James R. Ray v. Texas State Board of Public Accountancy

CourtCourt of Appeals of Texas
DecidedOctober 21, 1999
Docket03-98-00557-CV
StatusPublished

This text of James R. Ray v. Texas State Board of Public Accountancy (James R. Ray v. Texas State Board of Public Accountancy) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James R. Ray v. Texas State Board of Public Accountancy, (Tex. Ct. App. 1999).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN




NO. 03-98-00557-CV

James R. Ray, Appellant


v.



Texas State Board of Public Accountancy, Appellee



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 261ST JUDICIAL DISTRICT

NO. 95-09251, HONORABLE SUZANNE COVINGTON, JUDGE PRESIDING

James R. Ray, appellant, appeals from a district-court judgment affirming an administrative order revoking his license to practice as a certified public accountant. In the two issues he raises on appeal, Ray complains that appellee, the Texas State Board of Public Accountancy, (1) impermissibly delegated its legislative and administrative authority to a private organization in violation of article III, section 1 of the Texas Constitution; and (2) denied him due process of law as guaranteed by both article I, section 19 of the Texas Constitution and the 14th Amendment of the United States Constitution. See Tex. Const. art. III, § 1, art. I, § 19; U.S. Const. amend. XIV, § 2. We will affirm the district court's judgment.



BACKGROUND

Ray was a certified public accountant licensed by the Texas State Board of Public Accountancy (the "State Board"). In 1994, Ray received notice from the State Office of Administrative Hearings informing him that a hearing had been scheduled to address certain allegations against him, including charges that Ray had violated several well-established professional standards with respect to audits he had performed of two insurance companies in 1992. More specifically, the State Board alleged that Ray had issued materially false and misleading financial statements and had failed to comply with "generally accepted accounting principles" and "generally accepted accounting standards" in his performance of the audits. Ray was provided three months notice of the proceedings and was told that the hearing would be limited in length to two days. The proceedings were conducted accordingly in July 1994. Both the State Board and Ray presented expert testimony on the issue of whether Ray had violated generally accepted accounting principles and standards in conducting his audits. On the first day, the hearing lasted from 10:00 a.m. until approximately 6:00 p.m. On the second day, the hearing commenced at 10:00 a.m. and did not adjourn until 2:00 a.m. the following morning.

After considering the arguments and evidence presented by each party, including expert-witness testimony from both sides regarding Ray's compliance with professional accounting standards, the Administrative Law Judge ("ALJ") ruled in the State Board's favor and recommended that Ray's license be revoked. In her proposal for decision, the ALJ found that Ray failed to adequately document his work papers, obtain sufficient and competent evidence supporting the information in his audit reports, exercise professional judgment regarding the validity of the supporting documentation, and detect errors and irregularities in the financial statements provided to him by the companies. (1) The ALJ concluded that the evidence demonstrated a significant pattern of failure to exercise due care throughout the audits and that Ray did not know how to conduct a proper, reliable, or professional audit. After reviewing the ALJ's proposal for decision and hearing additional oral argument from both parties, the State Board adopted the ALJ's proposal in all respects and revoked Ray's license.

Upon the State Board's denial of his motion for rehearing, Ray filed suit in district court, seeking judicial review of the State Board's action. See Public Accountancy Act, Tex. Rev. Civ. Stat. Ann. art. 41a-1, § 22 (f) (2), (3) (West Supp. 1999); see also Administrative Procedure Act, Tex. Gov't Code Ann. § 2001.176 (West Supp. 1999). Ray asserted that the State Board had exceeded its statutory authority, abused its discretion, and denied him due process of law, and that its decision was not supported by substantial evidence. After a two-day hearing, the district court rejected these claims and rendered judgment affirming the State Board's decision to revoke Ray's license.

Ray now appeals the district court's judgment, claiming that the State Board unconstitutionally delegated its powers to the American Institute of Public Accountants (the "Institute") and denied him procedural due process in the proceedings before the State Office of Administrative Hearings ("SOAH").



DISCUSSION

Unconstitutional Delegation

We first address the issue of whether the State Board unconstitutionally delegated its rulemaking authority to a private organization. Ray contends that section 501.22 of the Texas Administrative Code is an unconstitutional delegation of legislative and regulatory authority to the Institute. (2) 22 Tex. Admin. Code § 501.22 (1999); Tex. Const. art. III, § 1. Ray contends that every point on which the ALJ ruled against him was founded upon violations of the standards promulgated by the Institute through its Financial Accounting Standards Board (collectively the "Institute"). The State Board refers to these standards in section 501.22 of the Texas Administrative Code, which provides:



A certificate or registration holder shall not permit his name to be associated with financial statements in such a manner as to imply that he is acting as an independent public accountant with respect to such financial statements, unless he has complied with applicable generally accepted auditing standards. Statements on auditing standards issued by the American Institute of Certified Public Accountants, auditing standards included in Standards for Audit of Governmental Organizations, Programs, Activities and Functions, issued by the United States General Accounting Office, and in other pronouncements having similar generally recognized authority, are considered to be interpretations of generally accepted auditing standards, and departures from such pronouncements, where they are applicable, must be justified by those who do not follow them.



22 Tex. Admin. Code § 501.22 (1999) (emphasis added).

Ray argues that the State Board's incorporation of these standards in its rule is an unbridled delegation of legislative and administrative power to the Institute. We disagree and hold that this is not an unconstitutional delegation of power.

We addressed a similar argument in Central Power & Light Co. v. Sharp, 919 S.W.2d 485, 492-93 (Tex. App.--Austin 1996), pet. denied per curiam, 960 S.W.2d 617 (Tex. 1997). Central Power involved a statute and agency rule that required corporations to compute their annual surpluses, assets, and debts according to "generally accepted accounting principles" for tax purposes. See id. at 492; see also Tex. Tax Code Ann.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Mathews v. Eldridge
424 U.S. 319 (Supreme Court, 1976)
John Ed Price v. City of Junction, Texas
711 F.2d 582 (Fifth Circuit, 1983)
United Savings Ass'n of Texas v. Vandygriff
594 S.W.2d 163 (Court of Appeals of Texas, 1980)
State v. Crank
666 S.W.2d 91 (Texas Supreme Court, 1984)
Central Power and Light Co. v. Sharp
960 S.W.2d 617 (Texas Supreme Court, 1997)
Sears v. Texas State Board of Dental Examiners
759 S.W.2d 748 (Court of Appeals of Texas, 1988)
University of Texas Medical School at Houston v. Than
901 S.W.2d 926 (Texas Supreme Court, 1995)
Central Power and Light Co. v. Sharp
919 S.W.2d 485 (Court of Appeals of Texas, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
James R. Ray v. Texas State Board of Public Accountancy, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-r-ray-v-texas-state-board-of-public-accounta-texapp-1999.