Under a Texas group health plan, can an individual employee reject in vitro fertilization coverage, or only the employer?

Texas AG Opinion JM-937: Who Controls IVF Insurance Coverage?

Plain-English summary

In 1987 the Texas Legislature told certain group health plans they had to offer coverage for in vitro fertilization, the procedure of fertilizing an egg outside the body. Senator Chet Brooks, who chaired the Senate's health committee, asked the Attorney General a series of questions about exactly how the new requirement worked. This 1988 opinion answers two of the most practical ones: who gets to say yes or no to the coverage, and whether the requirement reaches an out-of-state company that employs Texans.

First, the shape of the mandate. It is narrower than it sounds. A plan only has to offer IVF coverage if it already covers pregnancy in the first place. When it does apply, the IVF coverage need only match the plan's other pregnancy benefits, and it can be limited to patients who meet a list of conditions: the sperm must be the spouse's, the couple must have a five-year history of infertility or one of several listed medical conditions, they must already have tried cheaper covered treatments without success, and the procedure must be done at a clinic meeting recognized medical standards. On top of that, an insurer or employer that is part of a religious denomination that considers IVF contrary to its beliefs is exempt entirely.

So an employer had two ways out of the requirement: drop pregnancy coverage altogether, or qualify for the religious exemption. The Attorney General added an important caution, though. A federal law, the Pregnancy Discrimination Act, generally bars an employer from singling out pregnancy for worse treatment than other conditions. So an employer covered by that federal law who tried to escape the IVF mandate by cutting pregnancy-related fringe benefits would also have to cut the fringe benefits for other medical conditions. You cannot carve pregnancy out by itself.

Now the two questions the opinion focused on.

Question one: when a group plan lets the coverage be rejected, who holds that right, the employer or the individual employee? The Attorney General's answer was the employer. Under the Insurance Code, the employer that buys the group policy is the "policyholder." The employees are beneficiaries who receive a certificate of insurance, not the policy itself. The IVF statute says the offer of coverage must be made to the policyholder, and the policyholder is the one who may reject it, in writing. Nothing in the law gives an individual employee a separate right to reject a piece of the group coverage. So the decision belongs to the employer, not the worker.

Question two: what about a company headquartered outside Texas that employs Texans? Does the Texas IVF requirement apply to its group policy? Here the Attorney General had to work through a change in the law. Article 21.42 of the Insurance Code says a contract of insurance payable to a Texas resident by a company doing business in Texas is governed by Texas insurance law, even if the policy says otherwise. So if the insurer is doing business in Texas, the IVF requirement applies to the out-of-state employer's policy covering Texas employees. The harder case is an insurer that is not otherwise doing business in Texas. Older cases said policies like that were governed by the law of the state where the policy was issued, not by Texas law. But Texas choice-of-law doctrine has since changed completely. In 1984 the Texas Supreme Court dropped the old "place of the contract" rule and adopted the "most significant relationship" test, applying the law of the state with the closest connection to the issue. Given that shift, the Attorney General concluded a court would probably apply Texas insurance law, including the IVF requirement, even to an out-of-state insurer's policy covering Texas employees.

Currency note

This opinion was issued in 1988. 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.

The Insurance Code has been recodified since 1988, and the article numbers used here (3.51-6, 21.42, 1.14-1) have largely moved into the current Insurance Code. The IVF coverage mandate, the pregnancy-coverage trigger, the eligibility conditions, and the religious exemption may all read differently today, and federal law and ERISA preemption add further wrinkles for self-funded employer plans. The choice-of-law analysis reflects Texas law as of 1988. Anyone dealing with fertility-treatment coverage now should rely on the current Insurance Code, current federal law, and current case law rather than the provisions cited here.

Who this opinion affected (as of 1988)

Employers offering group health plans: The opinion told them the right to accept or reject IVF coverage belonged to them as the policyholder, and warned that using a pregnancy-benefit cut to dodge the mandate could trigger federal Pregnancy Discrimination Act problems.

Employees and their spouses: The opinion clarified that an individual covered under a group plan has no separate right to reject the IVF coverage; that decision rests with the employer.

Insurers, including out-of-state carriers: The opinion signaled that Texas's IVF requirement would likely apply to policies covering Texas employees even when the employer is out of state and the insurer is not otherwise doing business in Texas, given the modern choice-of-law test.

Common questions

Who decides whether a group plan keeps in vitro fertilization coverage, the employer or the employee?
The employer. The Attorney General concluded the employer is the "policyholder" with the right to reject the coverage in writing, and an individual employee covered under the group plan has no separate right to reject it.

Does the Texas IVF mandate apply to every group health plan?
No. It applies only if the plan already provides pregnancy-related benefits, and even then the IVF coverage need only match the plan's other pregnancy benefits and can be limited to patients meeting specific eligibility conditions.

Can an employer just drop the coverage?
An employer can avoid the requirement by ending all pregnancy-related coverage or by qualifying for the religious exemption. But under the federal Pregnancy Discrimination Act, an employer generally cannot single out pregnancy benefits, so dropping them may require dropping other fringe benefits too.

Does the requirement reach a company headquartered outside Texas that employs Texans?
Probably yes. If the insurer is doing business in Texas, article 21.42 applies directly. And even where the insurer is not otherwise doing business in Texas, the Attorney General concluded a court would probably apply Texas insurance law under the modern most-significant-relationship choice-of-law test.

Background and statutory framework

The 70th Legislature amended the Insurance Code (Acts 1987, 70th Leg., ch. 526) to require, effective September 1, 1987 and applicable to policies delivered or renewed after January 1, 1988, that covered insurers, nonprofit hospital and medical service plans, HMOs, and self-funded or self-insured welfare or benefit plans offer group policyholders coverage for outpatient expenses arising from in vitro fertilization, if the plan otherwise provides pregnancy-related benefits (Insurance Code article 3.51-6, section 3A(a)). A rejection of the offer must be in writing (section 3A(c)); IVF benefits must be provided to the same extent as other pregnancy-related procedures (section 3A(d)); and the offer is required only when the patient is covered under the plan, the fertilization uses the patient's spouse's sperm, the patient and spouse have at least five continuous years of infertility or one of several listed conditions (endometriosis, in utero DES exposure, blockage or surgical removal of one or both fallopian tubes, or oligospermia), less costly covered treatments have failed, and the procedure is performed at a facility conforming to recognized standards (section 3A(e)). An insurer, HMO, or self-insuring employer directly affiliated with a bona fide religious denomination that considers IVF contrary to its essential beliefs is exempt (section 3A(f)).

A group policyholder may thus avoid the requirement by ending coverage for any pregnancy-related condition or by meeting the religious exemption. But the federal Pregnancy Discrimination Act of 1978 (42 U.S.C. section 2000e(k)) requires that employees or their insured spouses disabled by pregnancy-related conditions receive the same benefits as others for all employment-related purposes, including fringe benefit programs (Newport News Shipbuilding and Drydock Co. v. EEOC, 462 U.S. 669 (1983); Attorney General Opinion JM-337 (1985)). So an employer subject to the federal law who ends pregnancy-related fringe benefits to avoid IVF coverage must also end fringe benefit plans covering other medical conditions.

On the first question, the Insurance Code requires group accident and health policies to be issued to the "policyholder" (Insurance Code article 3.51-6, section 1(a)), such as an employer deemed the policyholder insuring its employees, while beneficiaries under group policies receive a "certificate of insurance," not a policy. Section 3A identifies the policyholder as the entity to which the IVF offer must be made and the one that may reject the offer in writing (section 3A(a)-(c)); nothing provides that individuals who are merely beneficiaries under a policy issued to their employer have any right to reject that element of the group coverage.

On the second question, article 21.42 of the Insurance Code provides that any contract of insurance payable to a Texas citizen or inhabitant by an insurance company doing business in the state is held to be a Texas contract governed by Texas insurance law, notwithstanding a contrary provision. Article 1.14-1 defines the transactions constituting "doing an insurance business" in Texas, and whether a company is doing business here is a question of fact. If an insurer doing business in Texas issues a group policy to an out-of-state employer for the benefit of its Texas employees, article 21.42 applies and article 3.51-6's IVF requirement governs (John Hancock Mutual Life Ins. Co. v. Schroeder, 349 F.2d 406 (5th Cir. 1965); General American Life Ins. Co. v. Rodriguez, 641 S.W.2d 264 (Tex. App. - Houston [14th Dist.] 1982, no writ); Locomotive Eng. & Cond. Mut. Prot. Ass'n v. Bush, 576 S.W.2d 887 (Tex. Civ. App. - Tyler 1979, no writ); cf. Howell v. American Live Stock Ins. Co., 483 F.2d 1354 (5th Cir. 1973); Austin Building Company v. National Union Fire Ins. Co., 432 S.W.2d 697 (Tex. 1968)).

Older cases held that group policies issued to an out-of-state employer for Texas employees by insurers not otherwise doing business in Texas were governed by the law of the place of issuance, not the Insurance Code (Boseman v. Connecticut General Life Ins. Co., 301 U.S. 196 (1937) (interpreting former article 5054, V.T.C.S., now article 21.42); Metropolitan Life Insurance Co. v. Wann, 109 S.W.2d 470 (Tex. 1937)). But Texas choice-of-law has changed completely since Boseman. Boseman applied the traditional lex loci contractus / place-of-performance rule, but in 1984 the Texas Supreme Court abandoned that rule and held that, absent a valid contractual choice-of-law clause, the law of the state with the most significant relationship to the particular substantive issue applies (Duncan v. Cessna Aircraft Co., 665 S.W.2d 414 (Tex. 1984), following the Restatement (Second) of Conflict of Laws section 6). In light of Duncan, the Attorney General concluded that even where an insurer is not doing business in Texas but issues a policy covering Texas employees, a court would probably apply Texas insurance law and its IVF coverage requirement.

Citations

Statutory authority:

• Article 3.51-6, Insurance Code (group accident and health insurance; section 3A in vitro fertilization coverage requirement)
• Article 21.42, Insurance Code (contracts payable to Texas residents by companies doing business here are governed by Texas law)
• Article 1.14-1, Insurance Code (transactions constituting "doing an insurance business" in Texas)
• Chapter 20, Insurance Code (insurers and plans subject to the IVF requirement)
• 42 U.S.C. § 2000e(k) (federal Pregnancy Discrimination Act of 1978)

Cases:

• Newport News Shipbuilding and Drydock Co. v. EEOC, 462 U.S. 669 (1983) (U.S. Supreme Court; Pregnancy Discrimination Act and fringe benefits)
• John Hancock Mutual Life Ins. Co. v. Schroeder, 349 F.2d 406 (5th Cir. 1965) (federal appellate court; Texas law governs policy covering Texas insured)
• General American Life Ins. Co. v. Rodriguez, 641 S.W.2d 264 (Tex. App. - Houston [14th Dist.] 1982, no writ) (Texas appellate court; application of article 21.42)
• Locomotive Eng. & Cond. Mut. Prot. Ass'n v. Bush, 576 S.W.2d 887 (Tex. Civ. App. - Tyler 1979, no writ) (Texas appellate court; application of article 21.42)
• Howell v. American Live Stock Ins. Co., 483 F.2d 1354 (5th Cir. 1973) (federal appellate court; insurance choice of law)
• Austin Building Company v. National Union Fire Ins. Co., 432 S.W.2d 697 (Tex. 1968) (Texas Supreme Court; insurance choice of law)
• Boseman v. Connecticut General Life Ins. Co., 301 U.S. 196 (1937) (U.S. Supreme Court; former article 5054 and place-of-issuance rule)
• Metropolitan Life Insurance Co. v. Wann, 109 S.W.2d 470 (Tex. 1937) (Texas Supreme Court; place-of-issuance rule)
• Duncan v. Cessna Aircraft Co., 665 S.W.2d 414 (Tex. 1984) (Texas Supreme Court; adopting the most-significant-relationship choice-of-law test)

Prior Attorney General materials referenced: JM-337 (1985).

Source

• Landing page: https://www.texasattorneygeneral.gov/opinions/jim-mattox/jm-937
• Original PDF: https://www.texasattorneygeneral.gov/sites/default/files/opinion-files/opinion/1988/jm0937.pdf

Original opinion text

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

August 2, 1988

Honorable Chet Brooks
Chairman
Committee on Health and Human Services
Texas State Senate
P. O. Box 12068
Austin, Texas 78711-2068

Opinion No. JM-937

Re: Insurance coverage for in vitro fertilization (RQ-1334)

Dear Senator Brooks:

You ask our opinion on a number of questions concerning a requirement imposed by the legislature that certain group health insurance policies provide coverage for in vitro fertilization procedures, or reproduction through fertilization of an ovum by a sperm outside of the body. Annas and Elias, In Vitro Fertilization and Embryo Transfer: Medicolegal Aspects of a New Technique to Create a Family, 17 Family L.J. 199 at n. 1 (1983). After describing the legislation, we will answer each of your questions in turn.

The 70th Legislature amended the Insurance Code to mandate health insurance coverage for in vitro fertilization procedures in certain circumstances. Acts 1987, 70th Leg., ch. 526, at 2135. The legislation was effective on September 1, 1987, and applies to all policies and other evidence of coverage delivered, issued for delivery, or renewed after January 1, 1988. Id. The text of the statute follows.

[In vitro fertilization procedure]

Sec. 3A. (a) All insurers, nonprofit hospital and medical service plan corporations subject to Chapter 20 of this code, health maintenance organizations subject to the Texas Health Maintenance Organization Act (Chapter 20A, Vernon's Texas Insurance Code), and all employer, multiple-employer, union, association, trustee, or other self-funded or self-insured welfare or benefit plans, programs, or arrangements that either issue group health insurance policies, enter into health care service contracts or plans, or provide for group health benefits, coverage, or services in this state for hospital, medical or surgical expenses incurred as a result of accident or sickness shall offer and make available to each group policyholder, contract holder, employer, multiple-employer, union, association, or trustee under a group policy, contract, plan, program, or arrangement that provides hospital, surgical, and medical benefits, coverage for services and benefits on an expense incurred, service, or prepaid basis for out-patient expenses that may arise from in vitro fertilization procedures, if the group insurance policy, contract, plan, program, or arrangement otherwise provides pregnancy-related benefits for the insureds, enrollees, subscribers, employees, members, or other persons covered under the policy, contract, plan, program, or arrangement.

(b) An offer made under Subsection (a) of this section is subject to this section.

(c) A rejection of an offer to provide the coverage for services or benefits provided by Subsection (a) of this section must be in writing.

(d) Benefits for in vitro fertilization procedures must be provided to the same extent as the benefits provided for other pregnancy-related procedures under the policy, contract, plan, program, or arrangement.

(e) The offer to make the coverage available is required only under the following conditions:

(1) the patient for the in vitro fertilization procedure is an insured, enrollee, subscriber, member, or otherwise covered employee or person under the policy, contract, plan, program, or arrangement;

(2) the fertilization or attempt at fertilization of the patient's oocytes is made only with the patient's spouse's sperm;

(3) the patient and the patient's spouse have a history of infertility of at least five continuous years' duration or the infertility is associated with one or more of the following conditions:

(A) endometriosis;

(B) exposure in utero to diethylstilbestrol (DES);

(C) blockage of or surgical removal of one or both fallopian tubes; or

(D) oligospermia;

(4) the patient has been unable to attain a successful pregnancy through any less costly applicable infertility treatments for which coverage is available under the policy, contract, plan, program, or arrangement; and

(5) the in vitro fertilization procedures are performed at a medical facility that conforms to the American College of Obstetric and Gynecology guidelines for in vitro fertilization clinics or to the American Fertility Society minimal standards for programs of in vitro fertilization.

(f) An insurer, health maintenance organization, or self-insuring employer that is owned by or that is part of an entity, group, or order that is directly affiliated with a bona fide religious denomination that includes as an integral part of its beliefs and practices that in vitro fertilization is contrary to moral principles that the religious denomination considers to be an essential part of its beliefs is exempt from this section's requirement to offer coverage for in vitro fertilization.

Ins. Code art. 3.51-6, section 3A.

Several salient points should be noted in this statute. First, coverage for in vitro fertilization procedures is mandated only if the insurance policy also provides pregnancy-related benefits. Art. 3.51-6, section 3A(a). Second, coverage in such instances need be made available only to the same extent that coverage is provided for pregnancy-related procedures. Id. section 3A(d). Third, benefits for in vitro fertilization procedures may be limited to persons who have specified pre-existing medical conditions. Id. section 3A(e). Finally, benefit providers and policyholders "directly affiliated with a bona fide religious denomination that includes as an integral part of its beliefs and practices that in vitro fertilization is contrary to the moral principles that the religious denomination considers to be an essential part of its beliefs" are exempt from the requirement to offer coverage for in vitro fertilization. Id. section 3A(f).

Thus, a group policyholder may avoid the requirement to provide coverage for in vitro fertilization procedures by either ending coverage for any pregnancy-related condition or meeting the test for a religious exemption. [Footnote 2: We note that a policyholder who is entitled to an exemption on religious grounds from the requirement to provide coverage for in vitro fertilization procedures may continue to provide coverage for pregnancy-related conditions, while a policyholder unable to obtain such an exemption on religious grounds must terminate coverage for all pregnancy-related conditions before lawfully refusing coverage for in vitro fertilization procedures. We express no opinion on the constitutionality of this provision.]

We caution that the federal Pregnancy Discrimination Act of 1978, 42 U.S.C. section 2000e(k), requires that employees or their insured spouses disabled due to pregnancy-related medical conditions must be provided the same benefits as those furnished to other workers and their spouses for "all employment-related purposes, including receipt of benefits under fringe benefit programs . . . ." Id. See also Newport News Shipbuilding and Drydock Co. v. EEOC, 462 U.S. 669 (1983) and Attorney General Opinion JM-337 (1985). Thus, if an employer subject to the federal law terminates fringe benefit payments applicable to pregnancy-related conditions to avoid coverage for in vitro fertilization procedures, then the employer also must end fringe benefit plans covering other medical conditions.

I.

You first ask:

Under article 3.51-6, section 3A of the Insurance Code, does the group policyholder or the individual employee covered under the group policy have the right to reject coverage for in vitro fertilization?

The Insurance Code requires that group accident and health insurance policies be issued to those who are denominated by the code as the "policyholder." Ins. Code art. 3.51-6, section 1(a)(1)-(6). See, e.g., art. 3.51-6, section 1(a)(1) ("policy issued to an employer . . . who shall be deemed the policyholder, insuring employees of such employer for the benefit of persons other than the employer."). Beneficiaries under group insurance policies are issued a "certificate of insurance," and not a "policy." Ins. Code art. 3.51-6, section 1(a).

Likewise, section 3A of the code which mandates coverage for in vitro fertilization clearly identifies the policyholder as the entity to which an offer for coverage for in vitro fertilization must be made. Ins. Code art. 3.51-6, section 3A(a), (b). The policyholder may reject the offer of coverage and such rejection must be in writing. Id. at section 3A(c). Nowhere is it provided that individuals who are merely the beneficiaries under a policy of insurance issued to their employer have any right to reject such element of the group insurance coverage.

II.

You next ask:

If an insurer issues a group policy to a company whose headquarters are domiciled outside Texas but the group policy covers Texas-based employees, is the insurer required to offer coverage for in vitro fertilization to [the] Texas employees?

and

If the group policyholder has the right to reject coverage under section 3.51-6, section 3A of the Insurance Code, does the company whose headquarters are domiciled outside of Texas have the right to reject coverage for in vitro fertilization on behalf of its Texas employees?

Article 21.42 of the Insurance Code provides that:

Any contract of insurance payable to any citizen or inhabitant of this State by any insurance company or corporation doing business within this State shall be held to be a contract made and entered into under and by virtue of the laws of this State relating to insurance, and governed thereby, notwithstanding such policy or contract of insurance may provide that the contract was executed and the premiums and policy (in case it becomes a demand) should be made payable without this State, or at the home office of the company or corporation issuing the same.

Ins. Code art. 21.42.

Article 1.14-1 of the Insurance Code sets forth the transactions which constitute "doing an insurance business in this state." Ins. Code art. 1.14-1, section 2(a). Whether an insurance company is doing business in Texas is a question of fact. Id.

If an insurance company doing business in Texas issues a group insurance policy to an out-of-state employer for the benefit of its employees in Texas, article 21.42 applies, and the provisions in article 3.51-6 relating to mandatory coverage for in vitro fertilization procedures govern the policy. John Hancock Mutual Life Ins. Co. v. Schroeder, 349 F.2d 406 (5th Cir. 1965); General American Life Ins. Co. v. Rodriguez, 641 S.W.2d 264 (Tex. App. - Houston [14th Dist.] 1982, no writ); Locomotive Eng. & Cond. Mut. Prot. Ass'n v. Bush, 576 S.W.2d 887 (Tex. Civ. App. - Tyler 1979, no writ). Cf. Howell v. American Live Stock Ins. Co., 483 F.2d 1354 (5th Cir. 1973) and Austin Building Company v. National Union Fire Ins. Co., 432 S.W.2d 697 (Tex. 1968). See generally Cox, Group Insurance Contracts for Employees, 38 Tex. L. Rev. 211, 230 (1959).

But the courts have held that group insurance policies issued to an employer domiciled outside the state for the benefit of its employees in Texas by insurers not otherwise "doing business" in the state are governed by the law of the place where the policy is issued, and not by the Insurance Code. Boseman v. Connecticut General Life Ins. Co., 301 U.S. 196 (1937) (interpreting former article 5054, V.T.C.S., now article 21.42 of the Insurance Code); Schroeder, supra; Metropolitan Life Insurance Co. v. Wann, 109 S.W.2d 470 (Tex. 1937).

However, ruling case law in Texas on the choice-of-law issues implicit in your queries has changed completely since the decision in Boseman and the various Texas cases which rely on it, including decisions issued as recently as 1982.

In Boseman, the United States Supreme Court applied what now might best be considered as the "traditional" choice of law rule for determining the applicable law governing the contract performance questions -- the so-called "lex loci contractus/place of performance" rule. Boseman, 301 U.S. at 201. See generally Stoles and Hay, Conflict of Laws sections 18.14-18.15 (1984) and Multum non multa -- Festschrift fur Kurt Lipstein, 251, 256 (P. Feurstein and C. Perry eds. 1980). See also Restatement First, Conflict of Laws, section 331 (1934).

In 1984, in a seminal shift in the choice of law regime, the Texas Supreme Court announced that the "lex loci contractus" doctrine, including the "place of performance" rule, would no longer be followed. Instead, the law of the state with the most significant relationship to a particular substantive issue concerning the performance of a contract obligation is to be applied, absent a valid choice of law clause in the contract dictating otherwise. Duncan v. Cessna Aircraft Co., 665 S.W.2d 414 (Tex. 1984).

The rule announced for the resolution of choice-of-law in Duncan follows that in the current version of the Restatement of Laws published by the American Law Institute:

(1) A court, subject to constitutional restrictions, will follow a statutory directive of its own state on choice of law.

(2) When there is no such directive, the factors relevant to the choice of the applicable rule of law include:

(a) the needs of the interstate and international systems,

(b) the relevant policies of the forum;

(c) the relevant policies of other interested states and the relative interests of those states in the determination of the particular issue,

(d) the protection of justified expectations,

(e) the basic policies underlying the particular field of law,

(f) certainty, predictability and uniformity of result, and

(g) ease in determination and application of the law to be applied.

Restatement (Second) of Conflict of Laws, section 6 (1971). Duncan, 665 S.W.2d at 426.

In light of the adoption of the restatement test by the Texas Supreme Court in Duncan, we think that even in the case of an insurance company not doing business in Texas which issues policies to out-of-state employers for coverage of their Texas employees, a court would probably apply the substantive provisions of Texas insurance law to the contract, thus subjecting such contract to the requirements relating to coverage for in vitro fertilization procedures set out in article 3.51-6, section 3A of the Insurance Code.

SUMMARY

An employer furnishing a group health insurance policy for the benefit of its employees in Texas is the "policyholder" within the meaning of a provision of the Insurance Code which grants to "policyholders" the right to reject insurance coverage for in vitro fertilization procedures. Ins. Code art. 3.51-6, section 3A. The Insurance Code does not extend to employee beneficiaries of group health insurance plans the right to reject coverage for in vitro fertilization procedures. Under current choice of law rules, a court would probably hold that article 3.51-6, section 3A, of the Insurance Code applies to contracts for group health insurance entered into by employers located outside of the state for the benefit of employees within the state, whether or not the insurance company is otherwise "doing business" in Texas.

Very truly yours,

JIM MATTOX
Attorney General of Texas

MARY KELLER
First Assistant Attorney General

LOU MCCREARY
Executive Assistant Attorney General

JUDGE ZOLLIE STEAKLEY
Special Assistant Attorney General

RICK GILPIN
Chairman, Opinion Committee

Prepared by Don Bustion and Susan L. Garrison
Assistant Attorneys General