Can a Louisiana parish registrar of voters also serve on the board of a parish communications district (911 board)?

Plain-English summary

A Sabine Parish resident asked whether the Sabine Parish Registrar of Voters could also serve on the board of commissioners for the Sabine Parish Communications District (the parish's 911/emergency communications board). The AG said no.

Under the general Dual Officeholding and Dual Employment Law, this combination would likely have been fine. The registrar of voters is a full-time appointive office (appointed by the parish governing authority under La. R.S. 18:51, working the standard forty-hour week). The Communications District board seat is only part-time, roughly one hour of work per week for its seven appointed commissioners. La. R.S. 42:63(E) only bars combining two full-time appointive offices; it does not stop a full-time appointive officeholder from also holding a part-time appointive office. Under that general rule alone, the registrar could serve on both.

But a different, more specific statute overrides that general analysis. La. R.S. 18:63, part of the Louisiana Election Code, flatly states that a registrar, deputy registrar, or employee of a registrar "shall not be eligible to hold any elective or appointive public office or position with the United States or the state or any of its agencies or political subdivisions, except as otherwise specifically provided by law." That is an absolute bar with no part-time/full-time distinction, and it applies regardless of how few hours the second position requires. The AG's opinion also points to a prior opinion reaching the same conclusion when a registrar sought appointment to the State Mineral Board, concluding the registrar would have to resign before accepting.

What this means for you

Parish registrars of voters. Under this opinion, you cannot simultaneously hold any other elective or appointive public office or position, not just full-time ones. That includes low-hour, low-pay board seats like a communications district commissioner. If you want to accept such an appointment, you would need to resign as registrar first (or the Election Code would need to change).

Communications district boards and parish police juries making appointments. Before appointing or reappointing someone to a district board, confirm they are not currently serving as a parish registrar of voters (or a registrar's deputy or employee), since the Election Code bars that combination outright, independent of the board seat's hours or pay.

Anyone comparing this to the St. Landry housing authority/hospital board opinion (25-0058) issued around the same time. That opinion allowed combining two part-time appointive offices because no specific statute barred it. This opinion reaches the opposite result for a superficially similar fact pattern (full-time office plus a low-hour board seat) because a specific Election Code provision, not the general Dual Officeholding Law, controls here.

Common questions

Q: Does the part-time nature of the Communications District board seat matter at all?
A: Not for this specific combination. La. R.S. 18:63 does not distinguish between full-time and part-time offices; it bars a registrar from holding any other elective or appointive public office or position, period.

Q: Are there any exceptions to the registrar restriction?
A: La. R.S. 18:63 itself says "except as otherwise specifically provided by law," meaning some other statute could carve out an exception for a particular position, but the opinion does not identify one covering communications district boards.

Q: What happened the last time this office looked at a similar registrar dual-office question?
A: The opinion cites a prior opinion (La. Atty. Gen. Op. No. 01-0008) involving a registrar seeking appointment to the State Mineral Board, which concluded the registrar would need to resign the registrar position before accepting the second appointment. This opinion reaches the same conclusion for the Communications District seat.

Background and statutory framework

The registrar of voters office. Under La. R.S. 18:51, every Louisiana parish must have a registrar of voters, appointed by the parish's governing authority. The Sabine Parish Registrar normally works forty hours over five days, making the position a full-time appointive office under La. R.S. 42:62(2) and (4).

The Sabine Parish Communications District. Created by the Sabine Parish Police Jury under its home-rule ordinance authority (La. R.S. 33:1361) and the specific communications district statute (La. R.S. 33:9101 et seq.), governed by a seven-member board of appointed commissioners who work about one hour per week, a part-time appointive office under La. R.S. 42:62(5).

The general Dual Officeholding rule, and why it would not have blocked this combination. La. R.S. 42:63(E) bars a person from holding a full-time appointive office while also holding another full-time appointive office or full-time employment. It does not prohibit a full-time officeholder from also holding a part-time appointive office in the same or a different political subdivision, per the prior opinion cited here (La. Atty. Gen. Op. No. 12-0031).

The specific Election Code override. La. R.S. 18:63 imposes an absolute bar unique to registrars, deputy registrars, and their employees, prohibiting them from holding any other elective or appointive public office or position, without regard to hours or compensation. Because this is a specific statute targeting registrars, it controls over the more permissive general Dual Officeholding analysis.

Liz Murrill is the Attorney General of Louisiana. Harley Freiler signed the opinion as Assistant Attorney General.

Citations and references

Statutes:
- La. R.S. 42:61 et seq. (Dual Officeholding and Dual Employment Law generally)
- La. R.S. 42:62(2) (definition of "appointive office")
- La. R.S. 42:62(4) (definition of "full time")
- La. R.S. 42:62(5) (definition of "part time")
- La. R.S. 42:63(E) (bar on combining two full-time appointive offices)
- La. R.S. 18:51 (parish registrar of voters appointment)
- La. R.S. 18:63 (registrar barred from holding any other elective or appointive office)
- La. R.S. 33:1361 (municipal/parish authority to adopt a code of ordinances)
- La. R.S. 33:9101 et seq. (parish communications district creation)

Prior AG opinions referenced:
- La. Atty. Gen. Op. No. 12-0031 (full-time appointive officeholder may also hold a part-time appointive office in the same political subdivision)
- La. Atty. Gen. Op. No. 01-0008 (registrar of voters barred from State Mineral Board appointment absent resignation)

Source

• Landing page: https://www.ag.state.la.us/Opinions
• Original PDF: https://www.ag.state.la.us/Opinion/Download/25-0081

Original opinion text

Best-effort transcription from a scanned PDF. Minor errors may remain, the linked PDF is authoritative.

STATE OF LOUISIANA
DEPARTMENT OF JUSTICE
OFFICE OF THE ATTORNEY GENERAL
P.O. Box 94005
BATON ROUGE, LA 70804-9005

LIZ MURRILL
ATTORNEY GENERAL

July 22, 2025

OPINION 25-0081

78 - DUAL OFFICEHOLDING
La. R.S. 42:61 et seq.

Mr. Zachery Faircloth
400 S. Capitol St., #107
[city illegible in source scan], LA 71440

A specific provision of the Louisiana Election Code, La. R.S. 18:63, expressly forbids the registrar of voters for Sabine Parish from accepting appointment to the Sabine Parish Communications District.

Dear Mr. Faircloth:

Our office received your request for an opinion regarding whether the Sabine Parish Registrar of Voters can serve on the board of commissioners for the Sabine Parish Communications District.

Question: Can the Sabine Parish Registrar of Voters serve on the board of commissioners for the Sabine Parish Communications District?

Conclusion: No. A specific provision of the Louisiana Election Code, La. R.S. 18:63, expressly forbids the registrar of voters from holding the position of commissioner of the Sabine Parish Communications District.

The provisions of the Dual Officeholding and Dual Employment Law, found at La. R.S. 42:61 et seq., generally govern questions concerning the ability to hold two or more public offices and/or positions simultaneously. Classifying the correct nature of the positions held is essential for the purposes of applying the Dual Officeholding and Dual Employment Law.

According to La. R.S. 18:51, each parish in the state is required to have a registrar of voters, who shall be appointed by the governing authority of the parish. In your request, you assert that the Sabine Parish Registrar of Voters normally works forty hours per week in five work days. Therefore, the Sabine Parish Registrar of Voters is considered to hold a "full time" "appointive office" for the purposes of the Dual Officeholding Law.

Louisiana Revised Statute 33:1361 gives all municipalities or parish governing authorities the right to adopt a code embracing all of the laws which they have enacted. Accordingly, Sabine Parish Police Jury constructed the Sabine Parish Police Jury Code. Pursuant to the authority vested by La. R.S. 33:9101, et seq., the police jury created a communications district for Sabine Parish. The governing authority of the communications district consists of a board of commissioners composed of seven members, who are appointed. As detailed in your request, a board member normally works about one hour per week. Therefore, the Sabine Parish Registrar of Voters is considered to hold a "part time" "appointive office" for the purposes of the Dual Officeholding Law.

The Dual Officeholding and Dual Employment Law is La. R.S. 42:63(E), provides:

No person holding a full-time appointive office or full-time employment in the government of this state or of a political subdivision thereof shall at the same time hold another full-time appointive office or full-time employment in the government of the state of Louisiana, in the government of a political subdivision thereof, or in a combination of these.

La. R.S. 42:63(E) would not ordinarily prohibit a full-time appointed official of a political subdivision from serving simultaneously as a part time appointed official in the same political subdivision. However, a specific provision of the Louisiana Elections Code, La. R.S. 18:63, prohibits registrars of voters from simultaneously holding appointive public office in the following terms:

A registrar, deputy registrar, or employee of a registrar shall not be eligible to hold any elective or appointive public office or position with the United States or the state or any of its agencies or political subdivisions, except as otherwise specifically provided by law.

A prior opinion issued by this office dealt with a substantially similar question and concluded that a registrar of voters is prohibited from simultaneously holding a second office while serving as registrar. In response to an opinion request, this office concluded that, in light of the statute, a registrar would be compelled to resign his position as registrar before accepting an appointment to the State Mineral Board.

Based on the applicable provisions of law and the information you have provided, it is the opinion of this office that the provisions of La. R.S. 18:63 expressly prohibit the Sabine Parish Registrar of Voters from being appointed to the board of commissioners for the Sabine Parish Communications District.

Please note that our expressed opinion relative to state law is limited to an examination of the Dual Officeholding and Dual Employment provisions. It does not address the potential applicability of the State of Louisiana civil service laws, rules and regulations. Further, it does not address the potential applicability of the provisions of the Louisiana Code of Governmental Ethics, La. R.S. 42:1111, et seq. Advisory rulings addressing questions under the Ethics Code are within the jurisdiction of the Louisiana State Board of Ethics. The Board may be contacted at the following address: P.O. Box 4368, Baton Rouge, LA 70821, phone: 225-219-5600.

We hope that this opinion adequately addresses the legal issues you have raised. If our office can be of any further assistance, please do not hesitate to contact us.

With best regards,

LIZ MURRILL
ATTORNEY GENERAL

BY:
Harley Freiler
Assistant Attorney General

LM: HF

Footnotes referenced in the opinion:

1. "Full time" means the period of time which a person normally works or is expected to work in an appointive office or employment and which is at least seven hours per day of work and at least thirty-five hours per week of work. La. R.S. 42:62(4).
2. "Appointive office" means any office in any branch of government or other position on an agency, board, or commission or any executive office of any agency, board, commission, or department which is specifically established or specifically authorized by the constitution or laws of this state or by the charter or ordinances of any political subdivision thereof and which is filled by appointment or election by an elected or appointed public official or by a governmental body composed of such officials of this state or of a political subdivision thereof. La. R.S. 42:62(2).
3. Sec. 1-1, Sabine Parish Police Jury Code.
4. Sec. 44-118, Sabine Parish Police Jury Code.
5. "Part time" means the period of time which a person normally works or is expected to work in an appointive office or employment which is less than the number of hours of work defined in this Section as full time. La. R.S. 42:62(5).
6. See La. Atty. Gen. Op. No. 12-0031.
7. See La. Atty. Gen. Op. No. 01-0008.