ceased with the separation of' the school district from municipal control. In this con- nection, we wish to state that we have not been furnish- ed copies of the separationelection proceedings,and we express no opinion regardingwhether the election- duly called and held. For the purposes of this opinion, we will assume that the electionwas in all things prop- We have been advised that the reason we have not Ek furnished copies of such proceedings is that the compilationof the same would necessarilytake time, and that as the fall semesterwill open in shortly over's month, aeoisions must be reached prior to that time; we have also been advised that our rendering.thisopinion, based upon the above-mentionedassumption,meets with the approval of the board.of trustees of the district. Prior to the'electionon July 29, 1947, the district was a municipallycontrolled school distriot. Keeping this fact in mind, let us exemink the prooeed- ings relating to the voting of the bonds. -'Theordinani?e of November 14, 1945 (No.'3722)provided in its caption that the election 3s to be "participatedin by the qual- ified voters of the City of Dallas ooming within the pro- visions of Article~6, Sect on 3-A of the Texak Constitu- tion for the purpose of determiningupon t.heissuance of ooupon bonds in the respectiveamounts set ofltherein and for the purposes particularlyset forth . . .* (Em- phasis added). Section 2 providea.that"there shall be submitted to the qualifiedvoters of the City of 'Dallas who are qualifiedvoters of the City of Dallas domi within the provisions of Article 6, Section 3-A of ?he Texas Constitution,the question of the issuance of var- ious vends as follows + . ." (Emphasisadded. Then fol- lows descriptionof the seventeenproposed bona issues). Section 3 provided that in the event the bonds we're authorized,"the City Council of the City shall at the time of issuance and sale of &aid bonds providk for a levy of a tax sufficient . . .* Section 4 provided as follows: . - Hon. L. A. Woods - Page 3 (v-334) ', 189 "That the bonds herein submitted,,,, if authorized, shall be,issued in the .I denominationof qil,OOO.OO peachand pay+- able in'not~more than..fort,y(40) years: after date, or if authorized and ordered i~ssued,the city council shall have the power to issue same'9eriallyas in-their discre'tionmay be deemed-bestana pro-' viae for iidurities thereof atany time not to exceed forty (40) years. Said bonds shall bear interest not to exceed the rate of 5% per annum which shall be 'payable semi-annuallyas it accrues at such place as me& be designatedby'the Cit$,Councilof the City of Dallas, and said sonas *all'be issue'sand exeoutea ~inaocordance with the~terms of the City Charter of the City of Dallas with ref- erenoe to.the issuance of :bonds,and the general laws of,the State of Texas appli- cable thereto. ~That the bonds here sub- mitted shall, when authorized,be issue& in accordance with the applicable terms of the City Charter of the City of Dallas ,and the'Stat6 law." -8 Section.5 provided for the'o,fficial 'ballot in the foll.owingform: "For: The proposition-ofthe issu- ance of ~$10,000,000.00in coupon bonds of the,City of Dallas'for the purpose of obtainingmoney for publ$c school improvements . . . "Against: The propositioh . . . (same as above) . . ." Section 7 provided that, in the event the bonds were authorized at the election, nthe City Council of the City of~Dallas may issue for sale any portion of said amount . . ." 'Seotion8 ptiovided that,Ydie'manner of holding said election and making the returns shall be in accordance~withthe ordinances and the charter bf the .Cityof Dallas relative thereto and.the general laws of the State of Texas applicable to the holding of such an election . . ."' Hon. L. A. Woods - Page 4 (V-;334) On July 26, 1946, the City Council of the City of Dallas enacted OrdinanceNo. 3870 which~author- ized the issuanae of bonds in the amount of two hutiked thousand aollars (part of the ten million dollarsof bonds authorized at the election on Deoember 8, 1945). That ordinance in hitsoaption provide& "for.the issu- _ ante end sale of Two Hundred Thousand ($200,000)Dol- lars in negotiablecoupon bonds of'the City of Dallas heretofore authorizea . . .* The first preamble clause of the ordinanceprovided in part as follows: "WHEREAS,in accordancewi?h the charter of the City of Dallas and the applicableState Statutes, and in ac- oordancewith an ordinance passed Qy. the governing body of the City of Dal- las oh the 14th day of November,A. D. 1945 . . . a.propositionto issue Ten Million (810,000,000.00) Dollars in bonds of the City of Dallas . . .n 'Section1 of the ordinanceprovided that "there be and is hereby ordered issued negotiable Mu- pon bonds of the City of Dallas . . ." The printed bonds which were issued in accordanoewith the ordinenoe aha which Were approve& by the Attorney General were called *City of Dallas School ImprovementBonds." 'We have goqe to great length in setting out excerpts from the ordinancesenacted by the City Coun- ~11~of the City of Dallas in an.effort to show how the bonds were ~authorizedand issued. We would lib to add, at this point, t,kt the ordinancesW&e enacted and the eleotion was held in accordancewith the city charter and with the provisions of Title.22 of the Revised Civ- ,ilStatutes of Texas, as emended, which governs the his- suance of bonds by a aouqty or an incorporatedcity or town. Can it be said as a matter of law that the qualifiedvoters at the eleotion held on December 8,.. 1945, authorized'the.Boara of Trustees of~the'Dallas Independent School District, as it siow exists, by vir- tue of the separationelection held seventeenmonths after the @ona election, to issue the bonds in question? We think that the answer is in the negative. It is our 'opinionthat the proceedingsclearly show that the.vo- ters authorized the City of Dallas (as a municipally controlleaindependentschool district) and only thaii Hon. L. A. Woods - Page 5 (V-334) ,191 entity to istie the bonds. In a municipally controlled aistridt,'.the~~ CitJiCouncil,~issueEl-bonds ana,levies$axes. Pot8et.v'.Bridges, 248 5. %. 415: Thenvoters may have, ,exercisea,'a different choice if they had known~that the bonds ~~ould~~.beissued~by a board 'oftrUstee$ of,,& inae- pendent~'di:stric~:i~nstead~'of the City Council of ,theCity of Dallas+''~: Senate Bill No,.364.~doesnot proviae'that the succegsor d$strict may'issue the balance,of these bonds; therefore,we do not hqve to determinewhether thikptier'lies :withitithe legislative~~pre~~gativ~. Seo- tion:~9,of~'thk'bill prbvides as follows: "All bonds issUed:by an&'Ot@tand-. i~&~&gai,tit~~&~'suohcii$oti.,.towli; as ~&~ '~:schoola+trict',,anaall ob,llg&ions, oontracts,andindebtednessexisting a-: 1:&iibsf the city'or town, as ~a~schocddis-,'.':'~ ~.trictj shall,become the obligatio,ns a'nd '. ,', : debtsof the'independent sohdol district ,' ~:at.the'time of its ~separationftioin mud.- ,"., eipal control, and the said independent- school dis$rict, e.fterseparationfr&n , c..: :mu&icipal,cotitrol,'&hallbe'~held'tohave .,assumefl~the dis,&ar&&,ofIall;such.obTi& _ ~.gations,,~ contracts'and.indebtedness, and' '."~ the~same shall be,enforcekble~an& collect- i>&e~from,paid off end discharge8 by, ~, " the~said independentschool di,strict, as .,if'originally create&by it as 'a separate and inaependent school district;,anait' shall not be.necessaryto call an elec- : .tionwithin-and for such ,distriotfor the~,purpose of assWing such bonds and other,indebteaness." It will be noted that this section applies. to bonds which have been "issued,byn and are Youtstana- ing againstany such city oretown, as.~aschool district.* It'.ise~ide~tthat of the ten~million dollars only two hundrea~.thousandaollars of the bonas were issued and are outstanding.. It is well settled that~the power to issue ~' negotiablebon&s may be exercise& only in the mode of the granted power and for the purposes .speoified~inthe grant. 'Gel V. PUlte (Corn.App.), 10 US.V?.(2) 694. It is our:opinionthat the qualifiedproperty~taxpaying Hon. L. A. Woods - Page,6 (V-334) 192 voters did not grant the Board of Trustees of the pres- ently existing Dallas IndependentSchool Distriat the power to issue the bonds. This power was granted only to the City of Dallas as a municipally controlledschool district, ana not to its corporate,kuccessor. It is our opinion that the fact that the City of Dallas had extended its boundariesfor school purposes apes not al- ter what we have said. Poteet v. Bridges, supra. To support the view that we have taken, we call your attention to the provisions of Seotiqn 208 of the City Charter whereih the.tax rate is limitea to $2.50 on each $100.00~valuation,"and which said tax shall embrace all taxes for municipal purposes, inolu- sive of school taxes . . ." Can it be said that the qualifiedproperty taxpayingvoters'wouldhave author- ized these bbnds if they had known that the tax rate on their propertywould not be limited to $2.50 for~all purposes,but that it could be increased to $3.75 ($2.50 plus $1.25 authorizedby:Seotion5 of Senate $111 No. 364)? It is our opinion that the question should be as.iswWed~inthe.negative. Opinion No. 6059; City of Athens v. Moody, 280 S. W. 514. We call your attention f&her to.the fact that the bonds were-vote&under the.provikd.ons bf Title 22, Revised~Cidl Statntes~of‘Texas,as amended.These statutes (Article701, et seq.) do not govern'th&is- suance of bonds by an independent school distriot.~Love v. Rockwall Independent,School D&strict, 230 S.W. 642. The Dallas InaepenaentSchool District is no longer a municipallycontWled district, but is an inaepenaent school aistrict subjeot to the provisions of Senate Bill No. 364 and the general laws relative to inaepena- ent school districts; In the.issuanceof bonds, there- fore, Articles 2704e, et seq., Vernon,ts.CivilStatutes, would control (not Articles 701, et seq.). Article .~ 2705 requires a petition as a predicate to the calling of a bona election. It'requires~adifferent notice than that outline&in Article 704. Article ~2786re- .@.res that "the petition, election order &Xi fioticeaf electionmust distinctlyspecify the amount of bonds, the rate of interest, their maturity dates, and the purpose for which the bonds are to be used. (J@phasis added I. It requires.adifferentlyworded ballot. It requires that the bonds shall mature in serial annual installments'overa perioa of not excee&ng forty yesrs from their date, but that when the sohoolhousesdareto be constructedof wood, the bonds shall mature in not more than twenty years. Hon. L. A. Woods - Page 7 (v-334) 3.93 An independentdistrict in issuing bonds must meet the terms of these statutes. It is obvious that in the issuance'ofthe balance of the $lO,OOO,- 000 bonds, these terms could not be met. It is our opinion that this fact alone would preclude the issu- ance of such bonds. In view of the foregoing, you are advised that the Board of Trustees of the Dallas Independent School District is without authority to issue the bal- ance of such bonds. You are interestedin a second question, and this question concerns the tax of the new dis- trict under Se&ion 5 of Senate Bilk No. 364. We quote the following from your letter: "Prior to the said separation'elec- tion, a tax~in the amount of seventy-five cents was voted aa levied for maintenance of said school system';which/together with an approximateeleven cent bond re- tir~enient tax theretoforevqtea and levied, makes the total tax now leviedfor said school district amount to approximately weighty-sixcents on the one-hundreddol- ~larsvaluat%on. "Now, can the Board of Trustees of the UalLas Ind0pend8nt School District levy an additional tax,.whiohwhen added to the existing taxes does cot exceed one dollar and twenty-fivecents on the one hundred dollars valuation of taxable prop- erty of saia~aistrict,~forthe maintenance of the schools therein, without a vote of the tax paying property owners therein u+ der Senate Bill 3643" Section 5 of Senate Bill No. 364 reads as follows: "Except as herein denied or limited, all the powers conferred upon idependent' school districts and/or towns and villages incorporatedfor free school purposes only, by Title 49, of the Revisea Civil Statutes of Texas, of 1925, and amendments thereto, including the right to annex Hon. L. A. w00as - Page 0 (V-334) 694 contiguousterritoryfor school pur- poses, and the right to levy taxes and issue bonas for school purposes, as provided by General Law, hereby are cotierredupon any inaepenaent school district separatedfrom muni- cipal control under the provisions of this Act; provided however, that the trustees of any independent sohool district that may hereafter be separatedfrom municipal control under the provision& of this Aot, shall have the power to levy and ool- lect an annual ad valorem'tax not to exceed One and 25/100 ($1.25)Dol- lars on the One Hundred (~lOO;OO) Dollars valuation of taxable propep- ty of.the dist~i0t,for the.mainten- ante'of the sohools therein, end whioh may be used to pay the prinoi- pal ana interest on all bonas issued for sohool building purposes out- standing$$@.nst the extended muni- cipal school district at th6 ti@ie~of separationfrom municipd bontrol, and the principal of and interesC0n all bonds to be.issued hereafter by any such independentschool district; provided that nothing herein shall be construedaspabrogating or in any m&n- ner repealing or affecting any kin- tenance tax and/or bona taxes hereto- fore voted, authorizedand/or levied on taxable properties situated within the limits of the extended municipa.1 school district;PTOViaea further, that no increase in the maximum rate of school maintenancetax an&/or bona debt of any such district shall be authorizeauntil after an election shall have been held wherein a major- ity of the taxpayingvoters, voting at said election;shall .havevoted in favor of said tax, or the issuance of said bonds, or b&h, as the 0ase may be; ana provided further, that the bonds,, of any such distriot shall not exceed in amount seVen (7%) per oent- um of the assessed value of taxable d - Hon. L. A. Woods - Page 9,,(V-334) : 195 property,of suoh district,as shown by the last annual assessmentOf such property. In the event an elec- tion is hela.for the purpose of sep- arating such'schooldis$riqt from municipal control, and such election ~1sin favor of the separationof the public schools from municipal con- trol, then such independentsohool district may levy ana collect taxes as of January lst, ,ofthe year in w,hiohthe election Was held, and thereafter levy and,colleotsuoh taxes on an annual ba,sis.* You wish to know whetherthis t&x bf $1.25 can be levied without a vote of the qualified property taxpaying voters of the district. Seotion 3 of Article vII,'Constitutionof Texas, provides in part: n -~providedthat a~major- ity of t~e*&alified proljertytaxpay- ing voters of the district voting at ~:an electioq to ,be~heldfor that pur- pose, shall vote such tax . . ." This Constitutionalmandate must~be corn- plied with: Pyote Indep&ndentSchool District v. Dyer (Corn.App;), 34 S; 911. (2) 578; Bigfoot Independent School Distr&ot v. Cenard (Civ. App.) 116 S. W. (2) 804;Uff*a.., Corn.App.) 129 S. W. (21 1213; Crabb v. Celest6 Independent School'Dititrict,105 Tex. 194, 146 S. W.~528,'39 L.R.A. (NS) 601; Burns v. Dilly Independ- . ent So4001 Distriot (Corn.App.), 295 S. W. 1091. You are, therefore,aavised that the Board of Trustees of the-DallasIndependentSch6ol District has no authority to levy a tax of $1.25~unless a "major- ity of the qualified property taxpayingvoters of the district voting at an eleM,ion to be held for that pur- pose, shall vote such tax . . .* It has been hela that an election whereby the sohool sys$em is separatedfrom municipal oontrol is an amendment to the charter of the qity. -State v. City Commissionerof San Angelo (W. E. Ref.), 101 S.W.~ (2) 360.' It is assumed that the charter,of the City of Dallas had not been amended within the two years preceding the election held on July 29, 1947. Hon. L. A. Woods - Page~lO (V-3344) 296 1. The Board of Trustees of the Dallas Independentschool District', which aistr#.ct has been separatedfrom municipal control is without authority to issue the balance of the ten'millibindollars of bonds authorizedat an eleotion held on Deoember'8,1945, when the districtwas a municipally controlledais- trict. 2. The Board~of Trustees of the Dallas IndependentSohool~Districtis without auth- ority to levy a tax of $1.25 unless "a major- ity of the qualifiedproperty taxpaying voters of the district votingat an'eleotionto be held for that purpose shall vote such tax." .~ Very truly yours ATTORNEP CENERAL OF TEXAS B; hyT. + " George W. Sparks GWS-s:wb Assi.stant