HomeMy WebLinkAboutMemo 10
TRUCKEE DONNER PUBLIC UTILITY DISTRICT
STATEMENT OF GENERAL FUND - March 30, 1983
Bank Balance - March 1 , 1983 $ 189,825.14
Electric Revenue 448,280.14
Water Revenue 41 ,037.01,
Electric Connection Fees 450.00
Water Connection Fees 225.00
Facilities Fees 400.00
Miscellaneous Billings Revenue 1 ,56-.11
Miscellaneous Revenue 1 ,54-4.93
Standby Revenue 12,842.80
Transfer from LAIF 142,000.00 $ 838,171 .83
Approved Billings 477,896.04
Less: Overpayments and voided checks ( 710.56) 477,185.48
George Cattan - pension plan payment 258.75
AWWA - Water treatment forum, Waller, Rully, Tamietti 60.00
D & C Roadside Service 1 ,247.69
Directors - Board meeting attendance 800.00
Employment Development Dept. 3,081 .48
Employee Meals - 66.00
Employee Telephone 27.96
I.B.E.W. - union dues 460.30
Petty cash - replenish fund 186.58
155.44 342.02
Placer County Credit Union 1 ,068.42
Refunds: Credit balance on closed accounts 2,352.76
Refunds: Energy audit fees 30.00
Social Security Division
7,584.54
Department of Health. Services water certification
fee - Rully 15.00
Truckee River Bank - fed tax deposit 7,467.73
- LAIF deposit 293,000.00
Computer Loan Payment 2,569.80 303,037.53
United Parcel Service deposit to open
account 100.00
- Stamps 100.00
- Trust Fund 25.00 125.00
RMRS - Postage Meter 500.00
Craig, Susan - seminar expense 132.60
Ozalid - supplies for blue print machine 111 .00
Ward, Jim - seminar expense 95.93 (798.682.46)
PAYROLL
2/28/83 OT Gross Net
Permanent 2,761 .32 27,372.90 20,003.35
Temp. 70.49 65.20
3/15/83
Permanent 994.85 29,362.79 21 ,133.35
102.60 94.60
Total (41 ,296.50)
Bank Balance - 3/31/83 (1 ,807.13)
Bills for Board Approval - see attached (417,562.72)
-Martis Valley Substation ( 50,770.50)
Bank Balance after payment of above 470,l40.35
LAIF Transfer to cover above bills 420,000.00
LAIF Transfer from Martis Valley Substation account 50,770.50
Bank Balance after LAIF Transfer 54,662.99 630.15
BILLS FOR BOARD APPROVAL - April 4, 1983
Total Electric Water General Description
g Aetna Life & Casualty 97.50 97.50 Life insurance for 3/83
Airsignal of California 16.00 16.00 Radio Service for 3/83
Andersen, Arthur & Co. 985.00 985.00 Services and consultation on accounts and budget
Allied Automotive, Inc. 82.46 82.46 Misc. auto parts
Allied Petroleum Co. 1 ,646.74 1 ,646.74 Gas and barrel pumps
Alpha Supply 261.25 166.87 94.38 Door closer, rope, brooms and towels
American Water Works Assc. 15.60 15.60 Improving well/pump efficiency
Bi-State Petroleum 1 ,175.43 619.15 556.28 Oil for water dept. and heating oil
Blue Cross 10,180.15 10,180.15 Insurance premium for 3/83 & 4/83
California Service Tool 153.27 153.27 Wood rules and long nose pliers
Cal Western Life 9,376.06 9,376.06 Pension Plan 3/83 & 4/83
Cassano, Andrew R. 65.30 65.30 Consultant services 2/83
Cook Assoc. 1 ,951.10 1 ,951 .10 Consultant Services 3/83
Credit Bureau of Tah. Truckee 12.00 12.00 Services for 3/83
Davey, John 450.00 450.00 Misc. carpentry work
Davis Auto Parts 166.62 166.62 Misc. auto parts
Dearman Snow Removal 120.00 120.00 Removal Martis Sub.
Digital Equipment Corporation 893.00 893.00 Maintenance coverage on computers
Digital Systems 2,825.43 2,825.43 All license , fees 3/1/83 through 3/31/83,
General ledger conversion costs
Farmer Bros. Co. 138.78 138.78 Coffee, Cocoa, Tea
Grainger, Inc. 4.24 4.24 ONE switch
G.E. Supply 1 ,145.17 1 ,120.01 25.16 Misc. tools, light fixture, Fargo, auto dead
Graybar Electric 339.20 339.20 Rolls of MMM tape
Hansen, James and Assoc. 9,116.54 9,116.54 Consultant services 2/83 , travel expenses
High Country Answering Service 80.55 80.55 Answering service
House of Printing 1 ,187.73 1 ,187.73 Letterhead, envelopes, meter cards, mehu sheets
meter installation record
H & H Janitorial Supply 76.95 76.95 Seat covers and dispensers
John's Sprinq Service 79.20 79.20 Spring repair unit
J.S. Truckee Rents 53.00 53.00 Forklift rental
Lanier Business Products 25.78 25.78 Typemaster ribbon
Longs Drug Stores 33.22 33.22 Office supplies
McDonough, Holland & Allen 132.23 132.23 Consultant services 2/83
Y
BILLS FOR BOARD APPROVAL - April 4, 1983
page 2
Total Electric Water General Description
Mid Sierra 562.00 562.00 Labor for vehicle repair
Moore Computer Forms and supplies 228.43 228.43 Office Supplies
Morlock 114.43 114.43 Meter rinqs and keyhole inserts
Mountain Hardware 136.91 136.91 Misc. hardware
Nevada Communications 118.00 118.00 Radio repair
Northwest Public Power Assn. 135.00 135.00 Balance due for distribution system school
design for James M. Ward
OB's Board 76.50 76.50 Meal for Harker & Harker consultants
Office HELPER 144.22 144.22 Office supplies
Ozalid 550.00 550.00 Maintenance contract for blue print processor
Pacific Telephone 867.16 867.16 Telephone for 3/83
Pacific Telephone 454.99 454.99 Telemetry for 3/83
Pioneer Equipment 40.55 40.55 Misc. hardware
Pitney Bowes 68.37 68.37 RMRS meter rental
Record supply 50.75 50.75 Galvanized pipe
Red Star Services 136.20 136.20 Supplies for 3/83
Safety Live Line 190.57 190.57 Hot sticks
Sierra Pacific Power Co. 394.93 394.93 Design and install underfrequency protection
at Martis sub.
Sierra Pacific Power Co. 361 ,514.36 361 ,514.36 Power bill through 3/83
Sierra Sun 34.75 34.75 Public notices and ads in newspaper
Siri Office Supply 115.96 115.96 Office supplies
Sun Printing 3.71 3.71 Office supplies
Tahoe Heating 156.12 156.12 Service a/c for computer room
Tahoe Office Systems 1 ,134.20 1 ,134.20 Office supplies
Tahoe Truckee Disposal 129.00 129.00 Trash disposal for 2/83
Tahoe Truckee Med. Group 100.00 100.00 Physical exams for Mcgovern and Mcquary
Tahoe-Truckee Sanitation Agency 200.00 200.00 Lab services for 1/83
Tahoe Truckee Supply 3.78 3.78 Copper adapter
Taylor's Tires 18.85 18.85 Tire repair
Terra Engineering 1 ,400.00 1 ,400.00 Blue print processor
Truckee Auto 44 3.56 3.56 Misc. auto part
Truckee Donner Glass 39.18 39.18 Window
Truckee-Tahoe Lumber Co. 75.10 75.10 Misc. buildinq material
Weaver Equipment 15.60 15.60 Misc. vehicle parts
Vail , Raymond and Assoc. 447.00 447.00 Nevada county maps transferred to mylar
Westinghouse Supply Co. 1 ,482.52 1 ,482.52 Compression sleeves, flashliqhts, clamp stick
Pole clevis, spool , triplex "conch"
BILLS FOR BOARD APPROVAL - April 4, 1983
page 3
Total Electric Water General Description
Western Nevada Supply 146.68 146.68 Hose nozzel,s, rings, aqua pig, misc. nuts & bolls
Winslow's 145.37 145.37 Map holders
Withrow Oxygen service 65.46 65.46 Hobart, hardfacing alloys
Wood, Porter, Simon & Graham 3,116.86 3,116.86 Legal services for 3/83
Zellerbach Paper Co. 60.15 60.15 Can liners and towels
417,562.72 375,209.25 3,574.28 38,779.19
c�
1
BILLS FOR BOARD APPROVAL - April 4, 1983
Martis Valley Substation
Harker & Harker $50,770.50 10% retainer for substation work. One thousand dollars
has been held from this amount for grading to be done
in the spring.
March 25, 1983
James . Simon
Port er,S imon and Graham
Truckee, California 95734
.^
Dear Jim,
Yesterday, March 24, 1983s the Truckee Donner Public Utility District
Board of Directors held a special meeting with Rick �lumfield of Authur
Anderson, Inc. 1�hile I questioned tha proceedure for calling the meeting
and do have concerns over its legality, I am none-the-less more concerned
with what happened after the special meeting was adjourned at 5:20pm.
When I adjourned the special meeting at 5:20 I left the board room to
make a phone call. Directors Corbett, Kuttle and VanLandinghaa remained
- to talk with the Manager, Jim Ward. A few minutes later I returned to the
board room to give the manager a message. I observed two of the three
directors (Kuttle and VanLandingham) discussing an issue relative to board
policy (interest charges on late payments) with the manager. Director
Corbett was sitting there listening.
I turned and left the room believing that a violation of the secret
meeting laws was taking place. Today, I called Manager Ward and asked him
how long this meeting lasted. He told me that the discussion lasted thirty
minutes or so.
Please review the facts and in your capacity as Council to the District,
provide each director and the manager -41th an opinion of this situation.
Could you also amplify on the topic of what is a properly called public
meeting vs. an i11e?al or improper meeting as outlined in tha Ralph M.
Brown Act?
'thank you for your prompt attbotion to this matter.
Sincerely.,
i
7's
A. Haase
iredtor
Truckee Donner POD
cc Jim Ward
John Corbett
Karl Kuttle
Dick VanLandingham
LEGAL OPINION
DATE: MARCH 31 , 1983
TO: BOARD OF DIRECTORS, TRUCKEE DONNER PUBLIC UTILITY
.— DISTRICT
FROM: JAMES ERNEST SIMON, DISTRICT COUNSEL
QUESTION PRESENTED
By letter dated March 25 , 1983 , President Maass has
requested an opinion as to whether a special meeting which
occurred on March 24 , 1983 , was in violation of the California
Secret Meeting Laws .
CONCLUSION
We have determined that, depending upon the subject matter
f
actually discussed at the meeting, the deliberations made, and
the action taken, a technical violation of the Ralph M. Brown Act
may have occurred.
FACTUAL BACKGROUND
We are advised that a special meeting was held on March 24,
1983 , pursuant to written or telephonic notice to all Directors.
The subject matter of the meeting according to the agenda
concerned discussions with the District' s accountants for
purposes of discussing the annual audit. The meeting was
convened in the late afternoon and adjourned by President Maass
at 5: 20 .
We are advised that thereafter Directors Corbett, Kuttel and
VanLandingham remained engaged in a discussion with the General
Manager James Ward. We understand that the subject matter of the
-1-
Board of Directors
March 31 , 1982
Page 2
discussion related to implementation of the District' s policy
concerning interest on late payments to the District. We have no
information detailing the specifics of the discussion.
�. President Maass is of the opinion that a violation of the
secret meeting laws may have occurred inasmuch as the meeting
apparently lasted approximately 30 minutes.
DISCUSSION
A brochure entitled "Secret Meeting Laws and Public
Agencies" published by the Legal information Center of the
California Department of Justice is reproduced and attached
herewith. Please note that this brochure was published April 1 ,
1981 , and is therefore somewhat dated.
The Truckee Donner Public Utility District falls within the
provisions of the Ralph M. Brown Act, the purpose of which is to
A
ensure that all deliberations and actions of local public
agencies are performed in public. The Act was specifically.
designed to discourage and prevent secret meetings . .
The issue presented here concerns in part when the meeting
ended; that is was it properly adjourned.
Generally speaking, Robert' s Rules of Order under which the
District _generally conducts its meetings, require that a Motion
To Adjourn be made . Such a motion is undebateable, cannot be
amended , and cannot be reconsidered. In the absence of a motion
and subsequent vote, it is unlikely that an adjournment is
technically proper. Under the facts presented, it is assumed
that the motion was made, voted upon, and the meeting properly
adjourned.
-2-
Board of Directors
March 31 , 1982
Page 3
Once the meeting was adjourned, the inquiry now focuses upon
whether another meeting took place. A meeting is generally
defined as any gathering of a quorum of a legislative body, no
.-� matter how informal, where business is transacted or discussed.
The California Attorney General rendered an opinion in 1963
that an "informal, " "study, " "discussion, " "informational, " "fact
finding, " or "precouncil" gatherings of the majority of the
members of a board were probably "meetings" whether or not any
action was taken. (See Secret Meeing Laws, page 6 . )
The legislative purpose of the Brown Act was reiterated in
Carlson v. Paradise Unified School District (1971) 18 Cal.App. 3d
196 , 199.
In the event that the special meeting held March 24, 1983 ,
was properly adjourned, and various Board members informally
r
remained at which time Board business was transacted or
discussed, a technical violation of the open meeting law
(Government Code §54943) may have occurred.
In the event however that no "meeting" occurred, in that no
group discussions were had nor business transacted, the spirit of
the law may well have been complied with. For example, if the
gathering did not involve the collective acquisition and exchange
of facts which were preliminary to some future Board decision, it
is conceivable that the gathering was not a "meeting" of the type
which the Brown Act was designed to protect by ensuring that it
be held in a public and open environment.
For purposes of future activities , it is advised that all
meetings of the District be formally adjourned upon motion and
-3-
Board of Directors
March 31 , 1982
Page 4
that at all "informal" gatherings among three or more members of
the Board any discussion whatsoever about Board business by
avoided.
JES:cjg
Attachments : Secret Meeting Laws
Letter dated March 25 , 1983
w
-4-
J
Secret Meeting
Laws -
& Public _ - -
Rgencies
VON-
t
Prepored under the supervjsion of the
George Deukmejian Civil Division
Attorney General
Willard A. Shank
Michael franchetti Chief Assistant Attorney General
Chief Deputy Attorney General
Richard D. Martland
George Nicholson Assistant Attorney General
Senior Assistant Attorney General
Director, Legal Information Center Clayton P. Roche
M. Anthony Soares
Deputy Attorneys General
Editors
PREFACE
Secret Meeting Laws and Public Agencies was first published in January of 1972
and later revised in April of 1976. Since the 1976 revision, certain provi-
sions of the Ralph M. Brown Act (hereinafter "Act") (Government Code Section
54950, et seq. ) have been amended and various appellate court decisions and
Attorney General's opinions construing and applying the Act have been issued.
,�- Some of the more significant developments in the secret meeting laws
involve: (1) distinctions between "local" and "state" agencies, infra,
page 4; (2) definitions of the term "legislative body" and the application
thereto of the "less than quorum exception," infra, page 7; (3) special meet-
ings in "emergency situations," infra, page 19; (4) the availability to mem-
bers of the public of documents distributed to members of a legislative body
for consideration at a public meeting, infra, page 21; (5) the public state-
ment by a legislative body of the general reason or reasons for holding a
closed (executive) session, infra, page 22; (6) executive sessions authorized
by the "personnel exception," infra, page 22; (7) executive sessions impliedly
authorized by other confidentiality provisions in the law, infra,_ page 27; and
(8) minutes of executive sessions and the confidentiality thereof, infra,
page 30.
Also worthy of mention, is a nonsubstantive change in terminology which
took effect January 1, 1981. At that time, the term "closed session" replaced
the term "executive session" in the Brown Act. For purposes of this handbook,
however, the terms will be used interchangeably.
of(AIJA `
w Mr liKr/./
To order additional copies
of this publication, write to:
Legal information Center
Office of the Attorney General
555 Capitol Mall, Suite 290
Sacramento, California 95814
For further information, contact:
Tony Cimarusti
Press Secretary
Office of the Attorney General
916/445-0926
April 1. 1981
i
Cover illustration by Paul Duginski
3�
TABLE OF CONTENTS
/ Page
l 1 I. INTRODUCTION
2 II. THE RALPH M. BROWN ACT
2 A. Purpose and scope-of the act
2 B. To whom does the act apply?
2 1. Local agencies
3 2. Legislative bodies
4 3. The less than a quorum exception
6 C. What is a meeting?
7 D. Notice of meetings
7 1. Regular meetings
7 2. Special meetings
8 3. Emergency meetings
8 4. Special notice provisions - district landowners
R
8 E. Public's rights while attending a meeting
9 F. Permissible executive sessions
9 1. Expressly authorized executive sessions
11 2. Impliedly authorized executive sessions
12 3. Time for executive sessions and required notice
13 4. Minute book
13 5. Miscellaneous considerations regarding executive sessions
14 G. Penalties for violation of the act
15 H. Enforcement provisions
15 I. Effect of failure to hold open meeting
16 III. SPECIAL CONSIDERATIONS RELATING TO SCHOOL DISTRICTS
17 IV. THE STATE AGENCY ACT \.
19 V. CONCLUSION
20 APPENDIX
20 THE RALPH M. BROWN ACT, Government Code Sections 54950-54961
27 THE STATE AGENCY ACT, Government Code Sections 11120-11131
34 EDUCATION CODE, Sections 35145, 35145.5, 35146
36 SPECIAL PROVISIONS, STATE LEGISLATURE, Government Code Sections 9027-9032
37 SPECIAL PROVISIONS, REGENTS, UNIVERSITY OF CALIFORNIA
California Constitution, Article IX, Section 9, Subdivision (g)
Education Code Section 92030
r
3$
I. INTRODUCTION
i The Office of the Attorney General repeatedly receives requests from a variety
of sources as to the meaning and application of the various secret meeting
laws applicable to public agencies. Some of these requests ask for general
information while others relate to a specific incident.
Unfortunately our staff and resources do not permit an individual evalua-
tion of each request to determine the facts, research the matter, and advise
r- on specific questions raised. However, in order to be of some help and assis-
tance, we have prepared this brochure containing general information about the
Ralph M. Brown Act and other secret meeting laws. In addition to discussing a
number of matters that commonly arise, we set forth examples of the manner in
which the courts and this office have construed these laws.
As to this office's construction of the acts, it must be borne in mind
that, although we believe our opinions are well reasoned and we hope persua-
sive, the opinions of the Attorney General are advisory only, are not binding
upon other public offices or attorneys, and thus are not the law of the state
as are decisions of our appellate courts.
Of necessity, the discussion herein will consist of many generalizations.
Therefore this brochure cannot be, nor is it to be considered, a definitive
exposition of the law regarding secret meetings. It is informational in
nature and, hopefully, will be of value to the reader in presenting a general
outline of the law on the subject as it exists at the present time.
As to any specific question or problem, the statutes and decisions them-
selves should be consulted and the matter referred to the attorney for the
particular agency involved, the district attorney of the jurisdiction if cri-
minal action is suspected, or to a private attorney of the reader's choice who
will be in a position to evaluate the actual facts and render advice thereon.
The laws discussed herein will be the Ralph M. Brown Act, contained in
Sections 54950 through 54961 of the California Government Code; several perti-
nent provisions of the California Education Code relating to school board pro-
ceedings; and the State Agency Open Meeting Act (hereinafter 'State Act')
applicable to certain state agencies found in Sections 11120 through 11131 of
r^ the California Government Code. For ease of reference, a copy of these sec-
tions as they existed on the date of the most recent revision of this brochure
is attached. These, of course, may be amended by the Legislature from time to
time. A current code should be compared on any particular matter.
Also included in the Appendix of this brochure, but without discussion,
are the secret meeting laws specifically applicable to the State Legislature
and to the Regents of the University of California. Though not of the same
general interest as the Ralph M. Brown Act, these provisions may be of
interest to certain individuals to whom this brochure is distributed. (See
Government Code Sections 9027 through 9032 re the Legislature; and Education
Code Section 92030 re the Regents of the University of California.)
Section citations are to the Government Code unless otherwise noted.
Cases are cited by name. Published opinions of this office are. cited by
volume, page and year, e.g., 32 Ops.Cal.Atty.Gen. 240 (1958) [volume 32, page
240] and letter opinions are cited as indexed letters by year and number,
e.g. , I.L. 67-147. Published opinions are available through law libraries and
in many attorneys' offices. For the most part, indexed letter opinions of the
Attorney General are only in the offices of the Attorney General.
-1-
II. THE RALPH M. BROWN ACT
A. Purpose and scope of the act
The purpose of the Act can be briefly stated. It is to insure that the deli-
berations as well as the actions of local agencies are performed at meetings
open to the public and as to which the public has been given adequate notice.
It is to prevent government from being conducted in secret. (Section 54950.)
In furtherance of this purpose, the Act requires, with certain exceptions,
+ that all meetings of legislative bodies of local agencies be open and public.
(Section 54953.) Meetings must be conducted in such a manner as to permit
full and complete disclosure of the actions taken and the participation of
individual members in such action. Thus, secret ballot voting at meetings
required to be open and public is prohibited. (59 Ops.Cal.Atty.Gen. 619
(1976) .)
B. To whom does the act apply?
The Act applies to the legislative bodies of all local agencies of the state.
An understanding of the terms "local agency" and "legislative body," as well
as the "less than quorum exception," is important to any determination as to
the applicability of the Act.
1. Local agencies
Local agencies include all cities, counties, school districts, municipal
corporations, other special districts and all other local public bodies.
(Section 54951.) For example, the Act applies to a housing authority
(Torres v. Board of Commissioners (1979) 89 Cal.App.3d 545; I.L. 71-103) ;
to an air pollution control district (I.L. 71-198 and I.L. 70-213) ; and to
such other local bodies as voluntary area and local health planning agen-
cies (I.L. 72-29) . We, however, have held that it is not applicable to
county central committees (59 Ops.Cal.Atty.Gen. 162 (1976)) .
Besides purely public agencies, the Act covers all nonprofit organiza-
tions which receive public funds to be expended for purposes of the
Economic Opportunity Act of 1964 so far as consistent with federal law.
(Section 54951.1.) Likewise, also covered is a nonprofit corporation
formed to acquire or operate any public works project if the board of
directors is appointed by the forming public agency or agencies. (Section
54951.7.)
Inasmuch as the terms and requirements of the Brown Act differ in cer-
tain respects from those of the State Agency Open Meeting Act (Government
Code Section 11120 et seq.) , a potentially significant question is whether
an entity is a local or state agency. This question was addressed and
resolved as to housing authorities created pursuant to Health and Safety
Code Section 34208 in the case of Torres v. Board of Commissioners, supra,
89 Cal.App.3d 545. The court first concluded that "the Legislature
intended that all agencies be included in some open meeting act unless
expressly excluded." It then went on to hold that the housing authority
was included within the definition of local agency under the Brown Act
and, therefore, was not subject to the agenda requirements set forth in
the State Agency Act Section 11125. The court reasoned:
"While a housing authority may be a state agency for some pur-
poses . . . if it is within the Brown Act's definition of a local
agency, it is simply not included within the State Act. We hold that
-2-
a housing authority created by Health and Safety Code section 34200 et
seq. is included within the statutory definition of a local agency
under the Brown Act in that it is either an 'other local public
agency' or a 'municipal corporation' or both, as those terms are used
in Government Code section 54951. . . . The term 'municipal corpora-
tion' is broader than the term 'city,' particularly when the term
'city' already appears in the applicable statute. . . . In order to
give meaning to the term 'municipal corporation' in Government Code
r- section 54951 we hold that such term is not restricted to its tech-
nical sense of a 'city,' general law or charter, but rather includes
such entities as housing authorities. . . . In addition, a housing
authority is local in scope and character, restricted geographically
in its area of operation, and does not have statewide power or juris-
diction even though it is created by, and is an agent of, the state
rather than of the city or county in which it functions. . . .
"Furthermore, as perceptively noted by the trial court, the place-
ment of Government Code section 11120 and its history is some per-
suasive indication that the State Act was meant to cover executive
departments of the state government and was not meant to cover local
agencies merely because they were created by state law. A housing
authority is no more a state agency under these acts than is a city or
a county. The fact that such entities from time to time administer
matters of state concern may make them state agents for such purposes
but not state agencies under the open meeting acts." (Citations
omitted.) (Torres v. Board of Commissioners, supra, 89 Cal.App.3d at
pages 549, 550.)
( 2. Legislative bodies
The term "legislative body" is not used in its technical sense in the Act.
The Act's application is not limited to boards and commissions insofar as
they perform "legislative" functions. Actions which are primarily execu-
tive or quasi-judicial in nature are also covered. (61 Ops.Cal.Atty.Gen.
220 (1970) .)
Besides the actual governing body of a local agency:
a. The Act applies to boards, commissions, or committees of the
governing board or on which members of the governing board serve in
their official capacity and which are supported in whole or in part by
the local agency whether such boards, commissions, or committees are
organized and operated by the local agency or a private corporation.
Thus, it would apply to a voluntary organization composed jointly of
members of boards of supervisors and city councils of cities within
the county. (I.L. 70-91.) It, however is not applicable to a county
board of parole commissioners, since such serves as an adjunct of the
courts. (I.L. 62-46.)
b. The Act applies to permanent boards and commissions of a local
body, such as planning commissions, library boards, and recreation
commissions. (Section 54952.5.) The Act is not applicable to a
meeting of all judges of a superior court of a county. (I.L. 60-16.)
C. The Act applies to advisory boards, commissions, and committees of
a local agency if they are formed by some formal action of the govern-
ing body, or a member of the governing body of the local agency. The
Act, however, specifically excepts from such coverage any such advi-
sory bodies composed solely of less than a quorum of the legislative
body. (Section 54952.3.)
-3-
A possible example of a covered advisory committee is described in a
1965 letter opinion of this office (rendered before the specific addition
of Section 54942.3) wherein a hospital district formed a liaison committee
composed of three members of the district board and three members of the
medical staff. (See I.L. 65-57.) Another example is the San Francisco
Public Schools Commission (the Riles Commission) which was formed to
advise the local school board, the local superintendent of schools, and
the State Superintendent of Public Instruction on how to improve San
`., Francisco's schools. (I.L. 75-196.)
In Henderson v. Board of Education (1978) 78 Cal.App.3d 875, it was
held that an ad hoc committee composed solely of less than a quorum of the
members of the Board of Education and created for the purpose of advising
the full board as to the qualifications of candidates for appointment to a
vacant position was excepted from the requirements of the Act by the terms
of Section 54952.3.
In 61 Ops.Cal.Atty.Gen. 1 (1978) , this office concluded that a bar-
gaining committee created to "meet and confer" with employee organization
representatives pursuant to Section 3505 was not an advisory committee
since its function was to negotiate rather than study and recommend.
Thus, the meetings of the bargaining committee were not required to be
open and public by Section 54952.3. This office has also held that the
Act is not applicable to a county juvenile justice commission since such
is in effect a part of the court system. (I.L. 75-109.) Nor is it appli-
cable to a local admissions committee of the county superintendent of
schools, since such is an advisor or adjunct to a single county officer.
(56 Ops.Cal.Atty.Gen. 14 (1973) .)
d. A single individual acting on behalf of a local agency is not a
"legislative body" within the meaning of .the Act, since all defini-
tions of "legislative body" connote a group of persons. Thus, a
w hearing officer functioning by himself in an employee disciplinary
hearing is not a "legislative body." (Wilson v. San Francisco Mun.
Ry. (1973) 29 Cal.App.3d 870.) Similarly, this office has concluded
that an individual city council member having the responsibility to
screen candidates for vacant city offices is not a "legislative body"
and, therefore, not subject to the Act.
3. The less than a quorum exception
Permeating the whole coverage or applicability of the Act is what may be
termed "the less than a quorum exception" to the Act. As noted above on
the general applicability of the Act, Section 54952.3, relating to advi-
sory bodies of the local agency, now expressly codifies this exception as
it relates to such advisory bodies. Section 54952.3 was added to the Act
in 1968. However, since the opinion of this office rendered in 32 Ops.
Cal.Atty.Gen. 240 (1958) , such an exception has been recognized in varying
circumstances. In general terms, the concept is that the Act does not
apply to meetings of committees of less than a quorum of the legislative
body of the local agency. This is because the findings of such a commit-
tee have not been deliberated upon by a quorum of the legislative body,
and, consequently, the opportunity for a full public hearing and consider-
ation of the committee's findings and recommendations by a quorum still
remains. Hence the public's rights under the Act are still protected.
In 1969, this office expressed the following view: "The resolution of
the quorum problem with respect to other legislative bodies, that is,
-4-
bodies other than the advisory commissions referred to in section 54952.3,
should continue to be governed by our prior interpretation of the law as
set forth in . . ." our 1958 opinion, I.L. 69-131. Again in 1972, we
reaffirmed our prior holdings, such as I.L. 69-131, supra, wherein we
stated: "There have been no amendments to the Act nor case law since
these letter opinions which would change the views of this office as
expressed therein." (I.L. 72-49.) Capsulized, these views would appear
to mean that at least ad hoc, nonpermanent committees or boards not formed
by formal action, such as by charter, ordinance, resolution, or similar
formal action, would additionally still fall within the "less than a
quorum exception." The distinction between permanent and ad hoc commit-
tees arises by virtue of the addition in 1961 of Section 54952.5, making
the Act applicable to permanent boards or commissions of a local agency.
(I.L. 65-57; I.L. 68-106.)
Some examples from our pre-1968 opinions may be helpful. to illustrate
this distinction. In 1963, we held that an ad hoc committee appointed by
the mayor consisting of less than a quorum of the council to study the
possible subsidy of a local bus company by the city would be exempt from
the Act. (I.L. 63-97.) In the opinion discussed above, wherein we held
that the hospital district liaison committee consisting of three board
members and three medical staff members was subject to the Act, we stated
that "inasmuch as the Joint Conference Committee is a 'permanent commit-
tee'" the Act would be applicable "regardless of whether the governing
body is represented by three or two [less than a quorum] members on the
committee." (I.L. 65-57.) We also advised in that opinion that if inves-
tigative committees were to be formed which included less than a quorum of
C the board, the applicability of the Act would depend upon whether these
committees were permanent, or were formed for a limited duration for a
specific problem.
The "less than quorum exception" to the Act was recently upheld in the
case of Henderson v. Board of Education, supra, 78 Cal.App.3d 875, wherein
the above text was quoted at length and its reasoning characterized as
persuasive. For an application of Sections 54952, 54952.3, and 54952.5,
defining the term "legislative body," as they interrelate with the "less
than quorum exception," see I.L. 76-174, wherein we concluded that a meet-
ing of two subcommittees consisting of less than a quorum of the members
of their respective parent boards of supervisors to discuss mutual water
problems was not covered by the Act because (1) each subcommittee,
although literally within the Section 54952 definition, is excluded there-
from by the traditionally recognized "less than quorum exception"; (2)
each subcommittee is further excluded from the Section 54952.3 definition
by the "less than quorum exception" explicitly set forth in that section;
and (3) the subcommittees meet for the purpose of discussing a particular
matter and, therefore, are nonpermanent and not covered by the definition
of legislative body set forth in Section 54952.5. (See also 61 Ops.Cal.
Atty.Gen. 1 (1978) wherein we concluded that a local agency bargaining
committee designated to meet and confer with representatives of employee
organizations pursuant to Government Code Section 3505 was not a legisla-
tive body within the meaning of Sections 54952, 54952.3, and 54952.5.)
The "less than quorum exception" does not exempt from the provisions
of the Act seriatim meetings of various groups of members of a legislative
body even though each group is composed of less than a quorum of the total
membership. Thus, in Opinion No. 80-713 (63 Ops.Cal.Atty.Gen. 820
-5-
(1980) ) , this office concluded that inasmuch as such seriatim meetings
provide an opportunity for a quorum of the members of the legislative body
to deliberate on a particular matter, the rationale underlying the "less
than quorum exception" is inapposite and the meetings must be open and
public.
C. What is a meeting?
The question as to what constitutes a meeting within the Act sometimes may
present a difficult question. Basically, a meeting is any gathering of a
quorum of a legislative body, no matter how informal, where business is trans-
acted or discussed. (61 Ops.Cal.Atty.Gen. 220 (1978) .) Of course, no problem
exists as to regularly scheduled, duly noticed, regular and special meetings
of a legislative body. The problem arises as to informal meetings of a
majority of the members of a board. Such a meeting may have varying purposes
and characteristics. It is significant to note that the Act itself does not
define the term "meeting."
In a published opinion of this office written in 1963, we expressed the
view that so-called "informal," "study," "discussion," "informational," "fact
finding," or "pre-council" gatherings of a majority of the members of a board
probably fell within the scope of the Act as "meetings," whether or not the
individual members intended to take, or even took, any action at such gather-
ings. (42 Ops.Cal.Atty.Gen. 61 (1963) .)
In 1964 we held that regularly scheduled luncheon meetings by the members
of one or more city councils with representatives of certain civic associa-
tions for the purpose of discussing items, such as school and airport problems
and other items of public importance, fell within the Act. We pointed out,
however, that our opinion was not to be construed to prohibit legislative
bodies from mere social attendance at luncheons and dinners, such as are often
i given by fraternal groups such as the Rotary Club or Kiwanis. (43 Ops.Cal.
Atty.Gen. 36 (1964) ; see also I.L. 71-122.)
The courts have specifically held that the Act now applies to informal
meetings. In Sacramento Newspaper Guild v. Sacramento County Bd. of Suprs.
(1968) 263 Cal.App.2d 41, the court held that a luncheon gathering which
included five county supervisors, the county counsel, county executive, county
director of welfare, and certain union officers to discuss a strike which was
underway against the county was a meeting within the Act and therefore news-
paper reporters were improperly excluded. The court's language at pages 50-51
of the decision is an excellent summary of the reasoning behind its decision.
The court stated:
"In this area of regulation, as well as others, a statute may push
beyond debatable limits in order to block evasive techniques. An informal
conference or caucus permits crystallization of secret decisions to a
point just short of ceremonial acceptance. There is rarely any purpose to
a nonpublic pre meeting conference except to conduct some part of the
decisional process behind closed doors. Only by embracing the collective
inquiry and discussion stages, as well as the ultimate step of official
action, can an open meeting regulation frustrate these evasive devices.
As operative criteria, formality and informality are alien to the law's
design, exposing it to the very evasions it was designed to prevent.
Construed in the light of the Brown Act's objectives, the term 'meeting'
extends to informal sessions or conferences of the board members designed
for the discussion of public business. The Elks Club luncheon, .attended
by the Sacramento County Board of Supervisors, was such a meeting."
-6-
3V
Thus, meetings include informal gatherings where the public's business is
7 discussed, as well as informal meetings.
l A meeting, however, requires the presence of two or more persons. There-
fore, a hearing conducted by a single hearing officer on an employee discipli-
nary action was not a meeting within the meaning of the Act. (Wilson v. San
Francisco Mun. Ry. , supra, 29 Cal.App.3d 870, 880.)
D. Notice of meetings
1. Regular meetings
The legislative body of a local agency must provide by ordinance, resolu-
tion, bylaw, or rule, as appropriate to that body, for the time of holding
regular meetings. (Section 54954.) It may adjourn or continue a meeting
to a time and place specified in a notice of adjournment which is to be
posted within 24 hours on or near the door of the meeting place. If no
time is specified, the meeting is adjourned until the time of the next
regular meeting. (Sections 54955, 54955.1.)
The Act itself contains no agenda requirements for regular meetings.
(Torres v. Board of Commissioners, supra, 89 Cal.App.3d 545.) Such
requirements, however, may be found in the particular act which governs a
particular legislative body, e.g. , Section 25151, relating to posting an
agenda for meetings of boards of supervisors. (61 Ops.Cal.Atty.Gen. 323
(1978) .) Thus, it has been held ". . . That where the subject matter is
sufficiently defined to apprise the public of the matter to be considered
and notice has been given as required by law, the governing body is not
required to give further special notice of what action it might
take . . . ." (Phillips v. Seel (1974) 43 Cal.App.3d 104, 120; see also
{! III, infra, re Education Code Section 35145, and agenda requirements for
school districts.)
2. Special meetings
In order to hold a special meeting, a legislative body must provide
advance notice of such meeting to each member of the legislative body and
to each local newspaper of general circulation, and radio or television
station which has requested notice in writing. The notice shall state the
time and place of the special meeting. It shall also state the business
to be transacted, and no other business shall be considered at the special
meeting. (Section 54956.)
Notice is required even if no action is taken by the legislative body
at the special meeting. (Section 54956; 41 Ops.Cal.Atty.Gen. 61 (1963) .)
It is also required if the special meeting is to be held in executive
session. (43 Ops.Cal.Atty.Gen. 79 (1964) .) If a legislative body holds
an informal meeting falling within the scope of the Act, such as a
luncheon meeting, notice must be given. For example, if a city council
attends a luncheon meeting to discuss area problems with a civic group,
the public has a right to know of and attend such discussions. (43 Ops.
Cal.Atty.Gen. 36 (1964) .)
The notice required by Section 54956 shall be delivered personally or
by mail and shall be received at least 24 hours before the time of the
meeting. Thus, mailing the notice 24 hours in advance is not sufficient;
notice must actually be received 24 hours prior to the special meeting.
(Section 54956; 53 Ops.Cal.Atty.Gen. 246 (1970) .)
-7-
c
A member of the legislative body may waive failure to receive notice
of the meeting by filing a waiver prior to the time of the meeting or by
being present at the meeting when it convenes. Moreover, absent a written
request therefor, the legislative body is not required by the Act to pro-
vide the media with notice of its special meetings. (62 Ops.Cal.Atty.Gen.
658 (1979) .)
The detailed provisions of the Act as to time and notice of meetings
do not apply to regular or special meetings of advisory commissions, com-
mittees, or bodies of a local agency created by formal action of the leg-
islative body or a member thereof. However, such a group may provide for
regular meetings, and if it does so, it shall provide for the time and
place for holding such regular meetings. (Section 54952.3.)
3. Emergency meetings
In an "emergency situation," the legislative body is not required to
deliver written notice to the news media 24 hours in advance of its spe-
cial meeting. An emergency situation is defined to include a work stop-
page or other activity and a crippling disaster, which severely impairs
public health, safety, or both, as determined by a majority of the members
of the legislative body. In such cases, telephonic notice shall be pro-
vided to local newspapers of general circulation and radio or television
stations one hour prior to the meeting unless telephonic services are not
functioning. In the event that telephonic services are not functioning,
notice must be given as soon after the meeting as possible. The minutes
of the meeting, a list of the persons notified or attempted to be noti-
fied, a copy of a roll call vote, and any actions taken shall be posted
for a minimum of ten days in a public place as soon after the meeting as
possible. The legislative body may not meet in executive session during
an emergency meeting. Except for the 24-hour notice requirement, the spe-
cial meeting requirements set forth in Section 54956 shall apply in
emergency meetings. (Section 54956.5.)
4. Special notice provisions - district landowners
^ The legislative body of a district subject to the Act must mail notice of
all regular and special meetings to any district landowner who has filed a
written request for such notice. The request must be renewed annually.
(Section 54954.1.)
The legislative body may impose a reasonable charge for this service
based on estimated costs of providing notice. (Section 54954.1.) Any
estimate by the legislative body which has a reasonable cost accounting
basis would appear acceptable. (62 Ops.Cal.Atty.Gen. 658 (1979) .)
E. Public's rights while attending a meeting
What are the public's rights with regard to attendance at meetings? A member
of the public can attend a meeting without having to register or give other
information as a condition of attendance. (Section 54953.3; see also 27
Ops.Cal.Atty.Gen. 123 (1956) .) A legislative body may not prohibit any person
attending an open meeting from tape-recording the proceedings, absent a rea-
sonable finding that such would constitute a disruption of the proceedings.
(Section 51953.5; Nevens v. City of Chino (1965) 233 Cal.App.2d 775; I.L. 66-
121; cf. 62 Ops.Cal.Atty.Gen. 292 (1979) .)
On the other side of the coin, a legislative body may, if necessary,
exclude all persons from a meeting where a disturbance has been created and
-8-
the meeting cannot continue by merely excluding the disorderly persons. How-
ever, in such situations, newspaper personnel not involved in the disturbance
must be permitted to attend the session as continued. (Section 54957.9.)
Although this office has held that the Act neither explicitly nor implicitly
gives radio stations the right to broadcast meetings of legislative bodies (38
Ops.Cal.Atty.Gen. 52 (1961)) , Government Code Section 6091, enacted in 1965,
conditionally authorizes the broadcasting by radio and television stations of
meetings required by law to be open.
Any agenda or other writing distributed to all or a majority of the mem-
bers of the legislative body of a local agency for the discussion or consider-
ation at a public meeting are public records and shall be made available to
members of the public in accordance with the provisions of Section 54957.5 and
the Public Records Act (Government Code Section 6250 et seq.) . (Section
54957.5; I.L. 77-67.) Pursuant to Government Code Section 6257, a fee or
deposit may be charged to any person requesting a copy of a public record.
(Section 54957.5.)
Except as specifically authorized by the Act, the legislative body of a
local agency may not impose fees to defray its costs in carrying out the pro-
visions of the Act. (Section 54956.6.)
A local agency may not conduct any meeting or function where racial or
other discrimination is practiced. (Section 54961.)
F. Permissible executive sessions
Authority for executive sessions must be found in the explicit terms of the
Act or inferred from some other confidentiality provision in the law. (61
Ops.Cal.Atty.Gen. 220 (1978) .) The Act itself contains several purposes for
which a legislative body may meet in private or in executive session. Addi-
tionally, the courts and this office have held several other situations to
fall within the executive session exception to the open meeting requirements
of the Act.
Prior to or after holding any executive or closed session, the legislative
body of the local agency shall state the general reason or reasons for the
session. The legislative body may also cite the legal authority under which
the closed session is held. The scope of the closed session shall be limited
to matters covered by the legislative body's statement of reasons. The legis-
lative body is neither authorized nor required to include in its statement of
reasons information which could constitute an invasion of privacy or otherwise .
unnecessarily divulge particular facts concerning the closed session. (Sec-
tion 54957.7.)
1. Expressly authorized executive sessions
a. Personnel exception
The Act provides in Section 54957 for executive sessions to consider
the appointment, employment, or dismissal of a "public employee" as
defined by the Act or to hear complaints and charges against such
"public employee." This exception is commonly known as the "personnel
exception." An employee may request and require a public hearing
where the purpose of the executive session is to discuss specific
charges or complaints against him or her. A general discussion of an
employee's job performance may, however, be held in executive session
irrespective of the employee's desires. (61 Ops.Cal.Atty.Gen. 283
(1978) .)
-9-
�n
We have held that "public employee" as del ed by the Act does not
include anyone elected or appointed to an el.--ctive office; that the
definition contemplates only "nonelective off,- ers" insofar as it may
include officers. (59 Ops.Cal.Atty.Gen. 26f. (1976) .) Moreover,
mayors, chairpersons of boards of supervisor::, and other presiding
officers, although receiving separate appoints-iients to their presiding
offices, are not employees within the meaning of Section 54957.
,.-. Therefore, complaints against such presiding officers may not be dis-
cussed in an executive session. (61 Ops.Cal.Atty.Gen. 10 (1978) .)
Presently the legislative body must report at its next subsequent
public meeting any action taken during its closed session, and the
roll call vote thereon, to appoint, employ, or dismiss an employee.
Effective January 1, 1981, the legislative body must render its report
at the public meeting during which the executive session is held or at
the next subsequent public meeting. (Section 54957.1.) This report-
ing requirement applies to all legislative bodies irrespective of
whether they are otherwise required to act by roll call vote. (59
Ops.Cal.Atty.Gen. 619 (1976) .) However, the requirement has been con-
strued to apply only to actions to "appoint," "employ," or "dismiss."
Accordingly, an action to establish the compensation of a hospital
administrator need not be reported at the next subsequent public meet-
ing of the legislative body. (63 Ops.Cal.Atty.Gen. 215 (1980) .)
The personnel exception is probably the most widely used permitted
executive session device. This office has opined that the primary
purpose of the exception is to avoid undue publicity and embarrassment
to the affected employee and that an ancillary purpose of the excep-
tion is to encourage the free discussion of personnel matters by the
legislative body. (63 Ops.Cal.Atty.Gen. 215 (1980) ; 61 Ops.Cal.Atty.
Gen. 283 (1978) ; 59 Ops.Cal.Atty.Gen. 532 (1976) .) Examples of its
application may be helpful to demonstrate that in addition to actual
hiring and firing, it has a legitimate intermediate scope.
i. In Cozzolino v. City of Fontana (1955) 136 Cal.App.2d 608, the
court upheld a closed hearing to consider the propriety of a past
firing by the chief of police, and to ratify such action.
ii. In Letsch v. Northern San Diego County Hosp. Dist. (1966) 246
Cal.App.2d 673, the court held that a decision to terminate the
contract of the hospital radiologist, who was apparently an inde-
pendent contractor, taken after an executive session was held
discussing the radiologist's qualifications, was proper, and the
discussions fell within the personnel exception.
iii. In Lucas v. Board of Trustees (1970) 18 Cal.App.3d 990, s
decision not to rehire the district superintendent of a high
school district was held to be properly made in executive session.
Also, in 59 Ops.Cal.Atty.Gen. 532 (1976) , this office upheld the
use of an executive session by a school district governing board
to discuss and evaluate the performance of its superintendent.
iv. In 61 Ops.Cal.Atty.Gen. 283 (1978) and in several letter
opinions of this office, it was held that the personnel exception
could be used to discuss the salaries of individual employees as
opposed to discussing salary scales in general. Thus, in I.L_
66-184, we took the view that it was proper under the personnel
exception to discuss in private the salary of the manager of a
special district, and the discussions could include his work
-10-
0) 0 '41 4) 1 w C 0 1rol •4 cwN IA1 >, • vN 'o1W >, Ot +JC >, rovwl • 10 4
3 +J '4-H > W 0 U +J N 0 0 0 0 to 0 0 0+ to 43 u > 41 0 0)H C: 0 0 � 4) 0 m 4)
ro u H v 4) a) v
> •.4 -H 'a •.+ p, A u p X C •4 C ••+ C•H ••+ N
•ro •HyroCC0)0 41Ad04r-4a) 0 Nyaa N3a� 0 +1 0 � N C to (a rl > NUw03
r u w ro a a 3 C N w a ••+ N v ro 1 >1••+ ro N '-1 JJ > a N U a •+ v CO 4 N
,1 ro 0 C U w .I ro •.1 R1 u c 1J y.� .1 0+ N U +J•1 ro U v.,t roto N w .�1 p, .CI0�4 W e
j °p % ° 'v1 r 0 ''I rci .,cj 3 b [ N p a •vl 0 . aCi•�H JJ C y AO 1 w w . ro u to
NOVUAORI UE U A � NQ+WQ+ U •.� C Id vX ccc > U
v ,4MV Arov N vN4) ro0vb wp A tOCv ror40 ' roc'
0 N to u b u v y 0) .,>j u U J: N •.I 0+.-1 y•ra .,a v 4J c
8u roQ, NNv v roAv c y0 ++ aw .� 0 N .> y r .� &+•4 .a >.
acidv u••+ a.0 U3 � >, ^' a a UVUroUCCv ,� w . yam, „ `" w vvv ..+ auy
HUw 00, w01to 4
0r-I wcC U 0W7 H � vOv NOduUi � � ° w ••N+ c � � M �kro
v ..aua w pip, W % wa AroAAA uU > yC vv Cp u
H '° vccxa0ua ° rod v ro vuw crnvrow ^frosv �, u, cc' $' °; u � uc
A .14 yJ J: v A y w •,4 C v 0 ^ v C C+ c p y a 0 U U
u41vro OtN ro � ONUU .ac ^4cW .,� ^ vmx0 � to
0 A ,� a v c Q �+ N >,r 0 C •ri 0 00 0 v +J u U) ro
w u JJ 0 0 0 >+ C b 41 C a j w w � V to y u u ro � �J � U ro U v u � � 3 y N 3 M w
o y � yAw c 43 0 v 1, v U ` uv N cw ��>p40ON etc G ''' vUj � vrn v Uro y U C1 C
y ,4 U p 'p w v • y�J G 3 v G>') a to C C ro O v R c y ^ v > C C Z a z a 0
0 N 0 w ° 0 o ro x a C c C 0 O c A > F uri b d . ° " p .0 p, ro 0 0 u U
y N C N 0 ..1 N co v Ww to ° u N 0 U) U b H u >01 1 ^W N M b 'W ' 1J ro
41
in w
�AwtA,>ayb>�J� a3Gba04$gcii cv°•W.0�1 yN,Co1J U �� d r M,vCC WuO cro N c � �Ail��rvcl vroroCC aa y �+ >•��Abb s>r ° utU AC4 % >a croy A"�c4a•,4 'i 4) A 0 c CN r4 cv m -4 .0•ro� �roaC
aC• uU
ro•Ja.rC��J♦
•roA.b
0 a v „
r 4J > -A 0 U N > 41 •,4 J J •-I
w 4J 4) u �4 " a!'I Wpo a) jA 1J „ 4j 4)
O to
to C [ � � °- � � �
c 4) U � a . rn J m
ro .14 41C N + �0 �� V) N yu 4) y b yO to
Q . U Q) A ,4 % pt u 3 aW >4
w I N W4) C (0 ° N uuA ° -N ° ro 0 N C W u U yJ N 4J N•A 0•
v U � G W J u
U) 4)rgro u -I w i -A •,♦ 0 X y °� u Q ► w ° � � � � A a
ew •i uJro -i 0) N 'o u U Ny 41 U 4) 4) a V 4J (0 ro c 1J •av • 1 � ro o > u"q o 3U v0 R.4 > C � ca 0a yu (a • cN0
CA UVA � ^ uv0 rO yJyro0uv arow
H > 0w °° � UOvauUH uw VE >1 0H va • °
A . p 04J C w '14
' ao X ro y N N al•r♦ p ,, . yJ O In U•a y p y N ro W uI U C1 N W M X 4J a r4 r-1 ro > j 1JW - ) > rn J 1J W 'w4) •'4Ja J 1 ^� c v•-H U) +W u . • 1 U roN [
� >yCO . � � > NN '� y v u0 >r - ro C c N yJ
W X 0 fal ro to° N > 0 OO 0 V : U �G1 u a N N N A c a N 0a � W 0
J 4) aJ O
0 0 N 0 p' >r 4) 41 u N V H w 0) N C N C O u
u wUoU ra 0 0 y c 0aN pH 1,4 v >' 0
N A b 0 c Ui 0 .14 . p u -r4 . N N +j ko V 0) (a 0O ° 'o u •0 ' N N
d b � 0CN 41 3c > w U0 vjro j ° UyC
p �0 •i >r O0M '0 + +Ju0 4r, -H0, 414 wu2Wro
0 (0 WN N py ' 41 1 %croA U - 5 u >, 0 4J >+ rq 3 N }J UvJ
0 0 W u W r4 41 41 iJA a 0 G) 4J C U N kro
u rov0curo .4 HM U a 0 toro vo � A Ci
•a JJ u a �o Ca 0 � C riOCON00CN
4) rq > M J v JO U.aO + C! • p C > 0 Q) 10 ro 1j O Ur •4
N H 2 C to > 4 y 1J •,� JJ +J GJ
c tl C fo uw � a y A ,44jA (aH " AvxC ' auCai Hv u > miirooro u 04 0oo 41 Hc4j • aO, 0
Cri
t
�I
Z a C r-I•d Q) rl C yJ U >1•,4 ro N 10 4 -H a) 1J (0r-1 -4 4) C Ai . 1J (aU GUl ,4 0 C ,vC H 0 0) m 0 4) a) rto - 0 0 X a a) • ro %"4 A v 4 c� A N
A N 304 u H +J v +J � �-Aro N •'i 3 C a v E u H rota v 3 +J � � +J v
N
�Q
This office has r4led that the attdfney-client privilege is broad
enough to permit a legislative body to meet in executive session with /
its legal advisor to discuss "potential" litigation so long as it
relates to an existent set of concrete facts and circumstances, and
thus, litigation need not be pending not imminent to give rise to the
privilege. (I.L. 75-282.) In such letter opinion it was also held
that the Act does not require the legislative body to state who may be
�-- involved in such potential litigation before it may meet in executive
session. However, an executive session is justified on the basis of
the attorney-client privilege only if the statutory prerequisites to
the establishing of such a privilege are satisfied. Thus, this office
has concluded that discussions between adversary public agencies and
their attorneys concerning the settlement of potential litigation are
not confidential communications protected by the attorney-client priv-
ilege and, therefore, are not properly conducted during executive
sessions. (62 Ops.Cal.Atty.Gen. 150 (1979) .)
b. Other privilege and confidentiality provisions
Other privilege and confidentiality provisions which may, depending
upon the facts of the particular case, justify the holding of an exe-
cutive session include (1) the "official information privilege"
(Evidence Code Section 1040) which protects certain confidential
information acquired by public employees and (2) the exceptions to the
California Public Records Act found in Sections 6254 and 6255. It
would appear appropriate to discuss matters protected by these stat-
utes during executive session. (62 Ops.Cal.Atty.Gen. 150 (1979) ; 61
Ops.Cal.Atty.Gen. 220 (1978) .)
Absent express authority or an independent confidentiality provi-
sion from which authority for an executive session may be inferred,
meetings of legislative bodies must be open and public. Thus, in 61
Ops.Cal.Atty.Gen. 220 (1978) , we concluded that meetings of the Board
of Police Commissioners could not, as a general proposition, be held
in executive session, even though the matters to be discussed were
deemed sensitive by the commission and their disclosure considered
contrary to the public interest. This office has also concluded that
Evidence Code Section 1152, which renders inadmissible for the purpose
of proving liability evidence of the conduct or statements of a liti-
gant during settlement negotiations, does not authorize the holding of
an executive session for the purpose of conducting settlement negotia-
tions. Section 1152 has as its purpose the fostering of settlements
of disputes rather than the protecting of confidential communications.
(62 Ops.Cal.Atty.Gen. 150 (1979) .)
This office also has refused to imply an exception to the open
meeting requirements of the Act for "quasi-judicial" matters_ Thus,
we held that county boards of education could not meet in executive
session to deliberate when deciding appeals from decisions of local
school district boards refusing to enter into interdistrict attendance
agreements_ (See 57 Ops.Cal.Atty.Gen. 189 (1974) ; see also I.L. 71-
198 and Z.L. 70-213, deliberations of county air pollution control
district board after public hearing on appeals must also be held in
public.)
3. Time for executive sessions and required notice
The Act provides that executive sessions for personnel matters are to be
held only during a regular or special meeting. (Section 54957.) Thus, in
-12-
43 Ops.Cal.Atty.Gen. 79 (1964) , this office held that the requisite spe-
cial meeting notice was required to hold an executive session as to
whether to retain an incumbent school principal. Interesting, however, is
the decision in Lucas v. Board of Trustees, supra, 18 Cal.App.3d 990, in
which the court held that the school board need not publish a detailed
agenda of matters to be considered at executive sessions which were to be
held as part of, but apart from, a regular meeting. The rationale was
that such would negate the purpose of the executive session in personnel
matters; that is, to avoid undue publicity and embarrassment to the
officer or employee. The court relied for such rationale on a prior opin-
ion of this office, 33 Ops.Cal.Atty.Gen. 32 (1959) . We note, however,
that the employee himself was notified beforehand that his contract would
be considered at such sessions.
4. Minute book
The legislative body may designate, by ordinance or resolution, an officer
or employee of the local agency who shall attend each executive session
and maintain a minute book, which may consist of a recording of the execu-
tive session. The minute book is confidential and shall only be available
to members of the legislative body and, in litigation involving an alleged
violation of the Act during an executive session, to a local court of
general jurisdiction. (Section 54957.2.) Neither the executive session
minutes nor the information which they memorialize may be released by the
legislative body or any of its members. (I.L. 76-201.)
The recording of executive sessions is authorized by Section 54957.2
only to the extent that such recording is done in a manner which does not
violate the provisions of Penal Code Section 632. Thus, Section 54957.2
does not constitute a defense to criminal liability for recording confi-
dential communications without the consent, or at least knowledge, of the
parties. (62 Ops.Cal.Atty.Gen. 292 (1979) .)
5. Miscellaneous considerations regarding executive sessions
Though the Act speaks in terms of "considering" personnel matters, there
is no doubt that absent a provision in another code (such as the Education
Code to be discussed later) , to "consider" in executive session also
includes the ability to act in executive session. The legislative body
need not return to the open meeting before voting or taking action.
(Krausen v. Solano County Junior College Dist. (1974) 42 Cal.App.3d 394,
404; Lucas v. Board of Trustees, supra, 18 Cal.App.3d 990.) Thus, in .I.L.
61-85, we held that "consider" included the right to dismiss an officer or
employee in executive session, reserving to the officer or employee, how-
ever, his statutory right to request a public hearing.
The executive session is precisely what the term indicates and does
not include a semi-executive session. Neither members of the press nor
any other members of the public may be admitted as spectators to executive
sessions held pursuant to the Act. (46 Ops.Cal.Atty.Gen. 34 (1965) .) Nor
would it be proper for an investigative committee of a grand jury perform-
ing its duties of investigating the county's business to be admitted to an
executive session. (I.L. 70-184.) In both the foregoing examples, the
proceedings of the executive session would in due course be disclosed by
such third parties, thus negating the whole purpose of the executive ses-
sions; that is, required secrecy in limited circumstances. This office,
however, has held that a county board of supervisors may attend a closed
-13-
b�
session of a county grand jury which is held in the exercise of the grand
jury's own investigative powers without violating the Act. (58 Ops.Cal.
Atty.Gen. 829 (1975).) In 1979 the Act was amended to explicitly
authorize members of a legislative body of a local agency to testify in
private before a grand jury, either as individuals or as a body. (Section
54353.1.)
Finally, and of importance to an individual who may be the object of
disciplinary action at an executive session, failure of the officer or
employee to request a public hearing, as permitted by the Act, does not
amount to a failure to exhaust his administrative remedies as a condition
to attacking such disciplinary action in court. Thus, in Ball v. City
Council (1967) 252 Cal.App.2d 136, the court held that a police chief who
was fired for engaging in union activities was not foreclosed from
appealing such firing in court merely because he failed to request that
the matter of his firing be considered publicly rather than in private.
The Act itself does not grant a quasi-judicial-type hearing. The police
chief was an at-pleasure appointee, and no special administrative hearing
was prescribed for such personnel action.
G. Penalties for violation of the act
The Act, in Section 54959, provides that a member of a legislative body who
attends a meeting where action is taken in violation of the Act, and with
knowledge that the meeting violates the Act, is guilty of a misdemeanor. .
The term "action taken" includes a collective decision, commitment, or
promise by a majority of the members of a legislative body. (Section
54952.6.) It is the participation of a majority of the members of the legis-
lative body, rather than the outcome of any vote taken or the manner in which
members of the majority vote, that gives rise to criminal liability. (I.L.
78-84.) That the collective decision is tentative rather than final does not
shield knowing participants from criminal liability. (61 Ops.Cal.Atty.Gen.
283 (1978) .) However, if there is deliberation without action, the criminal
penalty is not applicable and only civil proceedings are available. (Sacra-
mento Newspaper Guild v. Sacramento County Bd. of Suprs., supra, 263 Cal.App.
2d 41.)
There must be not only a volitional act constituting a violation, but also
an act which is done with knowledge that it is illegal. Good faith reliance
on the opinion of counsel that a nonpublic meeting is proper would normally
preclude the finding of a "knowing" violation of the Act. (I.L. 76-173.) The
determination as to whether there is sufficient evidence that members of a
legislative body who have taken action at an illegal meeting in violation of
the Act have done so knowingly must be made, in the first instance, by the
district attorney or other local appropriate prosecuting attorney in light of
all the facts. (I.L. 67-147.) In this regard, it is of interest that effec-
tive January 1, 1981, a legislative body of a local agency may require that a
copy of the Ralph M. Brown Act be given to each of its members. (Section
54952.7.)
Although the Act itself only provides that a known violation is a misde-
meanor if action is taken, under some circumstances a violation may also be a
felony. If a conspiracy to commit a misdemeanor occurs, it can be a felony.
(Penal Code Section 182.) There are no court decisions or prior opinions on
this matter, but because meetings usually require the concurrence of more than
one member, it would appear that the possibility that a conspiracy will have
occurred will be present in many instances.
-14-
O.9
H. Enforcement provisions
/ Even if a criminal penalty is not applicable because action has not been
taken, the Act, nevertheless, may be enforced to prevent further or future
violations, as the Act can be enforced by civil action for activities beyond
those covered by the penal provisions. (Sacramento Newspaper Guild .v_ Sacra-
mento County Bd. of Suprs., supra, 263 Cal.App.2d 41, 48.)
If a member of the public or news media believes that the Act has been, is
being, or will be violated, that person's recourse is both informal and
formal. Informally the individual may advise the legislative body or the
attorney for the legislative body of his or her belief or, if appropriate, a
superior governing body of the agency. If such informal action is unavailing,
the individual's recourse is in the courts. The Act provides for court pro-
ceedings by any interested person to prevent violation of the Act or for
determinations as to the applicability of the Act to both past and future con-
duct of the legislative body. (Section 54960.) "Interested. persons" may
include a county or its officers on whose behalf an action may be filed by the
county counsel or, in counties not having a county counsel, the district
attorney. It was not intended, however, that the county counsel or the
district attorney be invested with powers as a civil prosecutor in matters
relating to the Act. (62 Ops.Cal.Atty.Gen. 150 (1979) .)
The court may award attorney fees and court costs to whichever party pre-
vails. (Section 54960.5.)
I. Effect of failure to hold open meeting
Though one might believe that the taking of action by a legislative body in.
secret, when the law requires such action to be taken in an open meeting,
should and would void the action, such is not the case. The courts have con-
sistently stated that the action is still valid. In Stribling v. Mailliard
(1970) 6 Cal.App.3d 470, the court was considering an attack on the San Fran-
cisco police regulation concerning the carrying of guns by off-duty policemen.
As to the plaintiff's contention that the regulation was invalid because
adopted in secret, the court stated, at pages 474-475:
"Appellants allege that the disputed regulation was passed by the
Police Commission secretly. Interested members of the public, it is
alleged were not permitted to express their views. The Ralph M. Brown Act
(Gov. Code 0 54950) is cited as stating the public policy of the state.
But even if we assume that section 54950 applies to the challenged regula-
tion, the regulation would not be invalidated. (Old Town Dev. Corp. v.
Urban Renewal Agency, 249 Cal.App.2d 313 [57 Cal.Rptr. 426]; Claremont
Taxpayers Assn. v. City of Claremont, 223 Cal.App.2d 589, 593-594 [35
Cal.Rptr. 907] ; Adler v. City Council, 184 Cal.App.2d 763, 774-775 [7 Cal.
Rptr. 8051.) (Some of the effects of the Adler case were removed by leg-
islation, but the proposal to make void any action taken at nonpublic
meetings was objected to by the Governor and was eliminated from the pro-
posed amendment to the statute. See 42 Ops.Cal.Atty.Gen. 61, 66.) "
(See also: Morris v. County of Marin (1977) 18 Cal.3d 901, 908-909, note
4; Griswold v. Mt. Diablo Unified Sch. Dist. (1976) 63 Cal.App.3d 648;
Greer v. Board of Education (1975) 47 Cal.App.3d 98.) For a similar con-
clusion regarding the validity of an action taken in violation of the
State Agency Act, see American Petroleum Institute v. Knecht. (C.D.Cal.
1978) 456 F.Supp. 889, 913-914, affirmed (9th Cir. 1979) 609 F.2d 889..
-15-
III. SPECIAL CONSIDERATIONS RELATING TO SCHOOL DI4TRICTS
One local agency of great public interest is the governing body of a school `.
district. There are a few special rules which should be pointed out are
applicable to school districts as opposed to local agencies generally. These
are additional to the Ralph M. Brown Act.
.- 1. Under the circumstances delineated by statute, school districts may hold
executive sessions to consider the suspension of or other disciplinary action
as to any pupil, with the right of the pupil or his parent or guardian to
request a public hearing. (Education Code Sections 35146 and 48914 (c) .)
2. As to such disciplinary action, the board may not take final action in
executive sessions, but must do so in a public meeting. (Education Code Sec-
tions 35146 and 48914 (g) ; see also: 44 Ops.Cal.Atty.Gen. 147 (1964) ; I.L.
61-93.)
3. A list of all agenda items for all regular meetings must be posted where
parents and teachers may see them at least 48 hours in advance of regular
meetings and 24 hours in advance of special meetings. (Education Code Section
35145.) Failure to post an agenda item will apparently void the action on
such item. In Carlson v. Pasadena Unified Sch. Dist. (1971) 18 Cal.App.3d
196, the court held that an injunction was proper to prevent the closure of a
school where the agenda item as to such school said nothing concerning closing
it, but merely stated that a proposed school site change would be considered.
It should be noted, however, that Government Code Section 54957, which author-
izes executive sessions on personnel matters, provides an exception to the
open meeting and posted agenda requirements of Education Code Section 35145.5.
i Thus, a governing board may consider personnel matters in executive session_
without posting a detailed agenda specifying the matters to be discussed.
(Campbell Elementary Teachers Assn., Inc. v. Abbott (1978) 76 Cal.App.3d 796;
Lucas v. Board of Trustees, supra, 18 Cal.App.3d 990.)
4. The school district governing board shall adopt reasonable regulations to
insure that members of the public are able to (1) place matters directly
related to school district business on the agenda of the governing board
meetings and (2) address the board regarding items on the agenda. (Education
Code Section 35145.5.)
-16-
/ IV. THE STATE AGENCY ACT
The Ralph M. Brown Act is by its terms not applicable to state agencies, but
only local agencies. However, in the past the Attorney General has on occa-
sion advised agencies which held regular meetings to follow the outline of the
Act as a matter of policy. (See: I.L. 66-21; I.L. 64-167; I.L. 64-69.) Since
1967 the state has had an act of general applicability to state boards and
commissions which are required by law to conduct official meetings. Effective
January 1, 1981, the State Agency Open Meeting Act also applies to (1) commis-
sions created by executive order, (2) multimember bodies on which a member of
a state agency sits in his or her official capacity and which are supported in
whole or in part by funds of the state agency or any of its members, and (3)
advisory bodies of three or more persons which are created by formal action of
a state agency. (Sections 11121, 11121.7.)
The State Act does not apply to agencies whose meetings are required to be
open and public by the Brown- Act. (Torres v. Board of Commissioners, supra,
89 Cal.App.3d 545.) Agencies which are adjuncts of the court system, such as
the Commission on Judicial Qualifications or the Judicial Council, and also
agencies specifically exempted by law are excepted. As already noted, there
are special provisions applicable to the Legislature, and the Regents of the
University of California, which are set forth in the Appendix herein.
The state agency law is similar in many respects to the Ralph M. Brown
Act; but in other respects is different, necessarily recognizing the differ-
ence in functions performed by the state as opposed to local agencies.
Some of the significant differences are:
1. The state law provides approximately a dozen additional statutory pro-
visions for the holding of executive sessions tailored to the orderly
functions of such agencies. For example, it provides:
a) Executive sessions for quasi-judicial determinations made by admin-
istrative agencies after an evidentiary hearing,
b) Executive sessions for the Franchise Tax Board to discuss confiden-
tial tax returns, as well as matters pertaining to the appointment or
r removal of the executive officer of the Franchise Tax Board,
c) Executive sessions for the selection of sites for state colleges,
and
d) Executive sessions for the California Postsecondary Education Com-
mission to consider matters pertaining to the appointment or termina-
tion of its director.
For these and other situations, Section 11126 of the Government Code
should be consulted.
2. The state law contains specific agenda requirements. (Sections 11125
and 11125.1; see also: American Petroleum Institute v. Knecht, supra, 456
F.Supp. 889, 912-914, affirmed (9th Cir. 1979) 609 F.2d 889.)
3. The state law provides that a state agency shall designate an employee
who shall attend its closed sessions and keep in a minute book a record of
the topics discussed and decisions made at the meeting. (Section 11126.1.)
4. The state law provides that a state agency shall provide a copy of the
State Agency Open Meeting Act to each member of the state agency upon his
or her appointment to membership or on assumption of office. (Section
11121.9.)
-17-
5. The state law provides that prior to holding a closed session, a state
agency shall state the general reason or reasons for the session, as well
as the statutory or other legal authority under which such is being held.
(Section 11126.3.)
6. The state law provides that attendance by a member of a state agency
at a meeting of such agency with knowledge of the fact that the meeting is
in violation of the State Agency Open Meeting Act is a misdemeanor.
(Section 11130.7.)
-18-
V. CONCLUSION
The Office of the Attorney General has attempted herein to outline the provi-
sions of the secret meeting laws applicable to public agencies, primarily the
Ralph M. Brown Act and, to a lesser degree, the act applicable to state
agencies. It is to be again emphasized that this brochure is not to be con-
sidered a definitive statement of the law, but is prepared and furnished for
informational purposes for members of the public or lay board members who wish
to gain a general overview of these laws. Specific situations must be deter-
mined on their own facts and circumstances. The officers or attorneys of the
local agency or the district attorney or county counsel of a county are the
appropriate persons to address inquiries regarding the Ralph M. Brown Act, or
a private attorney should be consulted for advice.
l
-19-
APPENDIX
THE RALPH M. BROWN ACT
Government Code Sections 54950 - 54961
s 54950. In enacting this chapter, the Legislature finds and declares that
the public commissions, boards and councils and the other public agencies in
this State exist to aid in the conduct of the people's business. It is the
intent of the law that their actions be taken openly and that their delibera-
tions be conducted openly.
The people of this State do not yield their sovereignty to the agencies
which serve them. The people, in delegating authority, do not give their
public servants the right to decide what is good for the people to know and
what is not good for them to know. The people insist on remaining informed so
that they may retain control over the instruments they have created.
$ 54950.5. This chapter shall be known as the Ralph M. Brown Act.
b 54951. As used in this chapter, "local agency" means a county, city,
whether general law or chartered, city and county, town, school district,
municipal corporation, district, political subdivision, or any board, com-
mission or agency thereof, or other local public agency.
9 54951.1. For the purposes of this chapter, and to the extent not inconsis-
tent with federal law, the term "local agency" shall include all private non-
profit organizations that receive public money to be expended for public
purposes pursuant to the "Economic Opportunity Act of 1964" (P.L. 88-452; 78
Stat. 508) .
$ 54951.7. "Local agency" includes any nonprofit corporation, created by one
or more public agencies, whose board of directors is appointed by such public
agencies and which is formed to acquire, construct, reconstruct, maintain or
operate any public work project.
9 54952. As used in this chapter, "legislative body" means the governing
board, commission, directors or body of a local agency, or any board or com-
mission thereof, and shall include any board, commission, committee, or other
body on which officers of a local agency serve in their official capacity as
members and which is supported in whole or in part by funds provided by such
agency, whether such board, commission, committee or other body is organized
and operated by such local agency or by a private corporation.
9 54952.3. As used in this chapter "legislative body" also includes any advi-
sory commission, advisory committee or advisory body of a local agency,
created by charter, ordinance, resolution, or by any similar formal action of
a governing body or member of such governing body of a local agency.
Meetings of such advisory commissions, committees or bodies concerning
subjects which do not require an examination of facts and data outside the
territory of the local agency shall be held within the territory of the local
agency and shall be open and public, and notice thereof must be delivered per-
sonally or by mail at least 24 hours before the time of such meeting to each
person who has requested, in writing, notice of such meeting.
-20-
If the advisory commission, committee or body elects to provide for the
holding of regular meetings, it shall provide by bylaws, or by whatever other
l rule is utilized by that advisory body for the conduct of its business, for
the time and place for holding such regular meetings. No other notice of
regular meetings is required.
"Legislative body" as defined in this section does not include a committee
composed solely of members of the governing body of a local agency which are
less than a quorum of such governing body.
The provisions of Sections 54954, 54955, 54955.1, and 54956 shall not
apply to meetings under this section.
§S 54952.5. As used in this chapter "legislative body" also includes, but is
not limited to, planning commissions, library boards, recreation commissions,
and other permanent boards or commissions of a local agency.
§S 54952.6. As used in this chapter, "action taken" means a collective deci-
sion made by a majority of the members of a legislative body, a collective
commitment or promise by a majority of the members of a legislative body to
make a positive or a negative decision, or an actual vote by a majority of the
members of a legislative body when sitting as a body or entity, upon a motion,
proposal, resolution, order or ordinance.
S 54952.7. A legislative body of a local agency may require that a copy of
this chapter be given to each member of the legislative body. An elected
legislative body of a local agency may require that a copy of this chapter be
given to each member of each legislative body whose members are appointed by
or under the authority of the elected legislative body.
§S 54953. All meetings of the legislative body of a local agency shall be open
and public, and all persons shall be permitted to attend any meeting of the
legislative body of a local agency, except as otherwise provided in this
chapter.
9 54953.1. The provisions of this chapter shall not be construed- to prohibit
the members of the legislative body of a local agency from giving testimony in
private before a grand jury, either as individuals or as a body.
s� 54953.3. A member of the public shall not be required, as a condition to
attendance at a meeting of a legislative body of a local agency, to register
his name and other information, to complete a questionnaire, or otherwise to
fulfill any condition precedent to his attendance.
S 54953.5. Any person attending an open and public meeting of a legislative
body of a local agency shall have the right to record the proceedings on a
tape recorder in the absence of a reasonable finding of the legislative body
of the local agency that such recording constitutes, or would constitute, a
disruption of the proceedings.
§S 54954. The legislative body of a local agency shall provide, by ordinance,
resolution, by-laws, or by whatever other rule is required for the conduct of
business by that body, the time for holding regular meetings. Unless other-
wise provided for in the act under which the local agency was formed, meetings
i
i
-21-
b�
of the legislative body need not be held within the boundaries of the terri-
tory over which the local agency exercises jurisdiction. If at any time any
regular meeting falls on a holiday, such regular meeting shall be held on the
next business day. If, by reason of fire, flood, earthquake or other emer-
gency, it shall be unsafe to meet in the place designated, the meetings may be
held for the duration of the emergency at such place as is designated by the
presiding officer of the legislative body_
54954.1. The legislative body of any district which is subject to the provi-
sions of this chapter shall give mailed notice of every regular meeting, and
any special meeting which is called at least one week prior to the date set
for the meeting, to any owner of property located within the district who has
filed a written request for such notice with the legislative body. Any mailed
notice required pursuant to this section shall be mailed at least one week
prior to the date set for the meeting to which it applies except that the
legislative body may give such notice as it deems practical of special meet-
ings called less than seven days prior to the date set for the meeting.
Any request for notice filed pursuant to this section shall be valid for
one year from the date on which it is filed unless a renewal request .is filed.
Renewal requests for notice shall be filed within 90 days after January 1 of
each year. Any request for notice, or renewal request, filed pursuant to this
section shall contain a description of the property owned by the person filing
the request. Such description may be in general terms but shall be sufficient
enough to readily identify such property.
The legislative body may establish a reasonable annual charge for sending
such notice based on the estimated cost of providing such a service.
9 54955. The legislative body of a local agency may adjourn any regular,
adjourned regular, special or adjourned special meeting to a time and place C
w specified in the order of adjournment. Less than a quorum may so adjourn from
time to time. If all members are absent from any regular or adjourned regular
meeting the clerk or secretary of the legislative body may declare the meeting
adjourned to a stated time and place and he shall cause a written notice of
the adjournment to be given in the same manner as provided in .Section 54956
for special meetings, unless such notice is waived as provided for special
meetings. A copy of the order or notice of adjournment shall be conspicuously
posted on or near the door of the place where the regular, adjourned regular,
special or adjourned special meeting was held within 24 hours after the time
of the adjournment. When a regular or adjourned regular meeting is adjourned
as provided in this section, the resulting adjourned regular meeting is a
regular meeting for all purposes. When an order of adjournment of any meeting
fails to state the hour at which the adjourned meeting is to be held, it shall
be held at the hour specified for regular meetings by ordinance, resolution,
by law, or other rule.
§ 54955.1. Any hearing being held, or noticed or ordered to be held, by a
legislative body of a local agency at any meeting may by order or notice of
continuance be continued or recontinued to any subsequent meeting of the
legislative body in the same manner and to the same extent set forth in
Section 54955 for the adjournment of meetings; provided, that if the hearing
is continued to a time less than 24 hours after the time specified in the
order or notice of hearing, a copy of the order or notice of continuance of
hearing shall be posted immediately following the meeting at which the order
or declaration of continuance was adopted or made.
-22-
$ 54956. A special meeting may be called at any time by the presiding officer
of the legislative body of a local agency, or by a majority of the members of
the legislative body, by delivering personally or by mail written notice to
each member of the legislative body and to each local newspaper of general
circulation, radio or television station requesting notice in writing. Such
notice shall be delivered personally or by mail and shall be received at least
24 hours before the time of such meeting as specified in the notice. The call
and notice shall specify the time and place of the special meeting and the
business to be transacted. No other business shall be considered at such
meetings by the legislative body. Such written notice may be dispensed with
as to any member who at or prior to the time the meeting convenes files with
the clerk or secretary >f the legislative body a written waiver of notice.
Such waiver may be given by telegram. Such written notice may also be dis-
pensed with as to any member who is actually present at the meeting at the
time it convenes. Notice shall be required pursuant to this section regard-
less of whether any action is taken at the special meeting.
$ 54956.5. In the case of an emergency situation involving matters upon which
prompt action is necessary due to the disruption or threatened disruption of
public facilities, a legislative body may hold a special meeting without com-
plying with the 24-hour notice requirement of Section 54956.
For purposes of this section, "emergency situation" means any of the
followings
(a) Work stoppage or other activity which severely impairs public health,
safety, or both, as determined by a majority of the members of the
legislative body.
(b) Crippling disaster which severely impairs public health, safety, or
\ both, as determined by a majority of the members of the legislative body.
However, each local newspaper of general circulation and radio or televi-
sion station which has requested notice of special meetings pursuant to Sec-
tion 54956 shall be notified by the presiding officer of the legislative body,
or designee thereof, one hour prior to the special meeting by telephone and
shall exhaust all telephone numbers provided- in the most recent request of
such newspaper or station for notification of special meetings. In the event
that telephone services are not functioning the notice requirements of this
section shall be deemed waived, and the legislative body, or designee thereof,
shall notify such newspapers, radio stations, or television stations of the
fact of the holding of the special meeting, the purpose of the meeting, and
any action taken at the meeting as soon after the meeting as possible.
Notwithstanding the provisions of Section 54957, the legislative body
shall not meet in executive session during a meeting called pursuant to this
section.
All special meeting requirements, as prescribed in Section 54956 shall be
applicable to a meeting called pursuant to this section, with the exception of
the 24-hour notice requirement.
The minutes of a meeting called pursuant to this section, a list of per-
sons who the presiding officer of the legislative body, or designee thereof,
notified or attempted to notify, a copy of the roll call vote, and any actions
taken at such meeting shall be posted for a minimum of 10 days in a public
place as soon after the meeting as possible.
-23-
54956.6. No fees may be charged by the legislative body of a local agency
for carrying out any provision of this chapter, except as specifically author-
ized by this chapter.
SS 54957. Nothing contained in this chapter shall be construed to prevent the
legislative body of a local agency from holding closed sessions with the
Attorney General, district attorney, sheriff, or chief of police, or their
respective deputies, on matters posing a threat to the security of public
buildings or a threat to the public's right of access to public services- or
public facilities, or from holding closed sessions during a regular or special
meeting to consider the appointment, employment or dismissal of a public
employee or to hear complaints or charges brought against such employee by
another person or employee unless such employee requests a public hearing.
The legislative body also may exclude from any such public or closed meeting,
during the examination of a witness, any or all other witnesses in the matter
being investigated by the legislative body.
For the purposes of this section, the term "employee" shall not include
any person elected to office, or appointed to an office by the legislative
body of a local agency; provided, however, that nonelective positions of city
manager, county administrator, city attorney, county counsel, or a department
head or other similar administrative officer of a local agency shall be con-
sidered employee positions; and provided, further that nonelective positions
of general manager, chief engineer, legal counsel, district secretary, audi-
tor, assessor, treasurer or tax collector of any governmental district supply-
ing services within limited boundaries shall be deemed employee positions.
Nothing in this chapter shall be construed to prevent any board, commis-
sion, committee, or other body organized and operated by any private organiza-
tion as defined in Section 54952 from holding closed sessions to consider (a)
matters affecting the national security, or (b) the appointment, employment or
dismissal of an employee or to hear complaints or charges brought against such
E employee by another person or employee unless such employee requests a public
hearing. Such body also may exclude from any such public or closed meeting,
during the examination of a witness, any or all other witnesses in the matter
being investigated by the legislative body.
-9 54957.1. The legislative body of any local agency shall publicly report at
the public meeting during which the closed session is held or at its next
public meeting any action taken, and any roll call vote thereon, to appoint,
employ, or dismiss a public employee arising out of any closed session of the
legislative body.
5 54957.2. (a) The legislative body of a local agency may, by ordinance or
resolution, designate a clerk or other officer or employee of the local agency
who shall then attend each closed session of the legislative body and keep and
enter in a minute book a record of topics discussed and decisions made at the
meeting. The minute book made pursuant to this section is not a public record
subject to inspection pursuant to the California Public Records Act (Chapter
3.5 (commencing with Section 6250) of Division 7 of Title 1) , and shall be
kept confidential. The minute book shall be available only to members of the
legislative body or, if a violation of this chapter is alleged to have
occurred at a closed session, to a court of general jurisdiction wherein the
local agency lies. Such minute book may, but need not, consist_ of a recording
of the closed session.
-24-
(b) An elected legislative body of a local agency may require that each
( legislative body all of whose members are appointed by or under the authority
of the elected legislative body keep a minute book as prescribed under sub-
division (a) .
SS 54957.5. (a) Notwithstanding Section 6255 or any other provisions of law,
agendas of public meetings and other writings, when distributed to all, or a
majority of all, of the members of a legislative body of a local agency by a
member, officer, employee, or agent of such body for discussion or considera-
tion at a public meeting of such body, are public records under the Public
Records Act (Chapter 3.5 (commencing with Section 6250) of Division 7 of Title
1) as soon as distributed, and shall be made available pursuant to Sections
6253 and 6256. However, this section shall not include any writing exempt .
from public disclosure under Section 6253.5, 6254, or 6254.7.
(b) Writings which are public records under subdivision (a) and which are
distributed prior to commencement of a public meeting shall be made available
for public inspection upon request prior to commencement of such meeting.
(c) Writings which are public records under subdivision (a) and which are
distributed during a public meeting and prior to commencement of their discus-
sion at such meeting shall be made available for public inspection prior to
commencement of, and during, their discussion at such meeting.
(d) Writings which are public records under subdivision (a) and which
are distributed during their discussion at a public meeting shall be made
available for public inspection immediately or as soon thereafter as is
practicable.
(e) Nothing in this section shall be construed to prevent the legislative
C- body of a local agency from charging a fee or deposit for a copy of a public
record pursuant to Section 6257. The writings described in subdivisions (b) ,
(c) , and (d) are subject to the requirements of the California Public Records
Act (Chapter 3.5 (commencing with Section 6250) , Division 7, Title 1) , and
subdivisions (b) , (c) , and (d) shall not be construed to exempt from public
inspection any record covered by that act, or to limit the public's right to
.� inspect any record required to be disclosed by that act. This section shall
not apply to any writings properly discussed in a closed session of. the .legis--
lative body of-the local agency.
(f) "Writing" for purposes of this section means "writing" as defined
under Section 6252.
9 54957.6. Notwithstanding any other provision of law, a legislative body of
a local agency may hold closed sessions with its designated representatives
prior to and during consultations and discussions with representatives of.
employee organizations regarding the salaries, salary schedules, or compensa-
tion paid in the form of fringe benefits of employees in order to review its
position and instruct its designated representatives. For the purposes enu-.
merated in the preceding sentence, a legislative body of a local agency may
also meet with a state conciliator who has intervened in the proceedings.
§ 54957.7. Prior to or after holding any closed session, the legislative body
of the local agency shall state the general reason or reasons for the closed
session, and may cite the statutory or other legal authority under which the
session is being held. In the closed session, the legislative body may con-
sider only those matters covered in its statement. In the case of special,
adjourned, and continued meetings, the statement shall be made as part of the
-25-
notice provided for the special, adjourned, or continued meeting. Nothing in
this section shall require or authorize the giving of names or other informa-
tion which would constitute an invasion of privacy or otherwise unnecessarily
divulge the particular facts concerning the closed session.
ss 54957.9. In the event that any meeting is willfully interrupted by a group
or groups of persons so as to render the orderly conduct of such meeting
unfeasible and order cannot be restored by the removal of individuals who
are willfully interrupting the meeting, the members of the legislative body
conducting the meeting may order the meeting room cleared and continue in
session. Only matters appearing on the agenda may be considered in such a
session. Duly accredited representatives of the press or other news media,
except those participating in the disturbance, shall be allowed to attend any
session held pursuant to this section. Nothing in this section shall prohibit
the legislative body from establishing a procedure for readmitting an indivi-
dual or individuals not responsible for willfully disturbing the orderly con-
duct of the meeting.
$ 54958. The provisions of this chapter shall apply to the legislative body
of every local agency notwithstanding the conflicting provisions of any other
state law.
5 54959. Each member of a legislative body who attends a meeting of such
legislative body where action is taken in violation of any provision of this
chapter, with knowledge of the fact that the meeting is in violation thereof,
is guilty of a misdemeanor.
Ss 54960. Any interested person may commence an action by mandamus injunction
k or declaratory relief for the purpose of stopping or preventing violations or
threatened violations of this chapter by members of the legislative body of a
local agency or to determine the applicability of this chapter to actions or
threatened future action of the legislative body.
S 54960.5. A court may award court costs and reasonable attorney fees to the
plaintiff in an action brought pursuant to Section 54960 where it is found
that the local agency has violated the provisions of this article. Such costs
and fees shall be paid by the local agency and shall not become a personal
liability of any public officer or employee thereof.
A court may award court costs and reasonable attorney fees to a defendant
in any action brought pursuant to Section 54960 where the defendant has pre-
vailed in a final determination of such action and the court finds that the
action was clearly frivolous and totally lacking in merit.
R 54961. No local agency shall conduct any meeting, conference, or other
function in any facility that prohibits the admittance of any person, or per-
sons, on the basis of race, religious creed, color, national origin, ancestry,
or sex. This section shall apply to every local agency as defined in Section
54951.
-26-
qv
THE STATE AGENCY ACT
( Government Code Sections 11120-11131
$ 11120. It is the public policy of this state that public agencies exist to
aid in the conduct of the people's business and the proceedings of public
agencies be conducted openly so that the public may remain informed.
In enacting this article the Legislature finds and declares that it is the
intent of the law that actions of state agencies be taken openly and that
their deliberation be conducted openly.
This article shall be known and may be cited as the State Agency Open
Meeting Act.
§ 11121. As used in this article "state agency" means every state board, or
commission, or similar multimember body of the state which is required by law
to conduct official meetings and every commission created by executive order,
but does not include state _agencies provided for in Article VI of the
California Constitution nor districts or other local agencies whose meetings
are required to be open to the public pursuant to the provisions of Chapter 9
(commencing with Section 54950) of Part 1 of Division 2 of Title 5 of this
code.
§ 11121.5. Under the provisions of this article, the official student body
organization at any campus of the California State University and Colleges, or
of the California Community Colleges, shall be treated in the same manner as a
state agency.
§ 11121.7. (a) As used in this article, "state agency" also means any board,
commission, committee, or similar multimember body on which a member of a body
which is a state agency pursuant to Section 11121 or 11121.5 serves in his or
her official capacity as a representative of such state agency and which is
supported, in whole or in part, by funds provided by the state agency, whether
such body is organized and operated by the state agency or by a private cor-
poration.
(b) As used in this article, "state agency" also means any advisory board,
advisory commission, advisory committee, advisory subcommittee, or similar
multimember advisory body of a body which is a state agency pursuant to Sec-
tion 11121 or 11121.5 or subdivision (a) of this section, if created by formal
action of the state agency or of any member of the state agency, and if the
advisory body so created consists of three or more members.
(c) Notice of a meeting of a state agency which complies with subdivision
(a) of Section 11125, shall also constitute notice of an advisory body of that
state agency, provided that the business to be discussed by the advisory body
is covered by the agenda of the meeting of the agency, provided the specific
time and place of the advisory body's meeting is announced during the open and
public state agency's meeting, and provided that the advisory body's meeting
is conducted within a reasonable time of, and nearby, the meeting of the state
agency.
(d) The provisions of subdivision (a) of Section 11125 which require a
specific agenda, and the provisions of subdivision (c) of such section shall
not apply to a meeting of a body which is a state agency pursuant to this sec-
tion. However, except as provided with respect to advisory bodies under sub-
division (c) of this section, notice of a meeting of a state agency as defined
by this section shall be required pursuant to subdivision (a) of Section
-27-
11125, and the notice shall include a brief, general description of the busi-
ness to be discussed, and the name, address, and telephone number of a person
who can provide further information prior to the meeting.
(e) A state agency, as defined by subdivision (a) or (b) , may conduct
closed sessions upon the same grounds as a state agency as defined by Section
11121 or Section 11121.5.
$ 11121.9. A copy of this article shall be provided to each member of any
state agency upon his or her appointment to membership or assumption of
office.
§ 11122. As used in this article "action taken" means a collective decision
made by the members of a state agency, a collective commitment or promise by
the members of the state agency to make a positive or negative decision or an
actual vote by the members of a state agency when sitting as a body or entity
upon a motion, proposal, resolution, order or similar action.
�S 11123. All meetings of a state agency shall be open and public and all per-
sons shall be permitted to attend any meeting of a state agency except as
otherwise provided in this article.
ss 11124. A member of the public shall not be required, as a condition to
attendance at a meeting of a state agency, to register his name and other
information, to complete a questionnaire, or otherwise to fulfill any . con-
dition precedent to his attendance.
9 11124.1. Any person attending an open and public meeting of the state
agency shall have the right to record the proceedings on a tape recorder in /
the absence of a reasonable finding of the state agency that such recording
constitutes, or would constitute, a disruption of the proceedings.
9 11125. (a) The state agency shall prepare an agenda for, and provide notice
of, its meeting to any person who requests such notice in writing. Notice
shall be given at least one week in advance of and shall include the agenda
for the meeting, provided that emergency meetings may be held with less than
one week's notice when such meetings are necessary to discuss unforeseen
emergency conditions. The agenda need not include a list of any witnesses
expected to appear at the meeting.
(b) Emergency meetings held for the purpose of adopting emergency regula-
tions pursuant to Section 11421 require no prior notice or agenda, except that
the agency shall make a reasonable effort to contact any persons requesting
notice pursuant to this section or Section 11423, or both.
(c) Notice shall include the items of business to be transacted, and no
item shall be added to the agenda subsequent to the provisions of such notice,
absent unforeseen emergency conditions, as provided in subdivision (a) .
(d) A person may request, and shall be provided, notice pursuant to sub-
division (a) for all meetings of the agency or only for a specific meeting or
meetings. In addition, at the agency's discretion, a person may request, and
may be provided, notice of only those agency meetings at which a particular
subject or subjects specified in the request will be discussed. A request for
notice of more than one meeting of an agency shall be subject to the provi-
sions of Section 14911.
-28-
a �
$ 11125.1. (a) Notwithstanding Section 6255 or any other provisions of law,
agendas of public meetings and other writings, when distributed to all, or a
majority of all, of the members of a state agency by a member, officer,
employee, or agent of such agency for discussion or consideration at a public
meeting of such agency, are public records under the Public Records Act
(Chapter 3.5 (commencing with Section 6250) of Division 7 of Title 1) as soon
as distributed, and shall be made available pursuant to Sections 6253 and
6256. However, this section shall not include any writing exempt from public
�^ disclosure under Section 6253.5, 6254, or 6254.7.
(b) Writings which are public records under subdivision (a) and which are
distributed prior to commencement of a public meeting shall be made available
for public inspection upon request prior to commencement of such meeting.
(c) Writings which are public records under subdivision (a) and which are
distributed during a public meeting and prior to commencement of their discus-
sion at such meeting shall be made available for public inspection prior to
commencement of, and during, their discussion at such meeting.
(d) Writings which are public records under subdivision (a) and which are
distributed during their discussion at a public meeting shall be made
available for public inspection immediately or as soon thereafter as is prac-
ticable.
(e) Nothing in this section shall be construed to prevent a state agency
from charging a fee or deposit for a copy of a public .record pursuant to
Section 6257. The writings described in subdivisions (b) , (c) , and (d) are
subject to the requirements of the California Public Records Act (Chapter 3.5
(commencing with Section 6250) of Division 7 of Title 1) , and shall not be
construed to exempt from public inspection any record required to be disclosed
by that act, or to limit the public's right to inspect any record covered by
that act. This section shall not apply to any writings properly discussed in
a closed session of the state agency. Nothing in this article shall be
construed to require a state agency to place any paid advertisement -or any
other paid notice in any publication.
(f) "Writing" for purposes of this section means "writing" as defined
under Section 6252.
�S 11125.2 Any state agency shall publicly report at a subsequent public
meeting any action taken, and any roll call vote thereon, to appoint, employ,
or dismiss a public employee arising out of any closed session of the state
agency.
9 11126. Nothing contained in this article shall be construed to prevent a
state agency from holding closed sessions during a regular or special meeting
to consider the appointment, employment or dismissal of a public employee or
to hear complaints or charges brought against such employee by another person
or employee unless such employee requests a public hearing. As a condition to
holding a closed session on the complaints or charges to consider disciplinary
action or to consider dismissal such employee shall be given written notice of
his or her right to have a public hearing rather than a closed session, which
notice shall be delivered to the employee personally or by mail at least 24
hours before the time for holding a regular or special meeting. If notice is
not given, any disciplinary or other action taken against any employee at such
closed session shall be null and void. The state agency also may exclude from
any such public or private meeting, during the examination of a witness, any
or all other witnesses in the matter being investigated by the state agency.
Following the public hearing or closed session the agency may deliberate on
the decision to be reached in a closed session.
-29-
For the purposes of this section, the term "employee" shall not include
any person who is elected to, or appointed to a public office by, any state
agency; provided, however, that officers of the California State University
and Colleges who receive compensation for their services other than per diem
and ordinary and necessary expenses shall, when engaged in such capacity, be .
considered employees.
Nothing in this article shall be construed to prevent state agencies.,
which administer the licensing of persons engaging in businesses or profes-
sions, from holding closed sessions to prepare, approve, grade or .administer
examinations.
Nothing in this article shall be construed to prevent an advisory body o£
a state agency which administers the licensing of persons engaged in busi-
nesses or professions from conducting a closed session to discuss matters
which the advisory body has found would constitute an unwarranted invasion of
the privacy of an individual licensee or applicant if discussed in an open
meeting, provided that the advisory body does not include a quorum of the mem-
bers of the state agency it advises. Such matters may include review of an -
applicant's qualifications for licensure and an inquiry specifically related
to the state agency's enforcement program concerning an individual licensee or
applicant where the inquiry occurs prior to the filing of a civil, criminal,
or administrative disciplinary action against the licensee or applicant by the
state agency.
Nothing in this article shall be construed to prohibit a state agency from
holding a closed session to deliberate on a decision to be reached based upon
evidence introduced in a proceeding required to be conducted pursuant to
Chapter 5 (commencing with Section 11500) of Part 1, Division 3, Title 2 of
the Government Code or similar provision of law. Nothing in this article
shall be construed to prevent any state agency from holding a closed session
to consider matters affecting the national security.
Nothing in this article shall be construed to grant a right to enter any
correctional institution or the grounds of a correctional institution where
that right is not otherwise granted by law, nor shall anything in this article
be construed to prevent a state agency from holding a closed session when con-
sidering and acting upon the determination of a term, parole, or release of
any individual or other disposition of an individual case, or if public dis-
closure of the subjects under discussion or consideration is expressly prohib-
ited by statute.
Nothing in this article shall be construed to prevent any closed session
to consider the conferring of honorary degrees, or gifts, donations and
bequests which the donor or proposed donor has requested in writing to be kept
confidential.
Nothing in this article shall be construed to prevent the Alcoholic
Beverage Control Appeals Board from holding a closed session for the purpose
of holding a deliberative conference as provided in Section 11125 of the
Government Code.
Nothing in this article shall be construed to prevent the Trustees of the
California State Colleges from holding closed sessions dealing with site
selection for such state colleges.
Nothing in this article shall be construed to prevent the California
Postsecondary Education Commission from holding closed sessions to consider
matters pertaining to the appointment or termination of the Director of the
California Postsecondary Education Commission.
-30-
"1h
Nothing in this article shall be construed to prevent the Franchise Tax
Board from holding closed sessions for the purpose of discussion of confiden-
tial tax returns or data the public disclosure of which is prohibited by law,
r or from considering matters pertaining to the appointment or removal of the
executive officer of the Franchise Tax Board.
Nothing in this article shall be construed to prevent the Board of Correc-
tions from holding closed sessions when considering reports of crime condi-
tions under the provisions of Section 6027 of the Penal Code.
Nothing in this article shall be construed to prevent the State Air
Resources Board from holding closed sessions when considering the proprietary
specifications and performance data of manufacturers.
Nothing in this article shall be construed to prevent the Board of Admin-
istration of the Public Employees' Retirement System from holding closed ses-
sions when considering investment decisions.
Nothing in this article shall be construed to prevent the Teachers'
Retirement Board of the State Teachers' Retirement System from holding closed
sessions when considering investment decisions.
Nothing in this article shall be construed to prevent the governing body
of a state agency, or such boards, commissions, administrative officers, or
other representatives as may properly be designated by law or by such govern-
ing body, from holding closed sessions with its representatives at any time in
discharging its responsibilities under Chapter 10 (commencing with Section
3500) of Division 4 of Title 1 of this code as such sessions relate to
salaries, salary schedules, or compensation paid in the form of fringe bene-
fits. For the purposes enumerated in the preceding sentence, a state agency
may also meet with a state conciliator who has intervened in the proceedings,
providing that a quorum of the state agency is present. For purposes of this
paragraph, a state agency may not otherwise meet without using a designated
representative, but it may appoint from its membership a member or members to .
act as its designated representative, with whom it may meet in closed session.
Notwithstanding any other provision of law, any meeting of the Public
Utilities Commission at which the rates of entities under the commission's
jurisdiction are changed shall be open and public.
Nothing in this article shall be construed to prevent the Public Utilities
�- Commission from holding closed sessions to deliberate on the institution of
proceedings, disciplinary actions against regulated utilities, or litigation.
Nothing in this article shall be construed to prevent the examining com-
mittee established by the Board of Forestry pursuant to Section 763 of the
Public Resources Code from conducting a closed session to consider discipli-
nary action against an individual professional forester prior to the filing of
an accusation against the forester pursuant to Section 11503.
Nothing in this article shall be construed to prevent an administrative
committee established by the Board of Accountancy pursuant to Section 5020 of
the Business and Professions Code from conducting a closed session to consider
disciplinary action against an individual accountant prior to the filing of an
accusation against the accountant pursuant to Section 11503.
Nothing in this article shall be construed to prevent an examining commit-
tee established by the Board of Accountancy pursuant to Section 5023 of the
Business and Professions Code from conducting a closed hearing to interview an
individual applicant or accountant regarding the applicant's qualifications.
9 11126.1. The state agency shall designate a clerk or other officer or
employee of the state agency, who shall then attend each closed session of the
-31-
state agency and keep and entcr in a minute book a record of topics discussed
and decisions made at the meeting. The minute book made pursuant to this sec-
tion is not a public record subject to inspection pursuant to the California
Public Records Act (Chapter 3.5 (commencing with Section 6250) of Division 7
of Title 1) , and shall be kept confidential. The minute book shall be avail-
able to members of the state agency or , if a violation of this chapter is
alleged to have occurred at a closed session, to a court of general jurisdic-
tion wherein the state agency lies. Such minute book may, but need not, con-
sist of a recording of the closed session.
9 11126.3. Prior to holding any closed session, the state agency shall state
the general reason or reasons for the closed session, and cite the statutory
or other legal authority under which the session is being held. In the closed
session, the state agency may consider only those matters covered in its
statement. The statement shall be made as part of the notice provided for the
meeting. Nothing in this section shall require or authorize the giving of
names or other information which would constitute an invasion of privacy or
otherwise unnecessarily divulge the particular facts concerning the closed
session.
SS 11126.5. In the event that any meeting is willfully interrupted by a group
or groups of persons so as to render the orderly conduct of such meeting
unfeasible and order cannot be restored by the removal of individuals who are
willfully interrupting the meeting, the members of the state agency conducting
the meeting may order the meeting room cleared and continue in session.
Nothing in this section shall prohibit the state agency from establishing a
procedure for readmitting an individual or individuals not responsible for
willfully disturbing the orderly conduct of the meeting. Only matters appear-
ing on the agenda may be considered in such a session. Duly accredited repre-
sentatives of the press or other news media, except those participating in the
disturbance, shall be allowed to attend any session held pursuant to this sec-
tion.
SS 11126.7. No fees may be charged by a state agency for carrying out any pro-
vision of this article, except as specifically authorized pursuant to this
article.
9 11127. The provisions of this article shall apply to every state agency
unless the agency is specifically excepted by law.
9 11128. All closed sessions of a state agency shall be held only during a
regular or special meeting of the agency.
ss 11129. Any hearing being held, or noticed or ordered to be held by a state
agency at any meeting may by order or notice of continuance be continued or
recontinued to any subsequent meeting of the state agency. A copy of the
order or notice of continuance shall be conspicuously posted on or near the
door of the place where the hearing was held within 24 hours after the time of
the continuance; provided, that if the hearing is continued to a time less
than 24 hours after the time specified in the order or notice of hearing, a
copy of the order or notice of continuance of hearing shall be posted imme-
diately following the meeting at which the order or declaration of continuance
was adopted or made.
-32-
SS 11130. Any interested person may commence an action by mandamus, injunc-
tion, or declaratory relief for the purpose of stopping or preventing -
( violations or threatened violations of this article or to determine the
applicability of this article to actions or threatened future action by mem-
bers of the state agency.
9 11130.5. A court may award court costs and reasonable attorney fees to the
plaintiff in an action brought pursuant to Section 11130 where it is found
that a state agency has violated the provisions of this article. Such costs
and fees shall be paid by the state agency and shall not become a personal
liability of any public officer or employee thereof.
A court may award court costs and reasonable attorney fees to a defendant
in any action brought pursuant to Section 11130 where the defendant has pre-
vailed in a final determination of such action and the court finds that the
action was clearly frivolous and totally lacking in merit.
$ 11130.7. Each member of a state agency who attends a meeting of such agency
in violation of any provision of this article, with knowledge of the fact that
the meeting is in 'violation thereof, is guilty of a misdemeanor.
9 11131. No state agency shall conduct any meeting, conference, or other
function in any facility that prohibits the admittance of any person, or per-
sons, on the basis of race, religious creed, color, national origin,, ancestry,
or sex. As used in this section, "state agency" means and . includes every
state office, officer, department, division, bureau, board, council, commis- .
(' sion, or other state agency.
-33-
iDA
EDUCATION CODE
Sections 35145, 35145.5, 35146
5 35145. Except as provided in Sections 54957 and 54957.6 of the Government
Code and in Section 35146 of, and subdivision (c) of Section 48914 of, this
ning board of any school district shall obeernopen
code, all meetings of the gover
to the public, and all actions authorized or requi ed by law of the governing
9
board shall be taken at such meetings and shall be subject to the following
requirements:
(a) Minutes must be taken at all such meetings, recording all actions
taken by the governing board. Such minutes shall constitute public
records, and shall be available to the Pl where members of the public,
(b) An agenda shall be posted at a place
including district employees, may view the same at least 48 hours prior to
the time of regular meetings and at least 24 hours prior to special meet-
ings. This agenda must include, but is not limited to See ems on which thn
governing board may take action at that meeting.
72121 relating to community colleges.]
�S 35145.5. It is the intent of the Legislature that members of the public be
able to place matters directly related to school district business on the
agenda of school district governing board meetings, and that members of the
public be able to addch
ress
vern Governing boards shall lnadopt reasonable regulations g items on the agenda as to
items are taken up. specify reason-
insure that this intent is carried out. Such regulations may sp Y
able procedures to insure the proper functioning of governing board meetings.
This subdivision shall not preclude the taking of testimony at regularly
scheduled meetings on matters not on the agenda which any member of the public
may wish to bring before the board, provided that no action is taken by the {\
board on such matters at the same meeting at which such testimony is taken.
Nothing in this paragraph shall be deemed to lim See u similar rther riSection n on 1 72121.5
same subject matter at a subsequent meeting.
relating to community colleges.]
35146. Notwithstanding the provisions of Section 35145 of
af this cde and
school district
Section 54950 of the Government Code, the governing body
shall, unless a request by the parent has been made pursuant to this section,
hold closed sessions if the board is considering the suspension of, or disci-
plinary action or any other action except expulsion in connection with any
pupil of the school district, if a public hearing upon such
u chion wo be
uld
lead to the giving out of information concerning school pup
ils w with Section 49073) of Chapter 6.5 of
in violation of Article 5 (commencing
Part 27 of this code.
ed session of the governing board of the district
Before calling such clos
boar
to consider these matters, the governing personal service,cif thel pupil
writing, by registered or certified mail or by p
is a minor, notify the pupil and his or her parent or guardian, or the pupil
if the pupil is an adult, of the intent of the governing board of the district
to call and hold such closed session. Unless the pupil, or his or her parent,
after receipt of such written
or guardian shall, in writing, within 48 hours
rning board be held
notice of intention, request that the hearing of the gave
ring
ducted uby i thee
governingeboard ina closed osession. if consider c such shallters
written request is
-34-
served upon the clerk or secretary of the governing board, the meeting shall
/ be public except that any discussion at such meeting that might be in conflict
( with the right to privacy of any pupil other than the pupil requesting the
public meeting or on behalf of whom such meeting is requested, shall be in
closed session. Whether the matter is considered at a closed session or at a
public meeting, the final action of the governing board of the school district
shall be taken at a public meeting and the result of such action shall be a
public record of the school district.
-35-
Y (tip
SPECIAL PROVISIONS
STATE LEGISLATURE /
Government Code Sections 9027-9032 `(
$ 9027. All meetings of the Assembly and Senate and the committees and sub-
committees thereof, and any conference committee, shall be open and public and
all the proceedings shall be conducted openly so that the public may remain
informed, except as otherwise provided in this article.
All meetings of any conference committee shall be open to press represen-
tatives accredited by the Joint Rules Committee.
9 9028. Any such meetings at which the discussion or adoption of any proposed
resolution, rule, regulation, or formal action occurs, or at which a majority
or quorum of the body is in attendance, shall be held only after full and
timely notice to the public as provided by the Joint Rules of the Senate and
Assembly.
s� 9029. Nothing contained in this article shall be construed to prevent: the
Assembly or the Senate or a committee or subcommittee thereof from holding
executive sessions to consider the appointment of members to committees or to
the chairmanship or vice chairmanship thereof, or to consider the appointment,
employment or dismissal of a public officer or employee or to hear complaints
or charges brought against such officer or employee, or an elected public
official, or to consider matters relating to internal house management, or to
consider assignment of bills to committee, or affecting the safety and
security of the State Capitol or Members of the Legislature, its staff and
employees, or the Members of the Assembly or the Senate from meeting privately
in caucus with members of their own political party.
$ 9030. Each Member of the Legislature who attends a meeting of the Assembly,
the Senate, or any committee or subcommittee thereof, where action is taken in
violation of Section 9027, with knowledge of the fact that the meeting is in
violation thereof, is guilty of a misdemeanor.
$ 9031. Any interested person may commence an action by mandamus, injunction
or declaratory relief for the purpose of stopping or preventing violations or
threatened violations of Section 9027 by Members of the Legislature or to
determine the applicability of this chapter to actions or threatened future
action of the Legislature.
9 9032. If any provision of this article, or the application thereof, to any
person or circumstance is held invalid, the validity of the remainder of such
article and the application of such provision to other persons and circum-
stances shall not be affected thereby.
-36-
r 1 ID
SPECIAL PROVISIONS
REGENTS
UNIVERSITY OF CALIFORNIA
California Constitution, Article IX, Section 9, Subdivision (g)
Education Code Section 92030
CALIFORNIA CONSTITUTION
$ 9 (g) . Meetings of the Regents of the University of California shall be
public, with exceptions and notice requirements as may be provided by statute.
EDUCATION CODE
s� 92030. All meetings of the Regents of the University of California shall,
except as otherwise provided in this section, be open to the public. The cor-
poration shall establish the time and place for holding regular meetings, but
may, as occasioned by necessity, hold special meetings. Public notice shall
be given for such meetings. Such notice shall be given by notifying any news-
paper of general circulation or any television or radio station, and shall be
- delivered personally or by mail so that the notice may be published or broad-
cast at least 24 hours before the time of such meeting.
The Regents of the University of California may also hold closed sessions
when it meets to consider or discuss: (a) matters relating to or .affecting
the national security; {b) the conferring of honorary degrees or other honors
tor commemorations; (c) those matters involving gifts, devises and bequests;
(d) matters involving purchase and sale of investments for endowment and pen-
sion funds; (e) matters involving litigation when discussion in open session
concerning such matters would adversely affect or be detrimental to the public
interest; (f) matters involving acquisition and disposition of property; (g)
matters relating to the appointment, employment, performance, compensation, or
dismissal of officers and employees, excluding individual regents other than
the president of the university; and (h) matters relating to complaints or
charges brought against officers or employees of the university, excluding .
individual regents other than the president of the university unless such
officer or employee requests a public hearing. There also may be excluded
from any such public or closed meeting during the examination of a witness,
any or all other witnesses in the matter being investigated.
t
-37-
March 25, 1983
James E. S imon
P ort er,S 1mon and Graham
Truckee, California 95734
D ear Jim,
Yesterday, March 24, 1983, the Truckee Donner Public Utility District
Board of Directors held a special meeting with Rick '31umfield of Authur
Anderson, Inc. While I questioned the proceedure for calling the meeting
and do have concerns over its legality, I am none-the-less more concerned
with what happened after the special meeting was adjourned at 5:20pm.
When I adjourned the special meeting at 5: 20 I left the board room to
make a phone call. Directors Corbett, Kuttle and VanLandingham remained
to talk with the Manager, Jim Ward. A few minutes later I returned to the
board room to give the manager a message. I observed two of the three
directors (Kuttle and VanLandingham) discussing an issue relative to board
policy (interest charges on late payments) with the manager. Director
Corbett was sitting there listening.
I turned and left the room believing that a violation of the secret
meeting laws was taking place. Today, I called Manager Ward and asked him
how long this meeting lasted. He told me that the discussion lasted thirty
minutes or so.
Please review the facts and in your capacity as Council to the District,
provide each director and the manager with an opinion of this situation.
Could you also amplify on the topic of what is a properly called public
meeting vs. an illegal or improper meeting as outlined in the Ralph M.
Brown Act?
Thank you for your prompt attffition to this matter.
Sincerely,
i
7do,A. Maass
1r
Truckee Donner PUD
cc Jim Ward
John Corbett
Karl Kuttle
Dick VanLandingham
(1`1.
LFC;AL OPINION
DATE: MARCH 31 , 1983
TO: BOARD OF DIRECTORS, TRUCKEE DONNER PUBLIC UTILITY
�-. DISTRICT
FROM: JAMES ERNEST SIMON, DISTRICT COUNSEL
QUESTION PRESENTED
By letter dated March 25 , 1983, President Maass has
requested an opinion as to whether a special meeting which
occurred on March 24 , 1983 , was in violation of the California
Secret Meeting Laws.
CONCLUS-ION
We have determined that, depending upon the subject matter
actually discussed at the meeting, the deliberations made, and
the action taken, a technical violation of the Ralph M. Brown Act
may have occurred.
FACTUAL BACKGROUND
We are advised that a special meeting was held on March 24 ,
1983 , pursuant to written or telephonic notice to all Directors .
The subject matter of the meeting according to the agenda
concerned discussions with the District' s accountants For
purposes of discussing the annual audit. The meeting was
convened in the late afternoon and adjourned by President Maass
at 5: 20 .
We are advised that thereafter Directors Corbett, Kuttel and
' VanLandingham remained engaged in a discussion with the General
of the
Manager James Ward. We understand that the subject matter
-1-
Board of. Directors
March 31 , 1982
Page 2
discussion related to implementation of the District' s policy
concerning interest on late payments to the District. We have no
information detailing the specifics of the discussion.
�-. President Maass is of the opinion that a violation of the
secret meeting laws may have occurred inasmuch as the meeting
apparently lasted approximately 30 minutes.
DISCUSSION
A brochure entitled "Secret Meeting Laws and Public
Agencies" published by the Legal information Center of the
California Department of Justice is reproduced and attached
herewith. Please note that this brochure was published April 1 ,
1981 , and is therefore somewhat dated.
The Truckee Donner Public Utility District falls within the
provisions of the Ralph M. Brown Act, the purpose of which is to
ensure that all deliberations and actions of local public
agencies are performed in public. The Act was specifically
designed to discourage and prevent secret meetings.
F The issue presented here concerns in part when the meeting
ended; that is was it properly adjourned.
Generally speaking, Robert' s Rules of Order under which the
District generally conducts its meetings , require that a Motion
To Adjourn be made. Such a motion is undebateable , cannot be
amended , and cannot be reconsidered. In the absence of a motion
I
and subsequent vote, it is unlikely that an adjournment is
technically proper. Under the facts presented, it is assumed
that the motion was made , voted upon, and the meeting properly
adjourned.
-2-
Board of Directors
March 31 , 1992
Page 3
Once the meeting was adjourned, the inquiry now focuses upon
whether another meeting took place. A meeting is generally
defined as any gathering of a quorum of a legislative body, no
matter how informal , where business is transacted or discussed.
The California Attorney General rendered an opinion in 1963
that an "informal, " "study," "discussion, " "informational, " "fact
finding, " or "precouncil" gatherings of the majority of the
members of a board were probably "meetings" whether or not anv
action was taken_ (See Secret Meeing Laws, page 6. )
The legislative purpose of the Brown Act was reiterated in
Carlson v. Paradise Unified School District (1971) 18 Cal.App. 3d
196 , 199.
In the event that the special meeting held March 24 , 1983 ,
was properly adjourned, and various Board members informally
remained at which time Board business was transacted or
discussed, a technical violation of the open meeting law
(Government Code §54943) may have occurred.
In the event however that no "meeting" occurred, in that no
group discussions were had nor business transacted, the spirit of
the law may well have been complied with. For example , if the
gathering did not involve the collective acquisition and exchange
of facts which were preliminary to some future Board decision, it
is conceivable that the gathering was not a "meeting" of the type
which the Brown Act was designed to protect by ensuring that it
be held in a public and open environment.
For purposes of future activities , it is advised that all
meetings of the District_ be formally adjourned upon motion and
-3-
Board of Directors
March 31 , 1982
Page 4
that at all "informal" gatherings among three or more members of
the Board any discussion whatsoever about Board business by
avoided.
JES:cjg
Attachments: Secret Meeting yaws
Letter dated March 25, 1983
i
i
I
I
9r
i
I
t
r
f
i
i
-4-
Truckee Danner Public Utility District
Post Office Box 309 • 11570 Donner Pass Road e Truckee. California 95734
(916) 587-3896
A7)ril 4, 1983
Roberta hie me y, Forman
ivevada County Grand Jury HAI:i� LEL DIE IRE D
123 Glasson Way
Grass Valley, California
i
Lear iris . I{ierney and I"embers of the Grand Jury,
i
As a teacher of American Government at Tahoe Truckeesigh
School for the -oast fourteen years , I have always strived to
Instill in my students the need for our citizens to become involved
In g ove rnme nt. I have always stressed the fact that non Involve-pent
of the electorate may lead to government officials doing "their
own thing". Incidents life Watergate and ABSCAMI make it difficult
for me to convince my students as well as adults that such dishonesty
i in government is the exception, not the rule .
i As a member of the Board of Directors of the Truckee Donner
j Public Utility District for the past six years , I have attempted
to put good, sound governmental principles into practice . However
during the past few months some disturbing events have occurred
within the district that concern me greatly. Some directors are
j taking it upon themselves to act individually in the operation and
managment of the District. Such actions are contrary to District
Policy, 72-04. In addition aller-ed violations of the Brown Act
,.-. may have occurred. One such example is outlined in a letter I
sent to our District Council , Mr. Jim Simon of Porter, Simon, and
Graham. of Truckee .
j i ,y concern is not over one or two specific examples of alleged
violations of District Policy or State Lags but more of an attitude
on the part of some directors that they ?nave the right to ignore
j District Policy and State La1as . They cannot accept the fact that
the TDPi7D Board gov rns only when it sits collectively in a le7,ally
called meeting. Directors do not have the right to govern as
individuals ; but a few of the directors believe they do have such
rights .
+� I am as'•�Ting that the Grand Jury, as a "lratehdo-;" for the COmr+nunity,
investigate governing aspects of the _'rucY_ee Donner Lublic
Utility District and take any actions as deemed appronrinte in
order to assure the people of Truckee that they are being, re-oresented
adequately and ;rithin the scope of t-ie District Policies and the
f 1a�"rs of the State of California.
I
i
vs . Roberta Fiemey, Forman
jNevada County Grand Jury Page 2
I
I have attached sore -1_etters and documents that may help
clarify and amplify upon the situation. If I can boe of further
I assistance , please do not hesitate to contact me .
Sincerely,
James A. Maass , President
I Board of Directors
i
cc Board of Directors
Jim Simon, District Council
Jim Ward, District Manager
A/N Letter dated March 25, 1983, Maass to Simon
Legal Opinion dated March 31, 1983, Simon to Board of Lirectors
Letter dated April 3, 1983, Maass to Simon
District Policy 72-04