B. Public Meetings Defined

• Library: The Sunshine Law Guidebook (2019 Ed.)

B. Public Meetings Defined

Chapter 610, RSMo, defines a "public meeting" as:

any meeting of a public governmental body . . . at which any public business is discussed, decided, or public policy formulated, whether such meeting is conducted in person or by means of communication equipment . . . . [T]he term shall [also] include a public vote of all or a majority of the members of a public governmental body, by electronic communication or any other means, conducted in lieu of holding a public meeting with the members of the public governmental body gathered at one location in order to conduct public business.

Section 610.010(5), RSMo 2016. This definition raises several issues, some of which have not been fully resolved.

1. What Is Public Business?

"Public business" is defined as "all matters which relate in any way to the performance of the public governmental body's functions or the conduct of its business." Section 610.010(3), RSMo 2016. It should be noted that the breadth of this definition is consistent with the policy of openness in § 610.011, RSMo 2016.

Examples include the following:

· In Kansas City Star Co. v. Shields, 771 S.W.2d 101, 102 (Mo. App. W.D. 1989), the court found that a public business discussion between members of a city finance committee, the city manager, and the city budget officer during a secret luncheon meeting was a public meeting.

· In Spradlin v. City of Fulton, Nos. WD 53104 and WD 53140...