Untitled Texas Attorney General Opinion

OFPlCE

OFTHEATTORNEY

GENERAL.

swrc OPTEXILS

JOHN CORNYN

October 27.2000

The Honorable Susan D. Reed Opinion No. JC-0300

Bexar County Criminal District Attorney

Bexar County Justice Center Re: Whether under section 3 12.206(a) of the Tax

300 Dolorosa, 5th Floor Code a county commissioners court is authorized

San Antonio, Texas 7871 l-2548 to enter into a tax abatement agreement only with

the owner of taxable real property, and related

questions (RQ-0212-JC)

Dear Ms. Reed:

The Property Redevelopment and Tax Abatement Act, chapter 3 12 of the Tax Code, allows

the governing bodies oftaxing units to enter into tax abatement agreements with respect to property

located in a reinvestment zone, under certain circumstances, for the purpose of economic

development of the property. You ask whether under section 312.206(a) of the Tax Code, a

commissioners court is authorized to enter into a tax abatement agreement only with the “owner of

taxable real property.“’ See TEX. TAX CODE ANN. 5 312.206(a) (Vernon Supp. 2000). If the

commissioners court is so limited, you also ask whether an owner of a leasehold interest in tax-

exempt real property may be considered an “owner of taxable real property” for the purposes of

section 312.206(a). See Request Letter, note 1, at 2, 7. We conclude that section 312.206(a)

authorizes a commissioners court to enter into a tax abatement agreement only with the “owner of

taxable real property” and that the owner of a leasehold interest in tax-exempt real property is not

such an “owner of taxable real property.”

The circumstances prompting your request are as follows: The Commissioners Court of

Bexar County has entered into a tax abatement agreement with Boeing Aerospace Operations, Inc.

(“Boeing”) for a ten-year term conditioned on Boeing investing in tangible personal property to be

located at its leased facility at Kelly Air Force Base in San Antonio. The federally owned base,

which is being realigned and will close in the year 2001, is located in the San Antonio Defense

Economic Readjustment Zone (the “Zone”) established by the City of San Antonio (the “City”)

pursuant to chapter 23 10 ofthe Government Code. Boeing leases its facility from the Greater Kelly

Development Authority (the “GKDA”), the Zone’s administrative authority, to which the property

has been conditionally conveyed by the federal government. Pursuant to chapter 2310, designation

of an area as a readjustment zone constitutes designation of the area as a reinvestment zone for tax

‘Letter from Honorable Susan D. Reed, Bexar County Criminal District Attorney, to Honorable John Comyn

at 3, 7 (Mar. 30,200O) (on tile with opinion Committee) [hereinafter Request Letter].

The Honorable Susan D. Reed - Page 2 (JC-0300)

abatement purposes under chapter 312 of the Tax Code. The City entered into a tax abatement

agreement with Boeing; and because the county must enter into any tax agreement with Boeing

under section 312.206(a) of the Tax Code within ninety days of the execution of the municipal

agreement, the county entered into the tax abatement agreement with Boeing subject to an attorney

general opinion concluding that Boeing is entitled to the tax abatement. See Request Letter, supra

note 1, at l-2.

You first ask: “Is a tax phase-in agreement entered into by a county under authority of Tax

Code 5 312.206 required to comply with Tax Code 3 312.204[(a)] relating to municipalities?”

Request Letter, supra note 1, at 7. We conclude in the affirmative.

Based on the information provided, we understand that the county seeks to exempt taxes on

the tangible personal property that Boeing will acquire for its tax-exempt leased facility located in

an area within the City of San Antonio and designated a readjustment zone pursuant to chapter 23 10

of the Government Code. Section 2310.407 of that chapter provides that “[dlesignation of an area

as a readjustment zone is also designation of the area as a reinvestment zone for: (1) tax increment

financing under Chapter 3 11, Tax Code; and (2) tax abatement under Chapter 3 12, Tax Code.” TEX.

GOV’T CODE ANN. 5 2310.407 (Vernon 2000).

Section 3 12.204(a) of the Tax Code authorizes an eligible city to enter into a tax abatement

agreement with the owner of taxable real property in a reinvestment zone within its taxing

jurisdiction by providing that:

The governing body of a municipality eligible to enter into tax

abatement agreements . may agree in writing with the owner of

taxable realproperty that is located in a reinvestment zone, but that

is not in an improvement project financed by tax increment bonds, to

exempt from taxation a portion of the value of the real property or of

tangible personal property located on the real property, or both .

TEX. TAX CODE ANN. 5 3 12.204(a) (Vernon Supp. 2000) (emphasis added). If a city executes a tax

abatement agreement with respect to property in a municipal reinvestment zone, other eligible taxing

units in which the property is located may also do so. Section 3 12.206(a) provides in pertinent part

that:

Ifproperty taxes on property located in the taxing jurisdiction

of a municipality are abated under an agreement made under Section

312.204 or 312.211: the governing body of each other taxing unit

%&ion 3 12.211 deals with real property that is the subject of a voluntary cleanup agreement under section

361.606 of the Health and Safety Code and personal prop&y located on the real property. See TEX. TAX CODEANN.

$ 312.211(a) (Vernon Supp. 2000). A city may enter into an agreement with the “owner of property described by

(continued...)

The Honorable Susan D. Reed - Page 3 (JC-0300)

eligible to enter into tax abatement agreements under Section 3 12.002

in which the property is located may execute a written tax abatement

agreement with the owner oftheproperty not later than the 90th day

after the date the municipal agreement is executed. The agreement is

not required to contain terms identical to those contained in the

agreement with the municipality. Section 312.2053 applies to an

agreement made by a taxing unit under this section in the same

manner as it applies to an agreement made by a municipality under

Section 312.204 or 312.211.

Id. 5 312.206(a) (emphasis added) (footnotes added); see also id. 5 312.206(c) (other taxing units

authorized to execute tax abatement agreements with owner of property in reinvestment zone in

city’s extraterritorial jurisdiction subject to restrictions in section 312.204 or 312.211, even if

municipality does not execute an agreement).

Your question requires us to construe section 312.206(a). When construing a statute, “our

primary objective is to give effect to the legislature’s intent.” MitcheN Energy Corp. Y. Ashworth,

943 S.W.2d 436, 438 (Tex. 1997). To give effect to legislative intent, we construe a statute

according to its plain language. See RepublicBank Dallas v. Interkal, Inc., 691 S.W.2d 605,607-08

(Tex. 1985); Bouldin v. Bexar County Sherif’s Civil Serv. Comm’n, 12 S.W.3d 527, 529 (Tex.

App.-San Antonio 1999, no pet.). Statutory words and phrases must be “read in context and

construed according to the rules of grammar and common usage.” TEX. GOV’T CODE ANN.

5 311.011 (Vernon 1998). Finally, exemptions from taxation are not favored by the law, and

“[sltatutory exemptions are subject to strict construction because they undermine equality and

uniformity by placing a greater burden on some taxpayers rather than all.” Baptist Mem ‘Is Geriatric

Ctr. v. Tom Green County Appraisal Dist., 851 S.W.2d 938, 942 (Tex. App.-Austin 1993, writ

denied) (citing North Alamo Water Supply Corp. v. Willacy County AppraisalDist., 804 S.W.2d 894,

899 (Tex. 1991)). Courts apply this rule of strict construction to measures that effectively reduce

or allow items to escape taxation as they are tantamount to tax exemptions. See, e.g., Bullock v.

National Bancshares Corp., 584 S.W.2d 268, 271-72 (Tex. 1979); State Bd. of Ins. v. Petroleum

Cas. Co., 447 S.W.2d 666,668 (Tex. 1969); Texas Utils. Elec. Co. v. Sharp, 962 S.W.2d 723,726

(Tex. App.-Austin 1998, pet. denied). Tax abatement is a form of tax exemption or relief from ad

valorem taxes on property located in a reinvestment zone. See TEX. CONST. art. VIII, 5 l-g

(amendment to equal and uniform provision permitting legislature to authorize taxing units to grant

Subsection (a)” under section 312.211 or under section 312.204, but not under both sections. Id. 5 312.21 l(g). We do

not understand the real property in question to be the subject of a voluntary cleanup agreement.

“Section 312.205 sets out certain %rms” that must be included or addressed in a tax abatement agreement.

See id. 5 312.205.

The Honorable Susan D. Reed - Page 4 (JC-0300)

tax exemptions or other tax relief from ad valorem property taxes on property located in

reinvestment zone to encourage development); Tex. Att’y Gen. Op. No. K-0092 (1999) (tax

abatement provision enacted to implement art. VIII, 9 l-g); TEX. TAX CODE ANN. 5 3 12.204(a)

(Vernon Supp. 2000) (city eligible to enter into tax abatement agreement may thereby agree “to

exempt from taxation a portion of the value of the real property or of tangible personal property”).

By its terms, section 312.206(a) authorizes a tax abatement agreement only with the owner

of taxable real property. See TEX. TAX CODE ANN. $3 12.206(a) (Vernon Supp. 2000). A county’s

authority under section 312.206(a) is derivative of a city’s authority to enter into a tax abatement

agreement under section 312.204(a) of the Tax Code.4 See id. $9 312.204(a), .206(a). Section

312.204(a) authorizes a city to enter into an agreement with the “owner of taxable real property.”

Compare id. 5 312.204(a), with id. § 312.204(e) (eligible municipality authorized to execute tax

abatement agreement with owner or lessee of real property when property owned or leased by

certificated air carrier). Section 3 12.206(a) specifically provides that “[ilfproperty taxes on property

located in the taxing jurisdiction of a municipality are abated under an agreement made under

Section 312.204 each other taxing unit eligible may execute a written tax abatement

agreement with the owner of theproperty. .” Id. 5 3 12.206(a) (emphasis added). “Owner of the

property” here necessarily refers back to the owner of the taxable real property with whom the city

has executed an “agreement made under Section 312.204” in the preceding phrase. See

RepublicBank Dallas, 691 S.W.2d at 607 (to effect legislative intent, statute to be construed

according to its plain language); TEX. GOV’T CODE ANN. 9 311 ,011 (Vernon 1998) (word and

phrases to be “read in context and construed according to the rules of grammar and common usage”).

Thus section 312.206(a) authorizes tax abatement agreements with the “owner of taxable real

property.”

This construction is consistent with the tax abatement provisions of chapter 3 12. See Jones

v. Fowler, 969 S.W.2d 429,432 (Tex. 1998) (legislative intent to be determined from entire act not

simply from isolated portions of act); Sayre Y. Mullins, 681 S.W.2d 25, 27 (Tex. 1984) (in

determining meaning of statutory language, statute to be read as whole giving consideration to entire

act, its nature and object, and consequences that would follow fiorn particular construction). As

discussed above, under section 312.204(a), an eligible city is authorized to enter a tax abatement

agreement only with the owner of the taxable real property. Pursuant to section 3 12.402, a county,

under its independent tax abatement agreement authority with respect to property located in a county

designated reinvestment zone, is also authorized to enter tax abatement agreements only with the

owner of taxable real property: “The commissioners court may execute a tax abatement agreement

with the owner of taxable real property located in a reinvestment zone designated under this

subchapter [C: Tax Abatement in County Reinvestment Zone].” TEX.TAXCODEANN. 5 312.402(a)

(Vernon Supp. 2000).’ Like the section 3 12.204(a) and 3 12.206(a) scheme, ifthe county enters into

%?e also id. 9 312.401 (Vernon 1992) (authorizing county to designate reinvestment zone in area of county

(continued...)

The Honorable Susan D. Reed - Page 5 (JC-0300)

a tax abatement agreement under section 312.402(a), other taxing units in which the property is

located may also enter into agreements abating taxes on that property. See id. 4 312.402(b). It

would be an anomalous result if a city and a county under their independent authority could not enter

into a tax abatement agreement with persons other than the owner of taxable real property, but a

taxing unit, including a county, could do so under their derivative authority. The legislature could

not have intended such a result given that when it has desired to authorize a taxing unit to execute

a tax abatement agreement with persons other than the owner of taxable real property in chapter 3 12,

it has so expressly provided. Subsection(e) of section 3 12.204 authorizes an eligible city to execute

tax abatement agreements “with the owner or lessee of realproperty that is located in a reinvestment

zone to exempt horn taxation. a portion of the value of the real property or of persona1 property,

or both, located within the zone and owned or leased by a certificated air carrier.” Id. 5 3 12.204(e).

We do not believe that section 3 12.204(a) is permissive. See Baptist Mem ‘Is Geriatric Ctr.,

851 S.W.2d at 942 (statutory tax exemptions subject to strict construction). Execution of the

agreement with the owner of taxable real property is not an optional “term” of the agreement, such

as the portion of the property to be exempted from taxation or the duration of the agreement, see

TEX. TAX CODE ANN. 5 312.206(c), (e) (V ernon Supp. 2000), or the kind or number of

improvements to be made, with which a county need not comply. See id. 5 312.206(a) (“The

agreement is not required to contain terms identical to those contained in the agreement with the

municipality.“). Rather, it is a prerequisite to the execution of the agreement in the first instance.

See id. (“each other taxing unit eligible may execute a written tax abatement agreement with the

owner of the property”).

You also ask: “May a county, pursuant to Tax Code 5 312.206, rely on a city’s agreement

to abate taxes on property located in its jurisdiction as the county’s sole authority to enter into an

agreement with the same property owner. 7” Request Letter, supra note 1, at 7. In essence, you ask

whether a county may enter into a tax abatement agreement with an entity that is not the owner of

taxable real property simply because a city has entered into an abatement agreement with that entity.

Based on our conclusion that, under section 3 12.206(a), acommissioners court is authorized to enter

into a tax abatement agreement only with the owner of taxable real property, we conclude in the

negative.

If a section 312.206(a) county tax abatement agreement must be with the owner of taxable

real property, you next ask: “[Mlay Boeing be considered an ‘owner of taxable real property’ under

Tax Code 5 3 12.204(a) by virtue ofit owning and controlling a leasehold interest in tax-exempt real

property owned by the United States Government, and conveyed to the [GKDA], located within the

San Antonio Defense Economic Readjustment Zone that has been established at Kelly Air Force

Base?’ Id. We conclude in the negative.

that does not include area in taxing jurisdiction of any municipality)

The Honorable Susan D. Reed - Page 6 (X-0300)

First, construing Boeing’s tax-exempt leasehold interest to qualify for tax abatement under

section 3 12.206(a) would require reading out ofthe statute the term ‘taxable” contrary to established

principles of statutory construction. We must give effect to each word in a statute when possible

because it is a well-established rule of statutory construction that every word in a statute is presumed

to have been used for a purpose and that the legislature did not intend to do a useless act by putting

in a meaningless provision. See Laidlaw Waste Sys., Inc. v. City of Wilmer, 904 S.W.2d 656,659

(Tex. 1995); Barr v. Bernhard, 562 S.W.2d 844,849 (Tex. 1978); Jessen Assocs., Inc. v. Bullock,

531 S.W.2d 593,600 (Tex. 1975); Perkins Y.State, 367 S.W.2d 140,146 (Tex. 1963). Giving effect

to the term “taxable,” it is an inescapable conclusion that real property on which taxes are authorized

to be abated under section 312.206(a) must be taxable. While a leasehold interest in tax-exempt

real property that “may be [of] at least one year” duration is generally taxable, see TEX. TAX CODE

ANN. 5 25.07(a) (Vernon Supp. 2000), Boeing’s leasehold interest is tax-exempt pursuant to a

“grandfather” provision of the Development Corporation Act of 1979. See Request Letter, supra

note 1, at 5-6; see also TEX. REV. CIV. STAT. ANN. art. 5190.6,s 4B(k) (Vernon Supp. 2000). Thus,

even assuming that a leasehold interest constitutes ownership ofreal property, the leasehold interest

here is not taxable.

Moreover, we do not believe a lessee of real property is an “owner of real property” within

the meaning of section 312.204(a). First, a lessee, by definition, is not the “owner” of the real

property. See, e.g., BLACK'S LAW DICTIONARY898 (7th ed. 1999) (defining “lease” as “[a] contract

by which a rightful possessor of real property conveys the right to use and occupy that property in

exchange for consideration, usu. rent.“); id. at 914 (defining “lessee” as [o]ne who has apossessory

interest in real or personal property under a lease; TENANT.“). Second, and more important, the

legislature clearly does not believe or intend “owner of real property” to encompass a lessee of that

property because when the legislature wishes to provide tax abatement to a lessee of real property,

it has done so expressly. Subsection (e) of section 312.204 expressly authorizes an eligible city to

execute tax abatement agreements with the owner or lessee of real property: “The governing body

of a municipality may agree in writing with the owner or lessee of realproperty that is located

in a reinvestment zone to exempt from taxation a portion of the value of the real property or

of personal property, or both, located within the zone and owned or leased by a certificated air

carrier. .” TEX. TAXCODEANN. 5 3 12.204(e) (Vernon Supp. 2000). As the Texas Supreme Court

has said: “‘It is a rule of statutory construction that every word of a statute must be presumed to

have been used for a purpose. Likewise, we believe every word excluded from a statute must also

be presumed to have been excluded for a purpose.“’ Laidlaw Waste Sys., 904 S.W.2d at 659

(citation omitted). Ifthe legislature intended lessees ofreal property to be eligible for tax abatement

under section 3 12.204(a), it would have expressly so provided as it did in another section of the same

statute.

We do not believe that Letter Opinion 98-001, construing section 3 12.402(d) which prohibits

a commissioners court from entering into a tax abatement agreement regarding property “owned or

leased by a member of the commissioners court,” supports a contrary interpretation. TEX. TAX CODE

ANN. 5 312.402(d) (Vernon Supp. 2000); see also Tex. Att’y Gen. LO-98-001. Relying on the

The Honorable Susan D. Reed - Page 7 (X-0300)

ordinary meaning of the terms “own” and “owner,‘* this offIce in Letter Opinion 98-001 determined

that:

the terms “owned” and “owner” in chapter 3 I2 refer to property

interest that includes at least some degree of control over the property

and do not embrace amere beneficial or equitable interest in property

completely lacking such control. A person who holds legal title to

property and owns the property in fee simple is clearly an owner for

purposes of chapter 3 12. We also believe that the sole shareholder of

a corporation who has the authority to dispose of corporate assets

may be an owner of corporate property for purposes of the chapter.

We do not believe, however, that the owner of a very small

percentage of a publicly-held corporation’s shares can be said to own

corporate property for purposes of chapter 312.

Tex. Att’y Gen. LO-98-001, at 3 (footnote omitted) (emphasis added). Although Letter Opinion 98-

001 indicates that an “owner” for the purpose of chapter 312 may include the holder of property

interest including some degree of control short of legal title in fee simple, it cannot reasonably be

read to include a leasehold interest when such an interest is specifically and separately provided for

under chapter 3 12.

Although you ask us only about section 3 12.206 of the Tax Code, a brief submitted by the

City of San Antonio argues that the county is authorized to enter into a tax abatement agreement

with Boeing, as the owner of the personal property on which taxes are to be abated, under section

31 I .0125 of the Tax Code.’ We disagree. While section 311.0125 does provide that a “taxing unit

other than a school district may enter into a tax abatement agreement with an owner of real or

personalproperty in a reinvestment zone,” TEX. TAX CODE ANN. 3 3 11.0125 (Vernon Supp. 2000),

we believe section 31 I .Ol25 does not apply here for two reasons.

First, section 311.0125’s application, in our opinion, is limited to tax increment financing

reinvestment zones. Unlike chapter 3 12 of the Tax Code dealing specifically and comprehensively

with tax abatement, chapter 3 11, the Tax Increment Financing Act, deals with the financing of

projects in a reinvestment zone, which must be done in accordance with a project and financing plan

6The Oxford English Dictionary defmes the term “owner” as “[o]ne who owns or holds something as his own;

a proprietor; one who has the rightful claim OTtitle to a thing (though he may not be in possession);,” XI OXFORD

ENGLISH DICTIONARY 6 (2d ed. 1989). Black’s Law Dictionary defmes “owner” as “[o]ne who has the right to possess,

use, and convey something; a proprietor.” BLACK’S LAW DICTIONARY 1130 (7th ed. 1999).

‘Brief from Frank J. Garza, San Antonio City Attorney, to Honorable John Comyn, Texas Attorney General

at 8-9 (Aug. 1,200O) (on tile with Opinion Committee).

The Honorable Susan D. Reed - Page 8 (JC-0300)

for the reinvestment zone adopted by the zone’s board of directors with “tax increments”* remitted

by participating taxing units or proceeds of tax increment bonds or notes. See id. $5 3 11.001, .002,

.003,.004,.008,.010,.011,.013,.014,.015(Vemon1992&Supp.2000). AsdescribedbytheTexas

Supreme Court, the statute is “designed to aid . in financing public improvements in blighted or

underdeveloped areas[,]” and “[a]ny increase in ad valorem tax revenues from land within the zone

is then committed to the purchase of property, improvement of approved property, or retirement of

revenue bonds issued to provide funding for the approved projects.” City ofEl Paso v. El Paso

Community College Disk, 729 S.W.2d 296 (Tex. 1986). Section 3 11.0125 authorizes tax abatement

for personal and real property in a reinvestment zone, tax relief that is not otherwise authorized in

tax increment financing reinvestment zones. See TEX. TAX CODE ANN. ch. 3 11 (Vernon 1992 &

Supp. 2000); City ofEl Paso, 729 S.W.2d at 296 (increased real property tax revenues committed

to improvements). Specifically, the statute authorizes a taxing unit, other than a school district, to

enter into tax abatement agreements regardless of whether the taxing unit “deposits or agrees

to deposit any portion of its tax increment into the tax increment fund[,]” TEX. TAX CODE ANN.

4 311.0125(a) (Vernon Supp. 2000); provides that to be effective, agreements to abate taxes on real

property must be approved by the reinvestment zone’s board of directors and any taxing unit that

levies real property taxes in the zone and deposits or has agreed to deposit tax increments into the

zone’s tax increment fund,see id. 3 3 11.0125(b); authorizes the zone’s board of directors to covenant

in connection with bonds or other obligations that the board will not approve real property tax

abatement agreements, see id. 5 311.0125(c); and provides that if a taxing unit enters into a tax

abatement agreement, taxes abated are not to be considered in calculating the unit’s “tax increment”

or the unit’s deposit to the tax increment fund for the reinvestment zone, see id. 5 3 11.0125(d).

Given its context and language, we construe section 3 11 .0125 to authorize tax abatement agreements

only with respect to property in a tax increment financing reinvestment zone. See Jones, 969 S.W.2d

at 432 (legislative intent to be determined from entire act not simply from isolated portions of act);

Baptist Mem ‘IS Geriatric Ctr., 851 S.W.2d at 942 (statutory tax exemptions subject to strict

construction). We do not understand the readjustment zone in question to be the subject of a tax

increment financing plan.

Second, because section 3 11.0125 of the Tax Code is a tax abatement provision rather than

a tax increment financing provision, it does not apply to a readjustment zone under chapter 23 10 of

the Government Code. Like chapter 312 of the Tax Code, chapter 311 applies to a readjustment

zone through section 23 10.407 of the Government Code providing that “[dlesignation of an area as

a readjustment zone is also designation of the area as a reinvestment zone for: (1) tax increment

financing under Chapter 3 11, Tax Code; and (2) tax abatement under Chapter 3 12, Tax Code.” TEX.

GOV’T CODE ANN. 5 2310.407 (Vernon 2000) (emphasis added). Section 2310.407 by its terms

makes a readjustment zone eligible orily for tax increment financing under chapter 3 11; it does not

make such a zone eligible for tax abatement under chapter 311. See id. 5 2310.407 (Vernon Supp.

‘In general, the “tax increments”are taxes derived by a taxing unit from the difference between the appraised

value of all taxable real property located in a reinvestment zone for that year less the appraised value of the property

when the zone was established. See TEX.TAX CODE ANN. $ 311.012 (Vernon 1992). In other words, they are taxes

attributable to the increased value of the real property in the zone presumably due to its development.

The Honorable Susan D. Reed - Page 9 (JC-0300)

2000); RepubZicBankDahs, 691 S.W.2d at 607 (to effect legislative intent, statute to be construed

according to its plain language); Laidlnw Waste Sys., Inc., 904 S.W.2d at 659 (every word of statute

presumed to be used for a purpose, and every word excluded born statute presumed to have been

excluded for a purpose). If the legislature had intended to make a readjustment zone eligible for tax

abatement pursuant to chapter 3 11, it would have so expressly provided as it did with respect to

chapter 312. CO~~U~~TEX.GOV’TCODEANN. 5 2310.407(l) (Vemon2000), with id. § 2310.407(2).

The Honorable Susan D. Reed - Page 10 02-0300)

SUMMARY

Section 312.206(a) of the Tax Code authorizes a

commissioners court to enter into a tax abatement agreement only

with the “owner of taxable real property,” and the owner of a

leasehold interest in tax-exempt real property is not such an “owner

of taxable property.”

Attorney General of Texas

ANDY TAYLOR

First Assistant Attorney General

CLARK KENT ERVIN

Deputy Attorney General - General Counsel

SUSAN D. GUSKY

Chair, Opinion Committee

Sheela Rai

Assistant Attorney General - Opinion Committee