Allen v. The Clark County Park District Board of Commissioners

Illinois Appellate Court
Civil Court
Open Meetings Act
Citation
Case Number: 
2016 IL App (4th) 150963
Decision Date: 
Wednesday, November 16, 2016
District: 
4th Dist.
Division/County: 
Clark Co.
Holding: 
Reversed.
Justice: 
STEIGMANN

Park District's Board of Commissioners approved 2 items on agenda of a regularly scheduled meeting. Court erred in dismissing Plaintiff's complaint, filed the next day, alleging that Board failed to comply with Open Meetings Act in providing insufficient explanation ("public recital") before voting to approval those 2 agenda items. Open Meetings Act requires that final actions by Board be preceded by a "public recital" of nature of matter being considered to inform public of business being conducted. Plaintiff's allegations were sufficient to state a violation of the Act. Introduction of agenda items at Board meeting were insufficient to inform public of any of key terms of lease agreement or covenants mentioned in agenda for those 2 agenda items. (HARRIS and APPLETON, concurring.)