State Highway Commission v. Coahoma County

32 So. 2d 555, 203 Miss. 629, 1947 Miss. LEXIS 367
CourtMississippi Supreme Court
DecidedNovember 10, 1947
DocketNo. 36585.
StatusPublished
Cited by17 cases

This text of 32 So. 2d 555 (State Highway Commission v. Coahoma County) is published on Counsel Stack Legal Research, covering Mississippi Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Highway Commission v. Coahoma County, 32 So. 2d 555, 203 Miss. 629, 1947 Miss. LEXIS 367 (Mich. 1947).

Opinions

Up to the time of the advent of the automobile as a practical means of conveyance all the roads in the state, outside of municipal streets, were of a primitive type, none of them being paved, except for some few yards here and there in swampy places where planked corduroys had been laid or sometimes but in rare instances a few yards of concrete were used. Along the coast there was a considerable mileage of shell roads but these were soon found to be wholly inadequate as against automobile travel.

The automobile had come into large use in the state by 1910, and there arose a demand in many parts of the state that more adequate roads be constructed or reconstructed. In that year Chapter 149, Laws 1910, was enacted authorizing the creation of road districts under the supervision of district commissioners after surveys by competent road engineers employed for that purpose, all to *Page 645 be subject to the approval or disapproval of the board of supervisors of the respective counties.

Under this Act many road districts were created and the preliminary work was done by them which later led to the broader field of state highways. The Act of 1910 was soon followed by other district enactments some of which undertook to place jurisdiction over the roads and the construction thereof entirely in the hands of the district road commissioners, but these acts were declared unconstitutional in State ex. rel. v. Board of Supervisors, 111 Miss. 867, 72 So. 700, and Havens v. Hewes,128 Miss. 650, 91 So. 397, on the ground that under Section 170, Constitution 1890, full jurisdiction over roads in the several countries was vested in the board of supervisors.

In 1916, fettered as it was by Section 170 of the Constitution, the legislature created by Chapter 168, Laws 1916, a state highway commission, which with the state highway engineer, to be appointed by the commission was to constitute the state highway department, the duties of which were "to consider and adopt plans for laying out opening, altering and working roads and building highways," the chief purpose being to act as an intermediary as regards federal road funds. In 1920, by Chapter 203, Laws 1920, a state highway department was created with broader duties and powers among which was "to cooperate with the boards of supervisors and district road commissioners, of the respective counties in the surveying, laying out and adoption of a state highway system." It was further provided that the powers of the state highway commission are advisory to the board of supervisors whom the commission may assist with its engineering force "in establishing, locating, surveying and building roads, culverts, and bridges, in the system of state highways and inter-state roads . . . and it may pay part of the construction costs of such highways from its current funds and may assist in the building of said roads, culverts and bridges from any of its funds, either those derived from the state or national government." *Page 646

In this Act, chapter 203, Laws 1920, there was the beginning in point of actuality of the state highway system. At the same session a constitutional amendment was proposed to amend Section 170 of the Constitution so as to remove the jurisdiction of the boards of supervisors. This proposed amendment was too broad, and another was proposed at the session of 1922 which was adopted by the people and was inserted in the Constitution by Chapter 143, Laws 1924, whereupon Chapter 278, Laws 1924, was enacted, designating certain highways as state highways and placing them under the jurisdiction of the state highway department. All the highways concerned in the case now before us are within the designation mentioned.

There was no provision in the Act of 1924 for the construction or reconstruction of any of the highways by the state. It provided for maintenance only so far as the state was concerned. From 1924 to 1930 no important state highway statutes were enacted. What happened was that although there was general agreement that the state should pay the entire cost of the construction or reconstruction of the designated state highways, the type of pavement to be used became the subject of partisan political controversy so that it was not until 1930 that a comprehensive and adequate statute for the conversion of the state highway system into one of modern paved highways was enacted.

In that year by Chapter 47, Laws 1930, a comprehensive statute to the ends aforesaid, under the leadership of Horace Stansel, a member of the lower house who was a competent road engineer, was passed, now known as the Stansel Act. After designating the highways that were to be considered primary state highways, the Act, as a dominant expression of its purpose, declared that such primary highways "are hereby placed under the supervision and control of the State Highway Commission for construction, reconstruction and maintenance at the cost and expense of the state." As already stated, *Page 647 there had never been any difference of opinion that the cost of the construction and reconstruction incident to the conversion of the old highways into modern paved highways should be at the cost and expense of the state, so far as the primary highway system was concerned.

But none of the previous enactments had placed any sufficient funds in the hands of the state highway department by which it could construct or reconstruct any of the roads in the state highway system. All that the department had was a portion of the gasoline taxes and of the road privilege taxes, sufficient for little more than the cost of maintenance. Nor did the Stansel Act provide any additional funds, the fact being that when the Stansel Act was passed in 1930 the profound depression that was soon to prostrate the finances of the state and entire country was plainly to be foreseen. It was not until 1936 that state funds for construction and reconstruction were provided.

It was foreseen or anticipated when the Stansel Act was passed that certain counties might be in a financial position, and would desire, to convert certain of its old roads in the primary system into modern paved highways before the time when the state could or would furnish the money so to do. Accordingly there was inserted in the Stansel the following section, now Section 5003, Code 1930, Section 8035, Code of 1942:

"Should any county desire to complete all or any part of the primary system of highways, as set out in this act, which lies in its borders at an earlier date than traffic demands and the regular order established hereunder would construct same, and if the revenues of such county from unpledged gasoline and motor vehicle privilege taxes are of such amount that half of such revenue will pay the interest and sinking fund of serial bonds needed for such construction, such bonds may be issued, as is now provided by law, for counties having 50,000 population, as general obligations of the county, and such gasoline or privilege taxes may be used to pay the interest and sinking *Page 648 fund of same, or if the county shall desire to issue general obligations of such county to be retired by ad valorem levy according to general law, then the county may issue highway bonds for such purposes in the manner and method provided by law. The proceeds from such bonds shall be placed in a special fund for the purpose of paying the cost of construction of such portions of the primary system in such county, and such county may proceed to construct such highways in the manner prescribed by law.

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State Highway Commission v. Coahoma County
32 So. 2d 555 (Mississippi Supreme Court, 1947)

Cite This Page — Counsel Stack

Bluebook (online)
32 So. 2d 555, 203 Miss. 629, 1947 Miss. LEXIS 367, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-highway-commission-v-coahoma-county-miss-1947.