TITLE attorney-general

Opinions

Opinion No. GA-0139

The Honorable Kenneth Armbrister

Chair, Committee on Natural Resources

Texas State Senate

Post Office Box 12068

Austin, Texas 78711

Re: The status of subdivision roads dedicated for public use in a county with fewer than 50,000 people where the commissioners court approved the subdivision plat for filing but did not accept the roads for county maintenance (RQ-0087-GA)

S U M M A R Y

A county has no authority to order the removal of an obstruction of a road that has not been accepted into the county road system. But, as a consequence of a real property conveyance that expressly refers to a plat showing abutting roads or streets, the purchaser acquires a private interest in the roads shown on the plat. A property owner holding such a deed has a right to enforce his or her private easement.

Property that has been dedicated to the public for use as streets but that has not been accepted by the county is not county-owned for tax-exemption purposes. The county must, consequently, levy ad valorem taxes on the property.

Only a commissioners court, acting as a body, has authority to accept a street for county maintenance. A commissioners court in a county with a population of 50,000 or less may acquire an interest in a road under section 253.011 or 281.002 of the Transportation Code.

Opinion No. GA-0140

The Honorable Mike Stafford

Harris County Attorney

1019 Congress, 15th Floor

Houston, Texas 77002-1700

Re: Execution of tax warrants and property seizure and sale under chapter 33, Tax Code (RQ-0089-GA)

S U M M A R Y

A peace officer, as defined by article 2.12 of the Code of Criminal Procedure, may execute a tax warrant for the seizure of personal property under section 33.23 of the Tax Code, while a sheriff or constable is the only type of peace officer that may execute a tax warrant for seizure of real property under section 33.93 of the same code. Likewise, any peace officer may seize personal property that is the subject of a tax warrant, while a sheriff or constable may seize real property. Seizure requires possession or control of the property. A peace officer who seizes personal property is authorized, but not required, by statute to relinquish possession to the tax assessor-collector. On the other hand, section 33.93 requires the sheriff or constable to turn the possession of seized real property over to the assessor-collector.

Section 33.23 does not specify who is to prepare the inventory or personal property seized in accordance with a tax warrant. Consistent with case law and with practical considerations, the officer who executes the warrant must prepare the inventory.

In accordance with section 33.25 of the Tax Code, in a county the size of Harris County, the sale of seized personal property must be held (1) by either the peace officer or the tax assessor-collector, whomever the court has specified in the tax warrant; or (2) under an agreement authorized by the commissioners court, by an auctioneer or Internet service provider. See TEX. TAX CODE ANN. §33.25(a)(2) (Vernon Supp. 2004). If the seller is an auctioneer or an Internet service provider, it should pay the proceeds either to the peace officer, who must pay them to the assessor-collector, or directly to the assessor-collector, in accordance with the agreement. An officer who receives proceeds from a third party or who receives proceeds as a result of having personally conducted the sale must pay them over to the assessor-collector. The assessor-collector must distribute the proceeds as section 33.25(f) directs.

Seized real property must be sold by "the officer charged with selling" it, unless directed otherwise by the taxing unit that requested the warrant. Id . §34.01(a). The officer who conducted the sale must distribute the proceeds. See id . §34.01(b).

Seized personal property may be sold at any time, unless the warrant or agreement with an auctioneer specifies otherwise.

None of the Tax Code provisions examined in this opinion unconstitutionally delegate authority to a tax collector-assessor.

For further information, please access the web site at www.oag.state.tx.us or call the Opinion Committee at (512) 463-2110.

TRD-200400708

Nancy S. Fuller

Assistant Attorney General

Office of the Attorney General

Filed: February 4, 2004


Request for Opinions

RQ-0165-GA

Requestor:

The Honorable Kurt Sistrunk

Criminal District Attorney, Galveston County

722 Moody, Suite 300

Galveston, Texas 77550

Re: Procedure for filling a vacancy in the office of district clerk (Request No. 0165-GA)

Briefs requested February 26, 2004

RQ-0166-GA

Requestor:

The Honorable Mike Stafford

Harris County Attorney

1019 Congress, 15th Floor

Houston, Texas 77002

Re: Constitutionality of the family protection fee authorized by §51.961, Texas Government Code (Request No. 0166-GA)

Briefs requested by February 27, 2004

RQ-0167-GA

Requestor:

Alicia G. Key

Administrative Director

Office of Court Administration

205 West 14th Street, Suite 600

Austin, Texas 78711-2066

Re: Whether a standard felony judgment form should include the name and address of a crime victim (Request No. 0167-GA)

Briefs requested by February 27, 2004

RQ-0168-GA

Requestor:

The Honorable Hector M. Lozano

Frio County Attorney

500 East San Antonio Street, Box 1

Pearsall, Texas 78061-3100

Re: Whether certain officials of a home-rule city may continue to hold their positions after announcing their candidacies for county officers (Request No. 0168-GA)

Briefs requested by February 28, 2004

For further information, please access the web site at www.oag.state.tx.us or call the Opinion Committee at (512) 463-2110.

TRD-200400709

Nancy S. Fuller

Assistant Attorney General

Office of the Attorney General

Filed: February 4, 2004