Untitled Texas Attorney General Opinion

Honorable R. A. Weinert, Chairman Civil Jurisprudence Committee Senate Austin, Texas Dear Senator: Opinion Ho. O-5066 Re: Constitutional validity of S. B. 44, dealing with the problem of delin- quent children. -You submit to us a copy of S. B. No. 44, dealing with delinquent children, as favorably reported by your com- mittee on January 26, 1943, with the request that we ad- vise with respect to the constitutionality of the bill, es- pecially with respect to, (a) the right of the court to ex- clude spectators from the trial; (b) the provisions that the records of the court shall be confidential; (c) the ap- peal to the Court of Civil Appeals, and (d) the provision that the judgment of the court shall not be suspended dur- ing appeal. In this connection we subjoin the following re- marks and suggestions: ., (a) The provision contained in Section 13 that "in the hearing.of any case the general public shall be excluded and only such persons admitted as have a direct interest in the case, except that the judge of said court may admit any person to the hearing at his direction," does not contravene Section 10 of the Bill of Rights (Article I) of the Constitution, since that Section deals only with "criminal prosecutions.1' The delinquency proceeding of your bill is not in any sense a criminal prosecution -- it is a civil pro- cedure -- and there is no constitutional mandate requir- ing public hearings in civil cases or proceedings. (b) There is no constitutional provision for- bidding the provision contained in Section 15 that the "court records shall not be inspected by persons other than probation officers or other officers of the Juvenile Court, unless otherwise directed by the court.tt We think such a provision in a measure like the one under consider- Honorable R. A. Weinert, page 2, O-5066 ation is entirely within the legislative prerogative. (c) 'Phe first sentence of Section 21, begin- ning wTth the words, "an appeal" on line 4, and ending with the word wcasestt in line 5, should be rewritten, we suggest as followso "An appeal may be taken by any party aggrieved .-. - . .. to the, Court of Civil Appals, sna me case may oe carried to the Supreme Court by writ of error or upon certificate, as in other civil cases." This change is apparently imperative.‘ The words of Section 21, above eliminated, authorize an appeal "in the manner provided by law or by rule of court", whereas, there is no provision at present for such an appeal, the general statutory right of appeal to the Courts of Civil Appeals extending to "all civil cases within the limits of their resuective districts of which the District Courts and County Courts have or assume jurisdiction when the amount in controversy, or the judgment renderemm exceed $100 i00 exclusive of interest and costs." (R C S. r. 19) The proceed1 here under consideratioi Gould not fall within the prese% statutory jurisdiction of the Court of Civil Appeals. Likewise, Article 2249 of t,he'Revised Civil Stat- utes contains the same statement of the jurisdiction of the Court of Civil Appeals. (d) The provision in Section 21, that "an appeal, in the case of a child, shall not suspend the order of the Juvenile Court," violates no constitutional provision. Whether or not the Legislature may in any event confer the jurisdiction and powers of the Juvenile Court uponthe County Court, is a debatable question. Indeed, there is uncertainty if not actual contrariety of holding upon this point between the Court of Criminal Appeals and the Supeme Court, resulting, of course, in confusion. We are not prepared to advise with judicial certainty the one way or the other upon this debatable question. We quite well understand that for administrative purposes it might be desirable for the County Court to ex- ercise this jurisdiction. In this state of the matter it might be wise not to eliminate the County Court as a Juvenile Court under Honorable R. A. Weinert, - page 3, O-5066 the bill, but to leave it as now written, in the hope that that court would be permitted to have and exercise the jurisdiction. The bill contains the separability clause, and if the Act should be stricken down as it empowers the County Court, the Act as a whole would not fall, but the jurisdiction and powers thereof could and would be exer- cised by the proper District Court. Your body in its wis- dom will, of course, choose what it thinks the preferable course in this respect. However, we do suggest that in any event there should be added, following immediately after line 53, page 1, at the end of Section 4 of the bill, the following words: "It is provided, however, that the juris- diction, powers and duties thus conferred and imposed upon the established courts hereunder are super-added jurisdictions, powers and du- ties, it being the intention of the Legislature not to create hereby another office." The purpose of this added language is, of course, to avoid the possible danger of dual-office holding, in contravention of Section 40, Article XVI, of the Constitu- tion. Would it not be well to include in the bill a pro- vision something like the following: Upon any such jury trial, the court may submit the oase upon a general charge to find whether or not the child is a "delinquent child", and the judgment shall follow the verdict unless such verdict be set aside for good cause. It shall be good cause for setting aside any verdict that the evidence is not sufficient, legally or factually, to support it. No verdict shall ever be permitted to stand, nor judgment without a verdict be permitted to stand, that is not supported by evidence, .that the parent, guardian or other person exercising parental control of such child, as the case may be, neglected or failed to exercise a reasonable parental care over such child. This is, of course, a matter entirely beyond our prerogative to advise, but a jury would be slow to return a --.; SC - Honorable R. A. Weinert - page 4 - O-5066 verdict of commitment, and a court fould be reluctant to approve a verdict that was not supported by some evidence that the parent had been remiss in his duty toward the child. Very truly yours ATTORNJZY GRRRRAL OF TEXAS S/ Ocie Speer BY Ocie Speer Assistant os-m/cg Approved March 3, 1943 s/ Gerald C. Mann ATTORNEY GEXRRAL OF TEXAS This opinion considered and approved in limited conference