Camacho v. Samaniego

831 S.W.2d 804, 1992 WL 91434
CourtTexas Supreme Court
DecidedJune 17, 1992
DocketD-1425
StatusPublished
Cited by79 cases

This text of 831 S.W.2d 804 (Camacho v. Samaniego) is published on Counsel Stack Legal Research, covering Texas Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Camacho v. Samaniego, 831 S.W.2d 804, 1992 WL 91434 (Tex. 1992).

Opinion

OPINION

PHILLIPS, Chief Justice.

This case involves a challenge by various bail bond issuers to the El Paso County Commissioners Court’s pre-conviction bail bond filing fee. The trial court, El Paso County Court at Law No. 2, rendered summary judgment against the issuers and upheld the fee. On appeal, the court of appeals on its own motion held that the statutory county court had no constitutional authority to hear the case. Accordingly, it vacated the trial court’s judgment and dismissed the suit. We hold that because the statutory county judge was, pursuant to a constitutionally valid statute, sitting as a district court judge, the trial was legally conducted in a court of proper jurisdiction. We further hold, however, that the county was not authorized to impose the fee in question. Accordingly, we reverse the judgment of the court of appeals, render a declaration that the fee is illegal, and remand to the trial court for further proceedings.

Facts and Procedural Background

In 1983, pursuant to the authorization of the El Paso County Commissioners Court and County Bail Bond Board, 1 the Sheriff of El Paso County began collecting a two-dollar fee on each surety bail bond filed for the release of persons from the El Paso County Jail. The fee was required of all persons in the business of issuing bail bonds on each bond filed in a felony or misdemeanor charge. No fee was assessed, however, for cash or personal bonds. For a few years, the Sheriff billed the bond businesses on a monthly basis; but commencing in 1987, payment was required upon presentation of the bond. The Commissioners Court raised the amount of the fee on several occasions, the current charge being $18.00 for each bond. 2

*806 The first action challenging this fee was brought against El Paso County and its Sheriff, Leo Samaniego, on January 25, 1988, by Mary Camacho, individually and doing business as Afuera Out Bail Bonds, and Nancy Merrill, doing business as Merrill Bail Bonds. 3 They claimed that the fees violated both the Texas Constitution and the Code of Criminal Procedure. As damages, they sought a return of all fees paid pursuant to the orders, four times that sum as a penalty under Tex.Rev.Civ.Stat. art. 3909, pre-judgment interest, and costs of court.

Although the face of the petition indicated a filing in district court, by law the statutory county courts of El Paso County have, since 1987, exercised substantially equivalent jurisdiction with state district courts. When suit was filed, Section 25.-0732 of the Government Code provided in relevant part:

(a) In addition to the jurisdiction provided by Section 25.0003 4 and other law, *807 and except as limited by Subsection (b), a county court at law in El Paso County has the jurisdiction provided by the constitution and by general law for district courts.
(b) A county court at law does not have jurisdiction of:
(1) felony cases;
(2) suits in behalf of the state to recover penalties, forfeitures, or escheat;
(3) misdemeanors involving official
misconduct;
(4) contested elections; or
(5) appeals.
(c) A county court at law has, concurrent with the county court, the probate jurisdiction provided by general law for county courts. 5

Upon filing, the district clerk, who also serves by law as clerk of the statutory county courts as well as district courts in El Paso County in cases of concurrent jurisdiction, 6 assigned the lawsuit to County Court at Law No. 2 of El Paso County. All parties agree that the district clerk accomplished this assignment by some random selection method, not by deliberate choice. On November 18, 1988, the court, on its own motion, ordered that damages be tried separately from, and subsequent to, the action for declaratory judgment.

Some months later, Frederick S. Tim-mons, Jr., individually and doing business as “Get Free” Bail Bonds Co., and Alberto J. De Lachica, Jr., individually and doing business as Lachica Bail Bonds, 7 filed a substantially similar action which was assigned to the 210th District Court of El Paso County. 8 On defendants’ motions, *808 Timmons and De Lachica’s suit was first transferred to County Court at Law No. 2, then consolidated with Camacho and Merrill’s suit. Both sets of plaintiffs unsuccessfully sought class certification of all bond businesses and all individuals required to pay a fee prior to release on bond from the El Paso County Jail. Timmons alternatively sought to join all bond businesses in El Paso County as involuntary plaintiffs pursuant to Tex.R.Civ.P. 39. Although the court denied all these motions, the following bond businesses voluntarily intervened before trial: Armando Camacho, doing business as Camacho Bail Bonds; Alberto Lopez, Jr., doing business as Compa Bail Bonds and A-l Bail Bonds; Fernando Lara Basoco, doing business as El Paso Bail Bonds; Dolores G. Solis, doing business as A.D. Solis Bail Bonds; Odia Harvey, doing business as Amigo Bail Bonds; and Kirsten Apodaca, doing business as Apodaca Bail Bonds.

All parties and intervenors sought summary judgment after the parties stipulated virtually all relevant facts. Defendants asserted that the orders assessing the bail bond fee did not violate the federal or state constitution or any statute, while the bond businesses moved for a partial summary judgment on all liability issues, reserving damages for later determination.

After all motions were filed, defendants for the first time contested the subject matter jurisdiction of the statutory county court. By this time, Section 25.0732 had been amended to eliminate the exclusion of appeals from the county court at law’s jurisdiction. Tex. Gov’t Code Ann. § 25.-0732(b) (Vernon Supp.1992). Pursuant to this amendment, the trial court held that it had jurisdiction to review the actions of the commissioners court. It then granted defendants’ motion for summary judgment and denied plaintiffs’ and amended inter-venors’ motions for partial summary judgment.

The bond businesses appealed to the court of appeals, seeking a declaration that the fee was unconstitutional and a remand for a trial on damages only. The county and sheriff did not re-urge the alleged jurisdictional defect on appeal, arguing instead that the trial court’s determination was correct. On its own motion, however, the court of appeals raised the issue of jurisdiction, reversed the trial court’s judgment, and dismissed the entire cause.

The court noted that under Tex. Const, art. V, sec. 8, and Tex. Gov’t Code Ann. § 24.020, the district court had “appellate jurisdiction

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Cite This Page — Counsel Stack

Bluebook (online)
831 S.W.2d 804, 1992 WL 91434, Counsel Stack Legal Research, https://law.counselstack.com/opinion/camacho-v-samaniego-tex-1992.