2008 VETOES.

cation of Laws', said new section to be known as Sec-
tion 9 and to follow immediately after Section 8 of said
Article, providing for the filing of rules and regulations
adopted by any officer, board or commission. "

This measure directly affects the State Law Department
from which I have received the following opinion:

"This Bill adds a new section to Article 76 of the
Annotated Code of Maryland (1939 Edition), title 'Pub-
lication of Laws7, and it requires, in substance, that
every state officer, board or commission empowered with
authority to adopt rules and regulations, submit to the
Attorney-General for approval, copies of every such rule
or regulation heretofore or hereafter adopted. Upon
such approval, copies are required to be filed with the
Clerk of the Court of Appeals and the Department of
Legislative Reference and no rule or regulation here-
after made is to be effective until after compliance with
the provisions of this section.

"There are a number of objections to this Bill. In
the first place, as has been noted, the body of the Act
requires all rules heretofore or hereafter adopted to be
submitted to the Attorney-General for approval. The
title gives no indication of this provision, it merely
stating 'Providing for the filing of rules and regulations
adopted by any officer, board or commission'. This provi-
sion as to filing is, of course, contained in the Act and
there is an additional provision not indicated by the title,
requiring approval by the Attorney-General as a pre-
requisite of filing. Such a discrepancy between the title
and the body of the Act may well render it invalid.
Assuming, however, the validity of this provision, it
should be noted that all regulations, whether hereto-
fore or hereafter adopted, are required to be submitted
for approval and this approval is a prerequisite to filing.
On the other hand, no regulation hereafter passed be-
comes law until it is filed and this phraseology leaves
open for argument the validity of those regulations here-
tofore passed and submitted to the Attorney-General un-
der this Bill but not approved or acted upon by him.
There seems to be no necessity for leaving this legal
question subject to debate.

"Further, it should be noted that the Bill establishes
no standards by which the approval of the Attorney-
General is to be determined. In other words, is this
approval to be based upon the legal sufficiency of the
ruling or is it to be based upon the Attorney-General's
opinion as to the policy of the rule ? If the standard is to