Can a Maryland county turn its regular jail into a 'regional detention center' just by renaming it, to get the shorter 18-month sentencing cap?

Plain-English summary

The Director of Maryland's Department of Correction and Rehabilitation, writing in his former capacity as president of a statewide association of correctional administrators, asked the Attorney General three questions about "regional detention centers" under Article 27, §705 of the Maryland Code: how a county establishes one, whether an existing local jail can be converted into one, and whether any law allowed a judge to sentence someone to more than the statute's 18-month cap. The questions mattered because some Maryland jurisdictions were interested in redesignating their jails as regional centers specifically to take advantage of that 18-month sentencing limit, at a time when some courts were imposing local jail sentences of two to four years or longer. The opinion concluded that a county could establish or redesignate a facility using whatever ordinary procedures that jurisdiction already used to build or repurpose a local detention facility, since the statute did not create special new procedures of its own. But it also concluded that a county could not simply rename its jail to capture the sentencing benefit: reading the term "regional" in light of the statute's structure and its reference to counties being "party to the operation and maintenance" of the facility, the opinion found that a true regional detention center had to actually serve more than one county through some kind of multi-county arrangement, formal or informal. Finally, the opinion confirmed that no statute allowed a judge to commit someone to a regional detention center for more than 18 months of actual confinement, though it clarified that the cap applied to time actually served, not to the sentence originally imposed, and did not limit how long a state prisoner could be housed there under a separate transfer agreement.

Currency note

This opinion was issued in 1983. Subsequent statutory amendments, court decisions, or later AG opinions may have changed the analysis. Treat this page as historical context, not current legal advice. Verify current law before relying on any specific rule, deadline, or remedy mentioned here.

Common questions

Could a Maryland county just rename its jail a "regional detention center" to shorten how long judges could sentence people there?
No, according to this opinion. It concluded that although the statute did not precisely define "regional," reading the term in the context of the whole law showed the General Assembly meant a facility actually serving more than one county under some multi-county agreement, not a single county's jail with a new sign out front.

What kind of agreement did counties need to set up a regional detention center?
The opinion found the statute did not require a written agreement; informal arrangements or even tacit understandings between counties could suffice, so long as each participating county was genuinely a "party to the operation and maintenance" of the facility.

What procedures did a county have to follow to build or redesignate a regional detention center?
The opinion concluded there was no special statutory procedure. A county establishing a new regional center would follow the same process it would normally use to build a local detention facility, and a county redesignating an existing jail would follow whatever procedures that jurisdiction customarily used to change the function of an existing facility, with a county attorney's involvement recommended.

Could a judge ever sentence someone to more than 18 months in a regional detention center?
Not directly. The opinion found the 18-month cap applied to the sentence actually to be executed, so a judge could impose a longer sentence with all but 18 months suspended, and confirmed that separate statutes allowed state prisoners with longer sentences to be housed in regional detention centers by agreement with the Commissioner of Correction, a category the 18-month judicial sentencing cap did not reach.

Background and statutory framework

Article 27, §705 of the Maryland Code defined a "regional detention center" as a facility "operated by one or more counties for the purpose of detention and confinement" (§705A.1, with Baltimore City treated as a county under §705A.2), and authorized the "governing body" of one or more counties to "establish and maintain" such a center and enter written agreements on responsibility, construction, operation, maintenance, and personnel, with the State an optional party (§705B). The opinion surveyed how "governing body" was used elsewhere in Maryland law to conclude it meant the mayor and city council of Baltimore City, the county council of a charter county, or the board of county commissioners of a code or non-charter county, tracing each jurisdiction's authority over detention facilities to its constitutional and statutory home-rule structure (Md. Const. art. XI-A, §3; art. XI-F, §2; Article 25A, §5(C); Article 25B, §§9 and 13; Article 25, §§1, 11A, 128).

On the central redesignation question, the opinion found the statutory text supported converting an existing jail, since §705D.1's reference to a county's determination "to build or maintain a regional detention center" implied facilities that already existed, and the 1968 enabling act's title expressly referenced "facilities now existing which later qualify as Regional Detention Centers" (Chapter 481, Laws of Maryland 1968). But the opinion concluded a facility could not become "regional" through relabeling alone, relying on the rule that statutory terms must be read in their full context (citing Guardian Life Ins. Co. v. Insurance Comm'r) and on the incongruity that would result from a construction letting a county capture the sentencing benefit through "mere nomenclature" (citing Pan American Sulphur Co. v. Dep't of Assessments and Taxation). The opinion found this reading reinforced by the statute's use of both "jail" and "regional detention and correctional center" in the same section (§705D.4) and by §705F's requirement that the sentencing court be located "within a jurisdiction which is a party to the operation and maintenance of the facility," language the opinion read as presupposing more than one county's involvement. On the sentencing question, the opinion traced a 1975 amendment (Chapter 205, Laws of Maryland 1975) that changed the statute's focus from the sentence "imposed" to the sentence "to be then executed," and read that change together with Maryland's suspended-sentence statute (§641A(a)) to conclude the 18-month limit governed actual time served, not the sentence a judge could nominally impose, while separate provisions for housing state prisoners in regional centers by agreement (§705E, §690(e), §700A(c)) were unaffected by that judicial sentencing cap.

Citations

Statutes:

• Md. Code Art. 27, §705, §705A.1, §705A.2, §705B, §705D.1, §705D.4, §705E, §705F (regional detention center establishment, definitions, and 18-month sentencing limit)
• Md. Code Art. 27, §641A(a) (suspension of sentence and probation)
• Md. Code Art. 27, §643A (District Court judge's suspension authority)
• Md. Code Art. 27, §690(b), §690(e) (Division of Correction commitment and inmate transfer)
• Md. Code Art. 27, §700A(c) (work-release housing agreements)
• Md. Code Art. 1, §14 (Baltimore City treated as a county)
• Md. Code Art. 25, §223, §5(c), §1, §11A, §128 (county governing body definitions and property/detention authority)
• Md. Code Art. 25A, §5(C) (charter county power to establish detention facilities)
• Md. Code Art. 25B, §3, §9, §13 (code county governing body and local law authority)
• Md. Code Art. 78D, §§1-3 (Regional Planning Council, multi-county model)
• Md. Const. art. XI-A, §3 (charter county/Baltimore City home rule)
• Md. Const. art. XI-F, §2 (code county home rule)
• Chapter 481, Laws of Maryland 1968 (enacted Article 27, §705)
• Chapter 205, Laws of Maryland 1975 (amended the 18-month sentencing measure to "sentence to be executed")

Cases:

• Guardian Life Ins. Co. v. Insurance Comm'r, 293 Md. 629, 642-43 (1982)
• Pan American Sulphur Co. v. Dep't of Assessments and Taxation, 251 Md. 620, 626-27 (1968)
• Mentus v. Town of Irvington, 191 A.2d 806, 808 (N.J. Super. 1963)
• Humthlett v. Reeves, 90 S.E.2d 14, 18 (Ga. 1955)

Source

• Landing page: https://oag.maryland.gov/resources-info/Pages/attorney-general%E2%80%99s-opinions.aspx
• Original PDF: https://oag.maryland.gov/resources-info/Documents/pdfs/Opinions/1983/Volume68_1983.pdf

Original opinion text

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

CORRECTIONS

Regional Detention Centers, Counties, "Governing Body", Procedures to Establish Regional Centers, Authority to Redesignate Local Facility as Regional Center, Need for Multi-County Arrangement, Effect of Sentencing Limitation.

December 6, 1983

Mr. Gary R. Blake
Director
Department of Correction and Rehabilitation

In your former capacity as President of the Maryland Community Correctional Administrators Association, you requested our opinion concerning the establishment and use of regional detention centers in accordance with Article 27, §705 of the Maryland Code. Specifically, you posed the following questions:

1. How does a county or Baltimore City establish a regional detention center?

2. May facilities that existed prior to the enactment of Article 27, §705 be converted into regional detention centers?

3. Does any law permit a court to sentence an offender to a regional detention center for a period in excess of 18 months, the limit specified in Article 27, §705F?

For the reasons given below, we have concluded as follows:

1. A county may establish a regional detention center, to be operated pursuant to some form of multi-county agreement, by following the procedures otherwise generally applicable in that jurisdiction for (i) the construction of a local detention facility or (ii) the change in use of a local facility.

2. An existing local facility may be redesignated as a regional detention center under an appropriate arrangement between or among the counties that the region comprises.

3. No law permits a judge to commit an offender to a regional detention center for more than 18 months.

I
Background

Article 27, §705 of the Maryland Code governs the establishment of regional detention centers. These centers are defined as "facilities operated by one or more counties for the purpose of detention and confinement". Article 27, §705A.1.1

The statute is quite general in its description of how these centers may be established:

"The governing body of one or more counties may establish and maintain a regional detention center and may enter into a written agreement with each other as to allocation of responsibility, construction, operation, maintenance and appointment of personnel. The State may, but need not be, a party to any such agreement." Article 27, §705B.

The statute then provides for State financial assistance in the following circumstances: "Upon the determination by a county or counties to build or maintain a regional detention center, application may be made to the Commissioner of Corrections for financial assistance for the construction or enlargement of the facility." Article 27, §705D.1.

Another provision limits the terms of sentences in these centers. Article 27, §705F, provides as follows:

"Notwithstanding any other provisions of the Annotated Code of Maryland, a judge of the circuit court for any county or any judge of the District Court may sentence a convicted offender to a regional detention center[,] if the sentence to be then executed is for a period of not more than 18 months and the court imposing the sentence is located within a jurisdiction which is a party to the operation and maintenance of the facility to which the person is sentenced."

1 Baltimore City is a "county" for purposes of this statute. Article 27, §705A.2. See also Article 1, §14.

Your letter states that some courts are sentencing offenders to terms in local jails "for lengthy periods of time (as much as 10 years or more) .... The very lengthy sentences are rare[;] however, sentences of two, three and four years are commonplace in some jurisdictions in the State." Dissatisfied with these sentencing practices, some local jurisdictions have considered establishing regional detention centers in order to avail themselves of the 18-month term limitation in §705F.2

II
Procedure to Establish Regional Detention Centers

A. Meaning of "Governing Body"

Under Article 27, §705B, "[t]he governing body of one or more counties may establish and maintain a regional detention center". The term "governing body" is not defined in the statute.

However, the term has elsewhere been defined. For example, for purposes of park administration, the Code provides as follows:

"The term 'governing body' as used herein means mayor and city council, by whatever name known, of a municipal corporation, board of county commissioners or county council, and shall mean and include Baltimore City." Article 25, §223 of the Maryland Code.

See also, e.g., §§3-201, 3-302(b), and 8-312(a) of the Health-General Article ("governing body" used but undefined); §2-504.1 of the Agriculture Article ("governing body" used but undefined). Cf. Article 66B, §1.00 (distinguishing "local executive" and "local legislative body" for purposes of zoning and planning).

We think that it is reasonable to ascribe a comparable meaning to the identical term in Article 27, §705F, that is, "gov-

2 As we understand it, Montgomery County has already redesignated its local facility as a regional detention center.

erning body" signifies the "mayor and city council, . . . board of county commissioners or county council".3 This meaning best reflects both the general scheme of government in the respective jurisdictions and their specific authority regarding local detention facilities:4

1. For Baltimore City, "the Mayor of Baltimore and City Council of the City of Baltimore . . . shall have full power to enact local laws of said City". Article XI-A, §3 of the Maryland Constitution. More particularly, the Mayor and Council have the power "to establish, maintain and control [City] jails, and

3 As used in §705F, of course, the term applies only to counties and Baltimore City, not to municipal corporations generally. When the bill that contained §705F was introduced, the provision began with the phrase, "The Board of County Commissioner[s] or the County Council of one or more counties may establish . . . ". An amendment changed the wording to, "The governing body of one or more counties may establish . . . ". See Chapter 481, Laws of Maryland 1968. Presumably, this change was made in recognition of the fact that, because the statute was to apply to Baltimore City and charter counties, in which the executive plays a role in the legislative process, a broader term should be used.

The term "governing body" also appears in Article XI-F, §2 of the Maryland Constitution. In that context, it refers to the board of county commissioners only. See Article 25B, §3 of the Maryland Code.

In Article 25, §26A, which sets out a procedure for the establishment of regional councils of government, the phrase "governing body" connotes the legislative branch, as distinct from the executive. See, e.g., §26A(b) ("[t]he representative or representatives from each participating county . . . shall be the elected chief executive of a participating government and/or a member or members of its governing body chosen by such body to be its representatives"). This is a common meaning of the term. See Mentus v. Town of Irvington, 191 A.2d 806, 808 (N.J. Super. 1963). Accord Humthlett v. Reeves, 90 S.E.2d 14, 18 (Ga. 1955). But, with respect to Article 27, §705B, there is no reason to attribute to the General Assembly an intention to somehow exclude the Mayor of Baltimore City or the county executive of a charter county from a decisionmaking process in which they play an integral part. See generally Revisor's Note to §5-416 of the Transportation Article (language granting authority to political subdivisions should be drafted, and, here, construed, "to permit each county, subject to its local law, to adopt its own rules as to the manner of acting under the authority of this section").

4 For a general survey of the forms of county government in Maryland, see Moser, County Home Rule, Sharing the State's Legislative Power with Maryland Counties, 28 Md. L. Rev. 327 (1968). See also 66 Opinions of the Attorney General 197 (1981) (authority of counties organized under the various forms of government to administer and enforce local public ethics laws).

to regulate all persons confined therein". Article 25, §5(c) of the Maryland Code. See also Article II, §13 of the Charter of Baltimore City.

2. For charter counties, that is, counties that have adopted a home rule charter under Article XI-A of the Maryland Constitution, "the County Council of said County . . . shall have full power to enact local laws of said . . . County". Article XI-A, §3.5 Among a charter county's express powers is the power, under Article 25A, §5(C) of the Maryland Code, to establish and maintain detention facilities. See, e.g., Chapter 13 of the Montgomery County Code.

3. For code counties, that is, counties that have adopted the optional powers of home rule under Article XI-F of the Maryland Constitution, the board of county commissioners has authority to enact the public local laws, including laws regarding detention facilities. See Article 25B, §§9 and 13 of the Maryland Code. See generally, e.g., §4-402 of the Worcester County Code.

4. For all other counties, although the power to enact public local laws resides in the General Assembly, the county commissioners "shall have charge of and control over the property owned by the county". Article 25, §1 of the Maryland Code. They may acquire property and erect buildings for public purposes. Article 25, §11A. See also Article 25, §128 (establishment of prison farms).

B. Procedures for Establishing A Regional Detention Center

The statute does not specify any particular procedures that the governing body of a county or Baltimore City must follow to establish a regional detention center. Hence, we must conclude that the General Assembly intended merely to require the use of whatever procedures are normally followed in a given jurisdiction to create a local detention facility. However, though the procedures for creation are the same, a county intending to establish a regional detention center should bear in mind the major difference between such a center and a local

5 Of course, a county charter may permit the county executive to exercise a veto and thus share in the legislative process.

facility: as discussed in Part III B below, it is our view that a regional detention center must serve regional needs through some form of multi-county agreement.

In sum, a county's establishment of a regional detention center by construction of a new facility would be undertaken by the same basic process that the county would use to acquire property and construct a local detention facility. Similarly, the redesignation of an existing local detention facility as a regional detention center, which we discuss in Part III A below, would be accomplished through whatever procedures the jurisdiction customarily follows to redesignate the function of an existing facility. We cannot attempt, in this Opinion, to catalog those procedures for each jurisdiction in the State; instead, we suggest that the county attorney be consulted should establishment of a regional detention center be contemplated.

III
Redesignation of Existing Facilities as Regional Detention Centers

A. Authority for Redesignation

Although Article 27, §705 does not expressly state that local detention facilities may be converted into regional detention centers, the statute is reasonably clear that the General Assembly did intend to permit redesignation.

First, the words "establish and maintain" in Article 27, §705B are as pertinent to the redesignation of a local existing facility as to the construction of a new center. Indeed, the wording of §705D.1 plainly contemplates the possible redesignation of an existing facility as a regional detention center:

"Upon the determination by a county or counties to build or maintain a regional detention center, application may be made to the Commissioner of Correction for financial assistance for the construction or enlargement of the facility."6

6 We think that it is immaterial whether the existing local facility was constructed before or after the date of enactment of §705.

Finally, the title of the Act that added §705 to the Code refers specifically to "facilities now existing which later qualify as Regional Detention Centers". Chapter 481, Laws of Maryland 1968.

B. Prerequisite to Redesignation

To redesignate an existing facility as a regional detention center, may a county simply rename its jail and, without any other change in operation, thereby avail itself of the advantage, the sentencing limit, that the statute grants regional detention centers?7 Although the question is not free from doubt, we think not.

The statutory definition of "regional detention center" does indicate that a single county may operate such a center. Article 27, §705A. See also Article 27, §705B and D. And neither the definition nor any other portion of §705 indicates precisely what geographic area constitutes a "region" or how a regional detention center differs from an ordinary county jail. Thus, there is some basis for the argument that a jail may be transformed into a regional detention center by a change of name alone.

However, it is axiomatic that individual provisions of a statute are "controlled by the[ir] context .... [W]here a particular provision of a statute is part of a single statutory scheme the legislative intent must be gathered from the entire statute rather than from only one part". Guardian Life Ins. Co. v. Insurance Comm'r, 293 Md. 629, 642-43 (1982). Taking into account the statutory context controlling the term "regional detention center", we conclude on balance that a county jail may become a regional detention center only if the operating county enters into some form of agreement with at least one other county under which the facility serves a region, rather than a single county alone.

We begin with the fact that the General Assembly used the terms "regional detention and correctional center" and "jail" separately in this very statute. Article 27, §705D.4. Some difference between the two must have been intended.

7 With respect to the sentencing limit unique to regional detention centers, see Part IV below.

That difference, in our view, lies in the import of the very name "regional detention centers". We think that "regional" was used to signify a service area greater than the local area, i.e., one county, typically served by a jail. Just as the General Assembly established a "Regional Planning Council" to deal with planning and development issues on a multi-county basis [Article 78D, §§1, 2, and 3 of the Maryland Code], so it encouraged the establishment of regional detention centers to deal with the housing of prisoners on a multi-county basis. This reading of the term "regional detention center" seems to us most harmonious with the apparent legislative purpose. See generally 65 Opinions of the Attorney General 385 (1980) (giving meaning to inexactly defined term "State officer" in consonance with legislative intent).

The converse reading, that "regional detention center" may mean a facility operated to serve the correctional needs of one county exclusively, is inconsistent with at least one provision in the statute and leads, in our view, to an incongruous result.

The 18-month sentencing limitation, discussed in more detail in Part IV below, applies if "the court imposing the sentence is located within a jurisdiction which is a party to the operation and maintenance of the facility to which the person is sentenced". We do not see how a county can be a "party to the operation and maintenance" of a regional detention center if no other county is involved. This phrasing implies that a regional detention center is to be operated pursuant to some form of multi-county agreement. See generally 61 Opinions of the Attorney General 24 (1976) (describing a regional detention center for Howard, Carroll, and Frederick Counties).8

Moreover, we cannot attribute to the General Assembly the intention to enact a benefit, the 18-month limitation on sentences, that does not apply to a county facility called a "jail", but that would apply to the same facility operated in exactly the same way, as long as it is simply renamed a "regional detention center". A statutory construction that would result in this triumph of mere nomenclature over substance would be incongruous at best. Such a statutory construction is to be

8 Article 27, §705B suggests, but does not require, that these agreements be written. More informal arrangements, or even tacit understandings, would appear to suffice.

avoided if possible. See Pan American Sulphur Co. v. Dep't of Assessments and Taxation, 251 Md. 620, 626-27 (1968).

If the General Assembly simply intended to forbid judges from sentencing defendants to longer than 18 months in any county facility, of whatever name, that a county chooses to designate for this limitation, it presumably would have said just that. Instead, it applied the sentencing limit to "regional detention centers" only. In our view, the apparent legislative intention would be ill-served if a county were permitted to transform its jail into a regional detention center merely by repainting the sign on the facade.

We readily concede, however, that our attempt to glean an understanding of legislative intent, and to construe the term "regional detention center" accordingly, is far from conclusive on all points. In particular, the statute is silent as to the precise form of the cooperative endeavor that is necessary to the operation of a regional detention center.9 Therefore, we urge the General Assembly to clarify the statute so that the true legislative intent is unmistakable.

IV
Sentencing Limit

Under Article 27, §705F, a judge may sentence an offender to a regional detention center, but only if "the sentence to be then executed is for a period of not more than 18 months". This grant of sentencing authority, and its accompanying limit, applies "[n]otwithstanding any other provisions of the Annotated Code of Maryland". In any event, we have found no other provision that even purports to allow a longer sentence to a regional detention center.

It should be noted, however, that the 18-month sentence limitation is phrased in terms of the execution of the sentence: "[A] judge . . . may sentence a convicted offender to a regional detention center ... if the sentence to be then executed

9 See note 8 above.

is for a period of not more than 18 months". This language differs from that in §705F as originally enacted by Chapter 481, Laws of Maryland 1968. The language then was as follows: "[A] judge . . . may sentence a convicted offender to a Regional Detention Center . . . provided the sentence imposed is for a period of not more than 18 months".

This change in §705F was effected by, and was the express purpose of, Chapter 205, Laws of Maryland 1975. The title of that Act states its purpose, in relevant part, as follows: "F[or] the purpose of repealing the provision that the length of the sentence imposed is a basis for determining that a convicted offender may be sentenced to a regional detention center; [and] providing that the length of the sentence to be executed is a basis for determining that a convicted offender may be sentenced to a regional detention center".

The distinction between sentence imposed and sentence to be executed is important, because the sentencing judge has authority to suspend the execution of a portion of the sentence imposed:

"Upon entering a judgment of conviction, the court having jurisdiction may suspend the imposition or execution of sentence and place the defendant on probation upon such terms and conditions as the court deems proper. The court may impose a sentence for a specified period and provide that a lesser period be served in confinement, suspend the remainder of the sentence and grant probation for a period longer than the sentence but not in excess of five years." Article 27, §641A(a).

See also Article 27, §643A (authority of District Court judge in criminal or motor vehicle case).

Reading the statutory provisions regarding the suspension of sentences in concert with the provisions of §705F, we conclude that, by placing an 18-month limit on the sentence "to be then executed", the General Assembly intended that commitments to regional detention centers be limited to 18 months or less of actual confinement. Accordingly, §705F allows a judge to sentence an offender to a regional detention center if the offender is given a sentence of longer than 18 months, with all but 18 months suspended.

In addition, the 18-month limit on sentence length in §705F applies only to commitments by judges. We do not read §705F as a flat prohibition against the incarceration of an offender with a sentence of more than 18 months in a regional detention center. Indeed, §705E provides that State prisoners may be housed in regional detention centers pursuant to agreement between the Commissioner of Correction and the jurisdictions administering the regional detention center. See 62 Opinions of the Attorney General 829, 834 (1977). Nothing in §705 imposes any limit, as to length of sentence or otherwise, on the category of State prisoners that may, by agreement, be housed in regional detention centers. Similarly, State inmates with sentences of more than 18 months actual confinement may be transferred to regional detention centers pursuant to the provisions of Article 27, §690(e) or §700A(c).10

Obviously, these provisions do not require the jurisdictions operating a regional detention center to accept prisoners with unsuspended sentences of more than 18 months. But neither does Article 27, §705F forbid the incarceration of such prisoners by agreement.11

10 Section 690(e) provides that: "The Commissioner of Correction may transfer minimum security inmates to county or Baltimore City detention facilities for participation in community-oriented correctional programs by mutual agreement with Baltimore City or the counties involved."

Section 700A(c) provides that: "The Department shall designate and adopt facilities in the institutions and camps under its jurisdiction for the housing of prisoners granted 'work release' privileges. In areas where such facilities are not within reasonable proximity to the place of employment of a prisoner so released, the Department may contract with the proper authorities of political subdivisions of this State for the quartering of such prisoner in suitable local confinement facilities."

11 We note that the original commitment in such cases would be to the jurisdiction of the Division of Correction. Article 27, §690(b). Actual service of the sentence in a regional detention center would result from the appropriate agreement.

V
Conclusion

In summary, it is our opinion that:

1. A county may establish a regional detention center pursuant to Article 27, §705 of the Maryland Code, to be operated pursuant to some form of multi-county agreement, by following the procedures otherwise generally applicable in that jurisdiction for (i) the construction of a local detention facility or (ii) the change in use of a local facility.

2. An existing local detention facility may be redesignated as a regional detention center under an appropriate arrangement between or among the counties that the region comprises.

3. No law permits a judge to commit an offender to a regional detention center for more than 18 months.

Stephen H. Sachs, Attorney General
Jack Schwartz, Assistant Counsel, Opinions and Advice
Alan D. Eason, Assistant Attorney General
Avery Aisenstark, Principal Counsel, Opinions and Advice.