P September 28, 1988

Mr. T. R. Fehrenbach Chairman OpinionNo. JM-958

Texas Antiquities Committee Re: Jurisdiction of the State P. 0. BOX 12276 Austin, Texas Antiquities Committee over

78711 propertyheld by an independent school district (RQ-1404)

DearMr. Fehrenbach:

On behalf of the Texas Antiquities Committee you request advice on the authority of the committee to designate school district buildings as state archeological landmarks. Your questionsarisebecause of legal challenges to the committee's authority attempts to exercise its statutory

over school district See Anticfuities

Committee property. Texas

Dallas C untv Communitv Collese District, 554 S.W.2d 9;; (Tex.197;). We will review the committee's statutoryauthorityand relevant case law before turning to your specific questions.

The committee is created by section 191.011 of the Natural Resources Code, and itspowers and duties are set out in the Antiquities Code of Texas, sections 191.001 through 191.174 of that code. &R Nat. Res. Code § 191.001. It "shall

. . .determine marks

. . . the site of and designate landas provided in Subchapter the Natural Resources Code. D" of chapter 191 of SubchapterD provides that: Nat. Res. Code 5 191.051(b)(2).

[slites, objects, implements, buildings, artifacts,

and locations of archeological, historical,

scientific, or educational interest

. . .that are located in, on, or under the surface of any landbelonging to the State of Texas or to any county, city, or political subdivisionof the state are state archeological landmarksand are eligible for designation.

Nat. Res. Code § 191.092(a). A structure historical interest if it: or building has

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Mr. T. R. Fehrenbach - Page 2 (JM-958)

(1) was the site of an event that has significance in the history of the United States or the State of Texas:
(2) was significantlyassociatedwith the life of a famousperson: (3) was significantlyassociatedwith an eventthat symbolizesan important principle
or ideal:
(4) represents a distinctive architectural type andhas value as an example of a period, style, or construction technique; or (5) is importantas part of the heritage of a religious organization,ethnicgroup, or local society.

Nat. Res. Code S 191.092(b).

Before the committee may designate a structure or building as a state archeological landmark, it must be listed on the National Register of Historic Places. Nat. Res. Code 5 191.092(c); see 16 U.S.C. 5 470(a). The committee is required to adopt rules establishing criteria for such designationsandmust consider "any and all fiscal impact on local political subdivisions" before it may designate as a state archeological landmark a building or structure ownedby a political subdivision. Nat. Res. Code f 191.092(d), (e).

Landmarksdesignatedunder section 191.092 of the code "are the soleproperty of the State of Texas andmay not be removed, altered, damaged, [or] destroyed

. . .without a contractwith or permit from the committee." & s 191.093. This provisionhas been the focus of conflictsbetween the committee's role inpreserving the historicalvalue of state archeological landmarks owned by school districts, see Attorney General Opinion JM-104 (1983), and the school district's interest inusing, altering, or replacing its buildings to carry out its educationalpurposes.. &8 Texas

ittee v. Dallas County Communltv Collea District, sunrq G Hoard of R cents lker 608 S.W.2de 252 (zex.W:iv. Count: Historical Com~zssron Houston [14th Dist.1'1980, APP. - no writ) (buildinglocated on land administeredby Board of Regents of the Texas State University System).

--.

p. 4856Mr. T. R. Fehrenbach - Page 3 (JM-958)

Texas Antiauitie Collece District is t:e leadinTc&e on t:e authority 0: the Antiouities Committee and some of vour o-uestions are specificallybased on it. In the palias Co&y case, the Texas Supreme Court set aside an order of the Antiquities Committee denying the Dallas County Community College Distr~ict

apermit to demolish three buildings. The court was divided onboth the reasoningand result of this case. An opinion of~four judgesNled in favor of the community collegedistrict on the ground that a provision of the Antiquities Codewas **both** unconstitutionaland unconstitutionally applied, and that the permit denial was not supported by substantial evidence. The chief justice concurred on the **basis** of the substantial evidence rule and declined to reach any constitutionalquestion. Four judges dissented.

The prevailing opinion of four judgesdetermined that former section **6** of article 6145-9, V.T.C.S., the predecessor to section 191.092(a)of theNatural Resources Code,
was unconstitutionallyvague and lacked sufficient standards governing the delegation of legislative authority. The predecessor statute declared buildings and locations of historical, archeological, scientific, educational interest located on lands of political sub%visions to be State Archeological Landmarks. The Antiquities Committee contended only that the Dallas buildingswere "of historical interest." Neither the statutenor any rule gave this descriptionmore specificityor predictability, and the law did not include the explicit standards necessary to prevent arbitrary and discriminatory enforcement. **554** S.W.Zd 924, at 928.

The same opinion also found the TexasAntiquities Act, formerly article 6145-9, V.T.C.S., unconstitutional as applied to the community collegebuildingsbecause no substantial evidence supported the action of the Antiquities Committee. **554** S.W. 2d 924, at 928. The evidencewas such that reasonableminds couldnothave reached the conclusion that the committee must have reached. Restoration of the buildingswould require the diversion of public funds held in trust to benefitpeople in the school district. In addition, the buildings could not be restored except by spending an unreasonable amount ofmoney, and even costly rebuilding would not make them usable for educational purposes. **554** S.W.2d 924, at 929.

In answer to the argument of theAntiquities Committee that a political subdivision has no contract or property rights protectable against the committee#s powers, the

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Mr. T. R. Fehrenbach - Page 4 (JM-958)

opinionpointed out that a state agency could not divest property and contract rights in violation of specific constitutionalprovisions. Snr:&ove v. Citv of Dalla S.W.Zd 20 (Tex. 1931);&ilam Cq&ntvv. BatemaD, 54 Tex.' 40 163 (1880).

We turn to your seven questions.

You first ask whether the committee'sdesignation of a public school building as a state archeological landmark (SAL)would divert dedicated educational funds or property to non-educational purposes in violation of article VII, sections 3 and 6, of the Texas Constitution.

you ask as your second questionwhether the committee's denial of a school district's request for a permit to demolish a designated building would divert educational funds orproperty to non-educationalpurposes in violation of articleVII, sections 3 and 6, of the Texas Constitution.
Article VII, section 3, of the constitution requires that certain tax revenues shall be used to support the llpublic

free schools." See Attorney General Opinion H-961 (1977). Article VII, section 6,provides that lands granted to the counties for educationalpurposes are the property of the counties, with title theretovested in the counties. The lands andproceeds generatedby the sale thereof are to be held by the counties "as a trust for the benefit of public schools therein." See Attorney General Opinion JM-729 (1987).

The prevailing opinion inTexas Antiouities Committee

**V.** Dallas Countv CommuDitv Collese District, in saying that constitutionalprohibitionswould restrain one state agency from divesting vested property and contract rights of another agency of the state, cited and discussed Love v. Citv of u, a, and Bilam Countvv. Bateman, szuEmr cases relying. on article VII, sections 3 and 6, respectively. In Wilam Countvv. BatemaD, the court stated that the state may not arbitrarilytake school land from the county and give it to privateparties. Milam Countv, 54 Tex. 163, at 166. In Love v. Citv of Dallas, the Supreme Court foundviolative of articleVII, section 3, legislation which required a schooldistrict to use its funds to educate personswho. did not reside in the district. The school funds and propertieswere held in trustby the city, school district, county, or other statutory agency to be used for the benefit of the school children of the community and the legislaturecould not devote them to any other purpose. &yg, 40 S.W.Zd 20, at 26. Seem also Citv of El Pasov. El

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tv Colleae District 729 S.W.2d 296 (Tex. 1986) (providingthat article VIII,' section l-g(b), of Texas Constitution creates exception from articleVII, section 3 prohibition against school tax funds being used for non-educationalpurposes).

We turn to your first question. The designation of a schoolbuilding as an SAL serves to retain the status guo and to subjectthe building to the committee's jurisdiction and to the permit requirement in section 191.093 of the Natural Resources Code. a Hoard of Reaents v. Walker CountvHiswcal oassion 608 S.W.2d 252 (Tex.Civ.App.

- Houston 114thD:st.] 1986, nowrit): Attorney General OpinionMW-378 (1981). Thus, it is certainlypossible that the designation of a buildingwould not change the district's use of dedicated educational funds or property. We cannot,however, rule out the possibility that on the facts of some cases the SAL designation will have the effect of making such a diversion, for example, by requiring the school to maintain a building that can no longerbe used for educationalpurposes.
The answer to your secondquestion will depend on the facts of the particular situation, and it cannot be answered in an **Attorney** General Opinion. The court in Texas Colleae **District;** indicatedthat a constitutional question would not have arisen if funds other than public school money had been available. 554 S.W.2d 924, at 928. Moreover, on the facts of that case, the buildings could not have been made usable for educational purposes. Different facts presumably couldyield a different conclusion.

your third question is as follows:

Is the Committee's reading of the pBllas County case correct in thatwhere funds not subject to the "publictrust01 are available, the SAL designation and ownership of the building's intrinsic value may not be disturbed absent a showing of. unsuitability for educationalpurposes?
The Antiquities Committeehad not designated any of the threebuildings at issue in the Dallas County case as state archeological landmarks. 554 S.W.Zd 924, at 926. Before the Supreme Court issued its opinions in that case, this office read the statute itself to designate certain publicly-ownedproperties as state archeological landmarks. See Attorney General OpinionsH-620 (1975);H-250 (1974).

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Since the mlas County case concerned the denial of a demolitionpermit,we will answeryour question in terms of the committee'sdenying a permit to demolish a building.

We do not agree with your characterization of the supreme court's decision. Five judges agreed that "this particular determination of the Antiquities Committee is not supportedby substantialevidence." 554 S.W.Zd 924, at 931 (concurringopinion). This was the basis of the majority decision. The committee acted soundbasiswith respect to arbitrarilyand without a the Dallasbuildings, as shown by the reasons set out in the first opinion. ;EBt In addition to evidence on the issues you mention, the court cited evidence that the buildings couldbe restored only by complete reconstruction from the foundationup at a cost greater than new construction and that the outside walls might collapse if reconstructionwere undertaken. Similar evidence, as well as facts not before the court in the Dalla C UntY could be relevantto other exercises of the c&m~ttee~?s$mit power over SAL-designated school districtbuildings. As this office stated in Attorney General Opinion H-620 (1975),a sitemay be "of such slight historic interestand of such littleutility" that denial of a permitwould be an unreasonableand arbitrary exercise of the committee'spower. to schoolbuildings Whether other actionswith respect are supported by substantial evidence must be determined on a case-by-casebasis by an adjudicator with power to make fact-findings,and cannotbe determined in an attorney general opinion.

Your fourthgues~tionis as follows:

If the answer to one, two and/or three is no, then to what extent, if any, may the Committee constitutionally and statutorily subject public school properties to its jurisdiction?

To the extent that this question can be answered in the abstract, ithas been your questions answered in the discussion preceding

and the discussion of questions. your first three

your fifth question is as follows:

If a public school district allows a SAL designation of one of itsproperties,has the schooldistrict waived its right to assert the diversionprinciple in futureproceedings (A, demolitionpermitproceedings)?

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The Antiquities Committee is subject to the Administrative Procedureand Texas RegisterAct, article 6252-13a, V.T.C.S., and the Natural Resources Code, section 191.021(a). A %ontested case"under that Act includes a proceeding in which an agencydecides whether or not to issue-~a

permit. m V.T.C.S. 6252-13a, s 3(2), (3). Your request letter in fact states that the committee deals with requests fordemolition of SALs as contested cases under the Administrative Procedure and Texas RegisterAct. See also Attorney General OpinionMW-378 (1981) (committee'sdecision in permit application cases will be tested under the substantialevidence rule). The Administrative Procedure and Texas Register **Act** gives parties to a contested case notice and an opportunity forhearing aswell are a right to judicial review after exhaustionof administrative remedies. V.T.C.S. art. 6252-13a, 55 13, 19.

You next ask whether the committee's denial of a demolitionpermit to a public schooldistrict constitutes an unconstitutionaltaking ofpropertywithout compensation.
Article I, section 17, of the Texas Constitution provides inpart:

No person'sproperty shallbe taken, damaged or destroyed for or applied to public use without adequate compensation being made

. . . .
In 2 ;.:.:d)2:9 (Tex. Civ? App. - Tylk '19795)Au t'n, 582 writ ref'd,

. . - ,a case involving zoning of a privately-owned hotel
as a historic landmark,the courtheld that the city imposed
a servitude on propertywhen it restrictedthe owners from reconstructing, altering, removing, or demolishing the buildingwithout a permit. Since the citymade no provision for any compensation to the owners, the court held that therehad been a "damaging" of the property forpublic use without adequate compensation in violation of article I, section 17, of the constitution. ;EBLat 238. Thus, designation of private property as a state archeological landmark or denial of a demolitionpermit forprivate property may invoke the requirement for adequate compensation in article I, section 17.
Article I, section 17, has generally been read, however, as applying to~the taking, damaging, or destruction ofprivate property. See. e.a,, State v. Steck Co 236 S.W.2d 866, 869 (Tex.Civ.App. -Austin 1951,writ r;f*d). Publicpropertymay be taken for anotherpublic use if there

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is express or implied legislativeauthority to do so, if the additionalpublic use will notmaterially interferewith the existinguse, or if the subsequenttaking is for a public purpose of greater importance which cannotbe accomplished in any other practical way. ustin Indeoendent School pistrictv. Sierra Cl& 495 S.W.td 878 (Tex.1973); Sn llen 224 S.W.Zd 305 (Tex. Civ. Ap;. - writ ref'd n.r.e.). The committee has statutory auth&ity to designate school buildings as SALs and to grant or deny demolition permits to the school district. If it exercises these powers in compliance with all applicable.provisionsof law, itwill not damage or take propertywithout compensation in violation of article I, section 17, of the Texas Constitution. Although ithas been argued as a policymatter that governmentalbodies should receive compensationwhen their property is taken, this view has not been adopted *inTexas. &R J. M. Payne, Intero vernmental Condemn ion as a Problem in Pub1 Tzx. Law Rev. 949 (1%3). ic Finance, 61

Your last question is as follows:

There being no regulatory standards concerning the approval or denial of w are the penal provisions. of the Code uncon' stitutional on their face since the legislature has delegateddiscretionaryauthority in this areawithout statutory standards?
Section 191.171 of the Natural Resources Code establishes a criminal penalty for violations of the provisions of chapter 191 of the code. It states inpart:

(a) A person violating any of the provisions of this chapter isguilty of a misdemeanor, and on conviction shall be punished by a fine of not less than $50 and notmore than $1,000,by confinement in jail for notmore than 30 days, or by both.

Nat. Res. Code § 191.171(a).

The Natural Resources Code provides that landmarks establishedunder section 191.091of the code may not be removed, altered, damaged,destroyed, salvaged, or excavated without a contractwith or permit from the committee. Nat. Res. Code 8 191..~093. See alsoNat. Res. Code 5 191.095.

The committee "shall

. . .consider the requests for and issue the permitsprovided for" in section 191.054 of ,

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the Natural Resources Code. Nat. Res. Section 191.054provides inpart: Code 5 191.051(b)(4).

(a) The committeemay issue a permit to other state agencies or political subf:;A;ions or to qualified -private institusurve; companies, or individuals, for the

and discovery, excavation, demolition, or restorationof or the conduct of scientific or educational studies at, in, or on landmarks, or eligible landmarksonfor the discovery of public land fi it is

(b) Restoration shallbe defined as any rehabilitationof a landmark exceptingnormal maintenance or alterations to interior spaces. nonpublic (Emphasisadded.)

Nat. Res. Code 5 191.054.
Violations of administrative rules and ordersmay be punishableby a legislatively-establishedpenalty. Dnited States v. Gordon, 580 F.2d 827 (5thCir. 1978); Harrincton
v. Rgilroad Co~&jssion 375 S.W.Zd 892 (Tex.1964); Tuttle V. Wood 35 S.W.2d 106i (Tex.Civ.App. writ rei*d). - San Antonio

Section 191.171of the Natural Resources 1931, Code establishes such a penalty.

An invalidadministrative ordermay not, however, be enforcedby a criminal penalty. Your last question thus raises the issue of whether section 191.054 is invalid because it lacks regulatory standards concerning the approval or denial of permits.

When the legislature delegates to an agency the authority to adopt rules and orders, it must prescribe adequate standards to guide the discretion it confers. Antiouit;ies Couee v. Dal1 8 Comm nitv Ex Countv -District, i4ul2.a: 561 S.W.2dU 503 (Tex.Crim. App. 1978);Tex. Const. art. II: .q1; art.
s 1. The Antiquities Committeehas been delegated III,legislative authority to grant permits, subject to the standard that, in the opinion of the committee,the permit is in "the best interest of the State of Texas." Nat. Res. Code s 191.054. We must therefore determinewhether the quoted language provides a sufficient legislative standard to control the committee's exerciseof discretion and to guard

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against arbitrary and unfair decisions on permit applications.

The standard, "in the best interest of the State of Texas,"was included in the predecessor of section 191.054 when the Antiquities Codewas adopted in 1969. Acts 1969, 61st Lag., 26 C.S., ch. 2, 5 10, at 101. As adopted, the permit provision read inpart as follows:

The Antiquities Committee shall authorized to issue permits to other stat: agencies or institutions and to qualified private institutions, companies, or individuals for the takina. salvaainc. excavation, restorina. or the conductincof scientific or educational studiesat, in, or on StateArcheological Landmarks as in the opinion of the Antiquities Committee would be &) the b t **kiterest of**  **the State**  **of Texas** 

**.** (Rmpha% added.)

XL 5 10.
This provisiondid not originallyappear to contemplate the alteration or demolition of a public buildingwhich had been designated as a StateArcheological Landmark. It was more relevant to activities such as salvaging or restoration thatwere consistentwith the purpose of historical preservation set out in the code:

It is the public policy and in the public interestof the State ofTexas to locate, protect, and preserve all sites, objects, buildings,pre-twentiethcentury shipwrecks, and locations of historical, archeological, educational, or scientific interest

. . . .
Nat. Res. Code 5 191.002. Thus, in the context of the originalAntiquities Code, the cited standard could be read togetherwith the purpose clause to require the committee's permit decisions to serve the state's **best** interest relative to historical preservation. See. e.a **S ate**  **D D**  **$a.** :pp. 19:2:* (:: z;zt;;,""', 409 So.2d 53, 57 interestof the public" refers to best

. . interest of'taxpayers of state): -cation of Pribil N.W.2d 356, **358** (Neb. 1966) ("bestinterest" in &at::: relating to land transfersbetween two school districts
means best educative interest).

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Moreover, the adoption of the Antiquities Code was precipitatedby the state's efforts to reclaim 16th century artifacts removed by a galleonwhich sank salvage company from a Spanish off the shore of Texas. exasAnt ties Code. An Comment, !f&

. *%&text, 24 SW. L.9 Criteria for D~~&D&&D I 76 (1979). 11 St. Mary's

-See Platoro. Ltd.v. Unidentified of a Vessel Supp. 351 (S.D.Tex. m. 371 F. Supp. 1970),~ Tex. 1973), rev d on m, 508 F.2d 1113 (5th Cir. 1975) (PlatoLoI) other The emergency clause of the bill adopting the code stated in pa*:

The fact that irreparabledamage and harm is

rapidlybeing done to the archeological and historicalheritage of the State of Texas and its citizens, and that historical and archeological sites, and treasures on public lands are without adequate legal protection and supervisionand arebeing destroyed and damagedwithout lawful authority, create an emergency
. . . .
Acts 1969, 61st Leg. 2d C.S., ch. 2, 5 23, at 103.
Thus, the nbest interest" standardwas adoptedby a legislatureanxious to stopprivate interests from damaging the state's archeological and historical resources and imposeda duty on the committee to **make**permit decisions thatwould serve the state's interests in such resources. These circumstances also support the conclusion that the committees shouldmake permit decisions thatwould serve the state's interests in such resources.
The "best interest" language has not changed, while otherprovisions of the Antiquities Code have been amended to acknowledge that other importantpublic interests exist in the governmental functions carried out by political subdivisions. .Thecommitteemust now consider "any and all fiscal impact" on a local political subdivision before designating a building or structurewhich it owns as a state archeological landmark. Nat. m Nat. Res. Res. Code 5 191.092(e). See

Code 5 191.021(b) (procedurefor considering educationalpurpose designation). ofhigher educationbuildings in SAL

Moreover, now that section 191.054 expressly authorizesthe committee to issuea demolitionpermit for a buildingpreviously designated as a state archeological landmark, the committee presumablyhas a duty to consider the applicantts reasons why such a building should be

p. 4865Mr. T. R. Fehrenbach - Page 12 (JM-958)

-,

demolished and not preserved. The "best interest" standard,
as originally understood, provides the committee little guidancewhen it has to reconcile the state's interest in historical preservation with a political subdivision's competing interest in controlling the use of its real property to carry out its own legislatively-imposed responsibilities.

InTaxas Antwties Coattee v. Dallas Countv Commnltv Colleae District the prevailing opinion of the supreme court included the followingdiscussion of standards that should accompany the legislature's delegations of powers to state agencies:

Dependingupon the nature of the power, the agency, and the subject matter, varying degrees of specific standards have been required in testing the reasonablebreadth of statutes. 1 Sutherland,Statutory Construction, 5 4.05 (4thed. 1975);&R&n v. State Board f Insurance, 160Tex. 278 $60). 506, 334 S.W.Zd

Sound reasons support the rule that some reasonable standard is essential to the constitutionality of statutory delegations of powers to state boards and commissions.

[QuotationfromEIgvnedv. Citv of Roc;rf, 408 U.S. 104, 108-09 (1972) I deleted.]

We adhere to the settledprinciple that statutorydelegations of power may not be accomplished **by** language sobroad and vague that persons *of common intelligence must necessarilyguess at itsmeaning and differ
as to its application.'

554 S.W.Zd at 927-28. The same opinion of the court considered the argument that administrativestandards in the form of published rules couldbe substituted for statutory standards. 554 S.W.Zd at 928 [discussingDavis,Administrative Law Treatise, 5 2.16 (1st ed. 1970)]. The opinion stated that in the present case no standard or criteria by statute or rule provided safeguards for the affected parties.

As the Antiquities Codehas been amended to deal with the legal questions that arose in theDallas County case, the legislative intent underlying the code has changed to

P. 4866**Mr.** T. R. **Fehrenbach -**  Page 13 (JM-958)

acknowledgethat public interests other than historical preservation **may be**  relevant inparticularpermit application cases. The "best interest"standard is stated in languagebroad enough to incorporate themodifications in the legislative intent brought aboutby amendments to the Antiquities Code. m -tina v. Texas State Board Medical EXB ' f

S 310 S.W.2d 557 (Tex.1958) (amendmenta:d old lawmust be C&&Ned as harmoniouswhole). the argument raised Relying on in theUas Countv **case, we**  the committee may adopt rules which amplify the be;::;:
interest" standard to giveweight to the public interest of political subdivisions in controllingtheir resources as necessary to perform their constitutionally and legislatively imposedduties. The **“ best**  interestof the State of Texas" in a particular case could reasonablybe an interest arrived **at** by weighing the public interest in preserving archeological resources against other important interests seNed by the governmentalentities public which have custody of archeologicalresources. Accordingly,we do not believe that section 191.054 must fall for lack of regulatory standards or that prosecutionsunder section 191.174 **for** violation of the permit requirementsare impermissible. Whether any permit denial is **a** valid agency action andwhether any individual isguilty of a violation under section 191.174 must be determined on a case-by-casebasis in an appropriate forum.

SUMMARY Designationby the StateAntiquities Committee of a schoolbuilding as a state archeological landmark could divert dedicated education fundsor property to non-educational purposes inviolation of articleVII, sections 3 and 6, of the Texas Constitution,
on the facts of the particular case. depending Whether the committee'sdenial of a school district's request for a permit to demolish a designated building would cause such a diversion of educational resourceswould have to be decided
on **a case-by-case**  basis, consideringthe facts of eachparticular situation,and subject to reviewby the courts for substantial evidence to support the committee8s decision. The committee'sdecisions in permit application
cases are contested casesunder the Administration Procedureand Texas RegisterAct and the applicants forpermitshave a right under

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that statute for judicial review of the committee'sdecision.

The committee's denial of a demolition permit to a school districtdoes not constitute an unconstitutionaltaking of property without compensation in violation of article I, section 17, of the Texas Constitution.
Section 191.054of the Natural Resources Code,which authorizes the committee to issue
a demolition permit for state archeological landmarks if "it is the opinion of the committee #at the permit is in the best interest of the State of Texas," is not invalid for lack of standards to guide the committee's exercise of delegated legislativepower. The "best interest" standard may be made more specificby reading it in reference to other provisions of the Antiquities Code which evidence the legislature's intent for exercise of the committee'spermit power.

JIM MATTOX Attorney General of Texas

MARYRELLER FirstAssistantAttorney General

Lou MCCREARY ExecutiveAssistantAttorney General

JUDGE ZOLLIE STEARLRY SpecialAssistantAttorney General

RICK GILPIN Chairman, Opinion Committee Preparedby Susan L. Garrison AssistantAttorney General

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