School Director Expenses

74 Pa. D. & C.2d 716
CourtPennsylvania Department of Justice
DecidedNovember 5, 1975
DocketNo. 75-39
StatusPublished
Cited by1 cases

This text of 74 Pa. D. & C.2d 716 (School Director Expenses) is published on Counsel Stack Legal Research, covering Pennsylvania Department of Justice primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
School Director Expenses, 74 Pa. D. & C.2d 716 (Pa. 1975).

Opinion

KANE, Attorney General,

You have requested our opinion as to whether members of the boards of school directors are entitled to reimbursement for lost wages in instances where they attend educational conventions. It is our opinion, and you are advised, that school directors are not entitled to reimbursement for lost wages resulting from attendance at educational conventions. Section 516 of the Public School Code of March 10, 1949, P.L. 30, art. V, as amended, 24 P.S. §5-516.1, permits members of boards of school directors to be reimbursed “for all expenses actually and necessarily incurred in going to, attending [717]*717and returning from the place of such meeting, including travel, travel insurance, lodging, meals, registration fees and other incidental expenses necessarily incurred, but not exceeding thirty dollars ($30.00) per day for lodging and meals.”

In order to reach an opinion on the question you raised, it becomes important to determine the meaning of the terms “all expenses actually and necessarily incurred” and “other incidental expenses necessarily incurred.”

I. The Statutory Construction Act of December 6, 1972, P.L. 967 (No. 290), sec. 3, provides that words and phrases shall be construed “according to their common and approved usage.”: 1 Pa.C.S. §1903. The dictionary definitions of the terms “expenses” and “incurred” shed some light in this area. The word “expenses” is defined as:

“The act or practice of expending money; the act or practice of using up; something expended to secure a benefit or bring about a result; financial burden or outlay; the charges incurred by an employe in connection with the performance of his duties; an item of business outlay chargeable against revenue for a specific period; a cause or occasion of expenditures; a sacrifice.”: Webster’s Third New International Dictionary.

The word ‘ ‘incur’ ’ is defined as: “To become liable or subject to.”: Webster’s Third New International Dictionary. These dictionary definitions suggest that, according to common usage, a person has “incurred expenses” when he has “become subject to or hable to a laying out or using up of money or other resources.”

II. The courts have given a number of definitions to the term “expenses incurred.” In general, these have echoed the dictionary definitions, defining [718]*718“expense” to mean an outlay of funds made in connection with an enforceable legal obligation to pay. In the case of Municipal Housing Authority v. Levine, 136 N.Y.Supp. 2d 197, 198 (1954), the Schenectady County Court of New York summarized the general definition of “expense” followed by State and Federal courts and relied on the Webster’s Dictionary definition of “expense” as meaning that which is “expendable, laid out or consumed; cost; outlay; charge. . . .” In the case of the United States v. St. Paul Mercury Indem. Co., 133 F. Supp. 726, 732, 733 (1955), the United States District Court of Nebraska stated that “expenses are not incurred . . . unless the legal obligation to pay them has arisen.” A person has “incurred expenses” when he “has run into an obligation to pay out money.” The court emphasized that, to qualify as an expense in any legal sense, there must have been a “real and substantial, not a fictitious, ostensible or merely philosophical ‘running into the obhgation to pay.’ ”

A somewhat broader definition of “expense” has been set forth in two recent decisions. The Court of Civil Appeals of Texas in the case of Travelers Ins. Co. v. Valey, 421 S.W. 2d 478, 481 (1967), stated that the term “expense” means “money spent; cost; charge; money to pay for charges; cost with the idea of loss, damage or sacrifice; drain on one’s finances; outlay; burden of expenditures.” The Supreme Court of Minnesotain the case of Local 1140, Intern. Union of Elec., Radio and Mach. Workers, AFL-CIO v. Massachusetts Mut. Life Ins. Co., 282 Minn. 455, 165 N.W. 2d 234, 236 (1969), stated that the word “expense” may include, in addition to monetary payment, the employment and consumption of time and labor or the expenditure of other [719]*719resources. The Travelers Insurance and Local 1140 cases represent an enlargement of the definition traditionally used by the courts, and may lend some credence to the position that a school directors’ lost wages should be included as an expense of the type designated as an “other resource, ”i.e., of their jobs as sources of income. However, in both cases the definition of “expense” still carries with it the connotation of an enforceable legal obligation to pay the commodity being expended, (whether money, time or other resources.) The school directors do, indeed, suffer a real loss of wages when they leave their regular occupations to attend educational conventions. However, they cannot be said, by the act of going to such a convention, to render themselves subject to a legal obligation to pay out or expend the amount of wages they would have received had they not attended the convention. Those particular wages would only become the property of the school directors had they worked instead of attending the convention, and performed the services for which the wages were to be paid. In no real sense can the school directors be said to have “laid out,” “spent” or committed themselves to pay wages which, by virtue of their attendance at an educational convention, they never earned and thus never possessed. Thus, lost wages would not fall within the definition of an “expense incurred” so that no legislative intent may be inferred that school directors should be reimbursed for wages lost as a result of attendance at educational conventions. The Statutory Construction Act of 1972, supra, provides that: “When the words of a statute are clear and free from all ambiguity, the letter of it is not to be disregarded under the pretext of pursuing its spirit.”: 1 Pa.C.S. §1921(b).

[720]*720III. Even if we were to assume arguendo that the meaning of expenses is ambiguous, we would still not be able to construe section 516 as authorizing school directors to be reimbursed for wages lost as a result of attendance at educational conventions. In the construction of laws, where general words are followed by words of a particular and specific meaning, the courts have held that “such general words are not to be construed in their widest extent, but are to be held as applying only to persons or things of the same general kind or class as those specifically mentioned.”: Abeles v. Adams Engineering Co., Inc., 64 N.J. Super, 167, 165 A. 2d 555, 560 (1960). See also 1 Pa.C.S. §1903(b). In section 516.1, the general words “expenses actually and necessarily incurred” are followed by the following words of particular and specific meaning:

“Travel, travel insurance, lodging, meals, registration fees and other incidental expenses necessarily incurred.”

The term “lost wages” is not of the same general kind or class as the terms “travel, travel insurance, lodging, meals, registration fees and other incidental expenses.” Therefore, the loss of wages could not be. construed as an “expense incurred” within the meaning of section 516 of the act.

IV. Section 321 of the Public School Code of March 10, 1949, P.L. 30, art. Ill, as amended, 24 P.S. §3-321, specifically states that all persons elected or appointed as school directors shall serve without pay.

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74 Pa. D. & C.2d 716, Counsel Stack Legal Research, https://law.counselstack.com/opinion/school-director-expenses-padeptjust-1975.