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Open and Public
Ralph M. Brown 195
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Meetings
Brown Act Definition: A meeting is a gathering of
members to hear or discuss any item of distric
rotential business. A meeting under the
ave to include action. It can sirr� ���� c
information.
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There are three types of meetings:
E
Regular - regularly scheduled
formally set the time and plac
their bylaws, by resolution or ,
➢ Special —
boa rd to
meetings called I
discuss a specific
➢ Emergency
the Act, to
— meetings h
deal with emE
Fe
majority of
Collective Briefings
➢ Collective briefings are not perm
briefings involving the
directors must be ope
satisfy the notice and
specified in the Act. j
➢A unilateral written
legislative body such
du
advisory memora�'
brown act. The m
public record.
to the pul
Benda req
ormm
nicatio
s an ),nrorrrr
� does` not �
M
ie
'0- and
ements
�o a
fco'
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More About Meetings
➢ The Board CAN NOT meet to discuss District
meeting that the public has received proper
agenda must be posted. Generally, Distri 0
for coffee or lunch to discuss Dist riJ ° e.
meeting.
Example: In 1968 the Sacrame
the Sacramento County Board;!
held a lunch gathering that in
supervisors, the county coun e
and representatives of a uni n
underway against the coun
fathering constituted a m etin�
in violation of the act.
➢ If you type ""Brown Act
engine you will get mai
or potential violations.,
➢ There are a few exce pti
business
not!,��ii
x
o Newspaper
jf Supervisors t
Ad d five count
a variety of cl
to discuss a str
'he c urt ruled
i and ,the sung
olatins" into
exa p l es of
n i me
-own ,
outside of a
meet
fa
ild sued
3use they
r officer,
iat was
this
wer
t sea
viola
I
Meeting Exceptions
Conferences — It is okay
not discuss District
permissible to
business if it is
program and the
to the public.
More Exceptions
Community Meetings — It is okay to attend community
meetings together. For example, if there is a meeting to
discuss building a new aquatic center in the District i
okay if all District board members atte,��,
➢ Other Legislative Bodies — Fc """"e"xample a mPt , "Irng of the
County Board of Supervisors r LAFCo.
➢ Social or Ceremonial Events There is nothi in the Act
to prohibit directors from a n ing purely si I or
ceremonial gathering. For x m le, funerals ddings,
etc.
The Bottom Line; With all o th se ex eptions, th and m t
avoid talking about District bus Hess He th the e ent.
The only time directors can discuss Dis riot B outsid a
meeting is if the busines is art of the "other or izatio i
agenda and the agenda as een properly poste For ex mple,
if the Board of SNscuss
ervis rs requested that the Di ict a
their meeting toDi sss �nd th 0S ha
properly posted notice,"')))))))
Special Meetings
Conditions for a special meeting:
➢ Written
notice
must
be delivered to each mem ��
body and
to each
local
newspaper of 9r �,� (]i�i��������6'� M101
television station which has requested114ch notice in wri
The written notice must be delivered nd posted at IE
prior to the special meeting in a site f eel accessible to
notice must include the time and plae of e meeting,
description of all business to be trar�sa�ted r discussed
The District cannot consider business that IS not
notice. i
➢ Notice is required even if no, ction is taken at, the m
pd radio or
g. (§54956)
24 hours
public. Th
a brief /
i4956)
ng.
in th
➢ As with regular meetings,4 � mus low for a
public comment period
Emergency Meetings
➢ Extremely rare
➢ Only call an emergency meeting if th 11D1�
emergency
➢ An emergency is defined as:
• a crippling activity, work stoppage ��"other activity wl
impairs public health, safety or bo . (§54956.5(a)(1)
Example: a well that is critical to th i trict's water sul
➢ Generally emergency meeti s an not incl!
sessions (§54956.5)
■ Exception: If the District is m eti g wit law enforcE
at least 2/3rds of the board d ter ines t t it is nece
➢ An one who has request" d otice f megfi
cal ed one hour before a meeting
➢ In the event the phon are not wor\ing th
requirement is waived
severely
is failing.
closed
t officials, and
%ust e
Emergency Meetings Cont.
➢ After
an emergency meetin
the minutes, a
list of people
who
received
notice,
roll
ca
votes,
and
any
action,
taken must
be
posted
y acc
in a freNS4
location
for
at
least
10
days.
�
In the case of a dire emerge y, the Distri ould only
need to provide notice at or ar the time t notice is
provided to the members of body. (§ 5 6.5(b).)
➢ Definition: A dire emergen s crippling c
destruction, terrorist act, t re tened terr
that poses peril so immed�at and significar
requiring a legislative body t provide one -
be ore holdingan emer enc meeti ma
I 9
public health, safety, or both, as determine
majority of the membe s of �Ihe legislative k
(§ 54956.5(a)(2).) �m
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ster, ms
i t activity
t at
uviinotic�
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Subcommittees
➢ The Brown Act also applies to meetings of all:
Standing committees — a
continuing jurisdiction ov
rgf(fg
ff,
§54952(b) For example:
,,,',,
Advisory committees th �
board and are not stands
Advisory committees
(regardless of the nu
Exception: The Brown
subcommittee that is m,
directors, is an advisory
committee
committe,
opic
3udgets, p sonnet, et
include a
a commit
it ae standi
er of directs
act dpes not
de ud of less
pply t
han a
Jar, i s n
ijority of
s �
comm"itt
ajoh
a stan
s
•r
Serial Meetings
Serial meetings occur wh a majority Ef the
Directors have communi �t d about asue
and have developed a cq�ll�ec �ve concnce.
➢ A collective concurrenc,6 i developed en:
Directors have either irec ly or indirectly and
each others opinion n a topic enough to
collective) develop r vo a
n n i ������ agreement o a s J
�N Ill 1 1 i �i� �� iii iiiiiiiiii uiii�iilllll IIIIIIIIII�IV�d��f� ����������III
Types of Serial Meetings
➢ A daisy chain meeting:
➢ Example: When director Bob calls dire
about a new wind energy prr�, �,1������ a s
director John to talk about"'f and final) r�°� n calls
o�U y
director Fred. A majority o :"the directors ve talked
about the topic and a colt ive concurrE e has bee
established.
➢ Hub and spoke meeting:
� Example: For instance, f 'mpl yee Terri Is Director
John and discusses an Disrict i sue to g is opinion
with him then she calls director RoberFf alls;-'
director Bill and then calIs'l directd� Tim t ng each
what the other has aid, 0 majority of th Boar
indirectly discusseh6 t pu not
and is therefore in owl t.
E-mail
§5492.2(b): Except as authorized
§54953, any use of dire ion,
personal intermediaries, r technol ical
devices that is employed y a maj of th
members of the legislat' body to velop
collective concurrence t action beta e
on an item by the me ers of the islatie
body is prohibited �
The attorney general his Zssqed a opi %"on
stating that this section of the ac pp
The Attorney General's opinion
regarding e-mail
➢ In 2001 the CA Attorney General issued an opinion regarding the use
of email. (Opinion #00-906, 2001) p��pANNNNN�������������I��1��111�0����101�������ll����llllllll�llllll�lllll�lllla�lllllllll�lll�lll��aaaaaaaQugpuu
➢ The opi n ion concluded: A majority o , u141 a � 01°11
public agency may not email each o°��er to develop
concurrence as to action to be take °by the board
the Ralph M. Brown Act.
Even if the emails are made public'te would still k
the Act because the board wouldel de riving the p
deliberative process.
➢ The opinion also states, "The to m
construed to connote 'not only, olle
acquisition and exchange of facts pi
decision. [Citation.]" (Rowen v, Sad
(1981) 121 Cal.App.3 231, 34; s
supra, 5 Cal .4th at p. 376.)
➢ You can find the opinion a
http://ag.ca.gov/opinions/
s of a local
a liective
✓� ut violating
Jelib6 ation' has
:tive disc ussi
elimin y to t
to Clara, Unified
Rober s v, Cin
fiolation of
of the
�h broad'
e coll ctive
to
►oo/ Dis
Pa/md le,
Meeting Agendas
All meetings
of the Board
of Directors
must have a
•.'
Meeting Agendas
➢ Requirements:
Posting requirements —Agendas must be posted at le
before the regular meeting in a location fre
members of the public.,,,,,,,,,,�iimiiiiiiiiii�i��ll�lll
Content requirements —The agenda hould contain rief general
description of each item of business o be transacte discussed
the meeting, including items to be s ussed in clos ssion.
Agendas must have enough infor io to enable m
general public to determine the en ral ature of su
each agenda item to be discuss d.
➢ The 1994 revision specified that the brief escri y
not exceed 20 words.
****The Board can not discuss or ake a 'tion on are item
agenda. However, there can b res uetions
other limited routine commen Adion
rs of the
matter 6
era I
t is
n the
;eptions.
n
The Three Action Exceptions
➢The three action exceptions are dis
section 54954.2(b) of thquaglif-low#W1�
➢ They are:
Emergency situations
A need for immediate a
Items posted on a
�� A detailed discussion
included in the next
Action Exceptions
Emergency Situations
➢ Action can be taken on an item that is no
there is an emergency situation
➢ An Emergency situation exist: if the legisla,
determines a work stoppage crippling disc
activity severely impairs pub1ilc\health, safe
➢ This exception would generally o ly apply
very rare occasions.
➢ An example might be if th Tr ckee River flo
floods the District's offices an0 emerg ocy cone
flood happened right bef re the regular, Board
agenda had been poste and the GM or ",a Direi
topic of the need for a erge re airs to the
allowable for the boar,
body
r, or other
)r both.
e Distri
Action Exceptions
A Need For Immediate Action
➢ Action can be taken on an item that is not on the agenda if the
Board determines by a 2/3 rds vote that there is a e IIIIII�IIIII�IIIIIIIIII�IIII������������������aaaaaaaappppgppp��u
immediate action that cant reasonably w
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meeting. (§54954.2(b)(2)) rii��i�������l�l�� �I
➢ exce Requirements to use this do f: 1�
q p
➢ The issue must have come to � attention of Board aft r
the agenda had been posted.
➢ The Board must openly disc s th issue durir he meeti g.
➢ Example- The day before the ist ict oard meet] a Director
finds a grant opportunity that is t e pe fect matc o a Ion
plannecl District project. The , ra t prop sal is NNI day after
the regular meeting. Staff wit put in the extra e to co plete
the proposal, however, it n eds tie approval of t Board to
submit it. In this case the irect6r could bring th rop
the meeting for the Direct rs to ote on wlhmether not P
this opportunity. The vote ylati of the Bro
Act. illll(Illlllllllllllllllllll���f�
Action Exceptions
The third action exception
➢The item appeared on
and was continued frq
not more than five day
➢Example: The Board
resolution on a topic
scheduled Board m�
Directors agree to c
on the topic at a
to be held in two
a previo
Closed Sessions
Without specific
Act for a closed
business must
uthority`
session,
in th
in
grow
trig'
public
Closed Session Requirements
➢ The Attorney General has stated, "If a specific statuto
exception authorizinn a closed session cannot b fo �i IIII�� a�aaa�aaaaaaaaaa�uu
matter must be conducted in public re)
sensitivity." (§ 54962 [of CA go , ,, �� �f ��� e wen v.
Santa Clara Unified School Disc (1981) 121 C .App.3d 231,
234; 68 Ops.Cal.Atty.Gen. 34, 4 0�' 42 (1985).) n
Items to be discussed in closed
agenda an must be orally ann u�ic
session. The agenda must inclu e the
brief description. It is a good id a si
Act that allows for the closed s ssi n.
provides a model format for clo ed
➢ Meetings are either
certain members of
should include only
staff required, legal
matter, consultants,
open or iose(:
the public and
District irectc
counse, a su
a la bo dfil ilia
t��
-)ions must k
d before go
reason for tr
_e the sectior
ction 549.1
session aae
The District can
exclude others. (
rs plus any additil
ervisor involved ii
in the
into close
osed and
khe Brow,
I of the Act
More Closed Session
Requirements
�� Decisions reached in closed session
discussed in public imme
session.
➢ Public comment on clos
➢ In their guide to the 6i
office has stated, ""it w
bodies to afford the p
on closed -session item
adjournment into cl SE
General's Office, pg. 1,
Closed Sessions are allowed for;
Personnel
Including:
v Employee appo
➢ Evaluation of empl
➢ Employee discipli
➢Complaints agai
Closed Sessions are allowed for;
Pending Litigation
Including:
Existing Litigation
Threatened or i pated
�L
Potential LitigaFoNote: The Attorneeneal hag
that the Distrmcts�' lawyer mu
present duri 9 the closed SE
(71 Ops.Ca 11
(1988).)
ation
tote
be
ionli�
-10!
Closed Sessions are allowed for.
Real Estate Negotiations
54956/10NNU
,�,,,
➢ If you a � meeting W h your
negotia r to discus he
purcha �, sale, exc ge or le s
of real ro erry.
➢ Befor oin into cla session
the Dist ict ust is i
negotia or (it,can b omealne ,
fro th district), dE ribe he �
proper and me e p
th oti ng with.
Closed Sessions are allowed for:
Labor Nea#
➢Closed sessionc.
are permitted f
some aspects c
labor
negotiations.
Closed Session Minute Book
(§54957.2 (a))
➢ The District may designate a
clerk to take notes and enter'
them into a minute book duri
closed sessions.
The minute book is not pub
record and must be kept /
confidential.
➢ The book is exempt from`pu is
disclosure under the Ca Public
Records Act in Chapter . 5
r
starting with §6250 of ivisi n
7 of Title 1.
E
Adjournments and
Continuances
v§54955 of the Ac
local agencies to
any regular, adjo�
regular, special o
adjourned specia
meeting to a time
place specified ir
order of adjournn
More on Adjournments and
Continuances
➢ If less than a quorum is present,
present can adjourn the meeting.
➢ If no Directors are present, i
legislative body
stated time and
create a written
0
may declare
place. The c
notice.
The Act ives very specific
of the a journment. §549.r-.
or notice of adjournment
on or near the door of th,
adjourned regular, special
was held within 24 hours
adjournment".
Location of Meetings
With a few exceptions,
meetings must be held wit
District boundaries
(§54954(b)).
Tropical locations are mos
likely not allowed for Distr
meetings.
➢ A meeting may not be hel
any facility that prohibits t
admittance of any person
the basis of race, religious
creed, color, national origi
ancestry, or sex; which is
inaccessible to disabled
persons; or where membE
the public may not attend
without making a paymen
purchase.
The Location Exceptions
Meetings can be held outside District boundaries for the
following reasons:
To comply with state or federal I ial or
administrative proceeding to wh the agency is party.
§54954(b)(1) r
To inspect real property that ca I of be easily bi
District boundaries. The meetin '154954(b)(2)
cussion is lin
property the District is inspecti,�
To participate as a body in a
another jurisdiction also part
the meeting must take place
agencies involved in the mee
If an agency does not ha
meet in the closest facilit
if the office is located oui
§54954(b)(4)
Muilti-agency meetii
cip ting 'n the meet
wi hin the boundari
a f 'ci I ity within its be
or a the princi,�ounda
al offic
ide t e district
ht within th
to the
Id in /
j. However,
0 one of ,the
daries, it can
Df the district
Location Exceptions Continued
To meet with elected or
a local meeting would be
e
To meet at or nearby a facility
outside district boundaries, if
to items related directly to th�
➢ To visit the office of the Di
session on pending litigatio
fees or costs. §54954(b)(7
Finally, if there is an em
location unsafe, the me(
designated by the presi
the local media that h
method of communicat
or state offi
I d5lC5l
4954(e)
Teleconferences
➢ 54953(b)(1) permits the use of teleconfencing
➢ Requirements for teleconferinclude:
➢ Teleconferences must comply w h the rest of the ct
➢ All votes taken during a teleco a ence must be en by roll
call.
Agendas must be posted at III �le�nference to ins. �
Each teleconference locatio�� m st b identified i agenda.
➢ Each teleconference location must be ccess% 4, public.
➢ At least a quorum of the oard must p rticipate m locations
within the district bound ries.
➢ The p
agenda must rove e for �ublic comment at ch(��
9
teleconference locatio
Disruptive Attendees q\\
The district MUST allow for negative
public comment however,
does address willful inter 'ptions of
meetings.
The Act states that the e tiers of
the legislative body cop c ng the
meeting may clear th r om nd
continue the meeting. Hwev r, al
press and other members oft e
pubic who were not'
of the"""",,
interruption must be all wed to
stay. 111111,11
Special Situations
➢The Brown Act also applies to
corporation that both ����� �� e
member or councilme 'ber appc
the agency to serve the corp
board, and (ii) receiv'e unds fry
district or city. /
i board
ted by
tion"s
the
Penalties and Remedies
■ 1. Criminal Penalties
. Misdemeanor for atten
body at a meeting why
violation of the Act a c
deprive public of inf rr,
ance by m
r action is
;ember ir
gat on.
ber of a
:en i n
ids to
/
Civil Remedies
2. Civil Remedies
Injunction, Mandamu
prevent or stop violat
violations
Action to void past a
or declara
ins or thre
� relief t
ned
Demand to Cure or Correct
■ Prior to bringing lawsuit the di'
attorney or interested oref"If, u
dmenad of the legisla "ve body t
correct the alleged u , � wful acti
. Demand must be
• 30
days
of
open
• 90
days
of
close
rya e
�ssion
I'
session
ithin
lake a
ure or
Cure or Correct
• Agency has 30 days from rece
N�N� pji J111111111��JJJJJJJ
d e m a nd to cu re or co fff �-;oetlj
■ Party must commen
days of notice to cui
expiration of 30 dad
U
ction wi
\not or
respgnse p
15
yin
do
Cease and Desist Letter
■ New Requireme
effective Januar
nt — SB 1003
Section 54960.2
■ Prior to filing lawsui
violation, district at
person must send;p
and desist" letter/
More Cease and Desist
• Clearly describes
alleged violation.
0
past action
Must be sent within
alleged violation
. Public agency
days with an
must
u n co
cease, desist from
action.
Attorney Fees
. Plaintiff may receive attorney fees
District, but not the B 1111111�
. District may receive at rney fees
and the action was frilous and �
merit.
• Court must award b
letter is sent more
of cease and desist.
Plaiff if a c
an 3:0\days of
, 1t prevails �', out
r�mitmeht
rl receipt
For more information
rView the CA Attorney General'http://www.ag.ca.clov/pUN'l�j,""�'CiCfns/23 Intro
rownAct.pdf
rAttorney General's Opinion Regard the Us
of email: http://aq.ca.gov/Qi)in'ons/publi � d/00-
906. pdf T7 \
rText of the Brown Act:
http://www.leginfo.ca.gov c i-
bin/waisgate?WAISdocID"6815592,,,,595+1 +0&WAISa
ction = retrieve(71
➢Ask your attorney!