OMA section 1.02
OMA5 ILCS 120/1.02. Section 1.02 overview: Defines “meeting” broadly -- it covers a gathering of a majority of a quorum of the body's members (in person, by phone, or electronically) to discuss public business, not just formally-called sessions -- plus defines “public body” similarly broadly to FOIA's definition.
61 issues across 51 determination letters:18 violation found · 43 no violation.
Counts are per issue, not per letter, and come from automated extraction checked against sampled letters. Determination letters are not binding precedent.
Authorities the Bureau cites most on this issue
- Ill. Att'y Gen. Op. No. 95-004 cited 17 times
- People ex rel. Difanis v. Barr, 83 Ill. 2d 191, 202 (1980) cited 14 times
- 1974 Ill. Att'y Gen. Op. No. S-726 cited 11 times
- Pope v. Parkinson, 48 Ill. App. 3d 797, 800 (4th Dist. 1977) cited 9 times
- Ill. Att'y Gen. Op. No. S-726 cited 7 times
- Nabhani v. Coglianese, 552 F. Supp. 657, 661 (N.D. Ill. 1982) cited 7 times
- Gosnell v. Hogan, 179 Ill. App. 3d 161, 170 (1989) cited 6 times
- Better Government Ass'n v. Illinois High School Ass'n, 2017 IL 121124 cited 5 times
How to challenge a denial on this issue
AI-generated summary of the decisions listed on this page, with each point linked to the letters it comes from. Determination letters are not binding precedent and this is not legal advice. Open the letter and check the PDF before relying on any point.
When a challenge is strong
- A majority of a quorum gathered (in person or by conference call) and engaged in interactive discussion to collect information or exchange facts on public business, even if no vote was taken or the body lacked authority to act on that matter. OMA defines a meeting as any gathering of a majority of a quorum held for the purpose of discussing public business; collective inquiry and fact-exchange qualify.Based on: 2024 · Proof-of-residency requirement fo… · 2018 · Unannounced pre-meeting gathering… · 2019 · Private agency funding hearings a…
- The group was created by a government entity, has defined responsibilities, a formal role in decision-making, and is supported by tax revenue. Such groups are subsidiary or advisory public bodies subject to OMA.Based on: 2024 · A DEI subcommittee's failure to p… · 2024 · Board vote to appoint an executiv… · 2020 · An advisory committee's closed me…
- The mayor or similar official counts toward a quorum under the applicable code, and a gathering of that official plus enough members to reach a majority of a quorum discussed public business. The official's presence counts toward the quorum, making the gathering a meeting.Based on: 2024 · A city council's unannounced priv…
When the public body usually wins
- Communications occurred through serial one-on-one conversations (in person, by phone, or electronically) without a contemporaneous gathering of a majority of a quorum. OMA requires a gathering of a majority of a quorum for contemporaneous interactive communication; serial contacts do not qualify.Based on: 2026 · A school board's letter signed by… · 2025 · Board deliberation on a censure r… · 2024 · A city council's agenda descripti…
- Members merely attended a presentation, forum, or site visit without engaging in interactive deliberation among themselves on public business. Attendance alone, without collective discussion of public business, is not a meeting.Based on: 2025 · A county board's Zoom gathering o… · 2025 · Informal gatherings of a village … · 2024 · Proof-of-residency requirement fo…
+9 more
2023 · Board members' presence at a comm… · 2019 · A community meeting attended by a… · 2018 · A council's gathering with a repo… · 2018 · Village board members' attendance… · 2018 · Village board members' attendance… · 2018 · A chamber of commerce breakfast w… · 2017 · A village committee's gathering a… · 2017 · Joint sessions of a university bo… · 2017 · A city council's campaign fundrai… - The group is an informal, ad hoc collection of volunteers with no formal appointment, no bylaws, no budget, and no binding authority, and is not subject to government control. Such groups are not public bodies under OMA.Based on: 2024 · A Community Advisory Group meetin… · 2022 · A school district parent committe… · 2021 · A violence prevention planning co…
Points to put in your letter
- If a majority of a quorum gathered and collectively discussed public business—even to just collect information or exchange facts—state that this is a meeting under OMA, and cite decisions like D1438.2 and D1215.1.Based on: 2024 · Proof-of-residency requirement fo… · 2018 · Unannounced pre-meeting gathering…
- If the group was created by the government, has a formal role, and uses tax money, argue it is a public body that must follow OMA. See D1437.1 and D1179.1.Based on: 2024 · A DEI subcommittee's failure to p… · 2018 · A city task force's compliance wi…
- If the mayor or village president was present and counts toward a quorum under your local code, include that in your count to show a majority of a quorum was reached. See D1457.1.Based on: 2024 · A city council's unannounced priv…
Common mistakes
- Assuming that any gathering of public body members, even for social or informational purposes, is a meeting. (D1297.2, D1250.1)Based on: 2019 · Private meetings of city council … · 2018 · A chamber of commerce breakfast w…
- Believing that serial one-on-one conversations among members constitute a meeting. (D1505.1, D1462.1)Based on: 2026 · A school board's letter signed by… · 2025 · Board deliberation on a censure r…
- Treating an informal volunteer group with no government control as a public body. (D1463.1, D1399.1)Based on: 2024 · A Community Advisory Group meetin… · 2022 · A school district parent committe…
- Assuming that e-mails sent hours or days apart are a contemporaneous meeting. (D1262.1, D1167.1)Based on: 2019 · Board members' emails coordinatin… · 2016 · Board members' emails on a board …
Facts to gather first
- Number of members present and whether they constituted a majority of a quorum.
- Whether the members engaged in interactive discussion about public business (e.g., exchanging views, asking questions, collecting information for future action).
- Whether the group was created by a government entity, has defined duties, receives public funds, or makes recommendations that are adopted.
- Whether communications were contemporaneous (happening at the same time) or separated by time.
- The specific code provision that defines the quorum for the body, especially if it includes the mayor or other official.
These notes are based on non-binding determination letters; outcomes depend on specific facts, and you should verify the full PDF for context.
Drafting brief for an AI assistant
Copy this into your assistant to help draft a request, appeal, or challenge to a denial that turns on this issue. It carries the rules and decisions, not your facts: add those yourself. Machine-readable version: oma-1-02.json.
Violation found (18)
Whether mayor counts toward quorum for OMA meeting
Rule: The mayor counts toward a quorum under the Municipal Code, so a gathering of the mayor and two alderpersons is a meeting subject to OMA.
Violation found A city council's unannounced private gathering · June 21, 2024
Council gathering as OMA meeting
Rule: A gathering of a majority of a quorum is a meeting when members engage in interactive discussion to collect information on public business within their authority.
Violation found Proof-of-residency requirement for a public meeting · March 15, 2024
Whether DEI subcommittees are public bodies under OMA
Rule: Subsidiary bodies, including subcommittees supported by tax revenue, are public bodies subject to OMA; key factors are government creation and control.
Violation found A DEI subcommittee's failure to provide meeting notice · April 9, 2024
Whether ACT Board is a public body under OMA
Rule: An entity is a subsidiary body if it has a public purpose and the government exercises significant control, outweighing independent contractor status.
Violation found Board vote to appoint an executive director without agenda notice · December 17, 2024
Improper closed meeting on March 10, 2021
Rule: A gathering of a majority of a quorum of a public body to discuss public business, including policy matters not requiring a vote, must comply with OMA.
Violation found A board's closed-session discussion of policy recommendations · January 19, 2022
Discussions of proposed legislative amendment by two commissioners
Rule: OMA applies to gatherings of a majority of a quorum discussing public business, even if no formal vote is taken and the body lacks authority to act on the matter.
Violation found Commissioners' discussions on property tax code amendments · December 15, 2022
March 26, 2020 conference call was a meeting
Rule: A gathering of a majority of a quorum discussing public business is a meeting subject to OMA.
Violation found City council conference call gatherings without public notice · September 11, 2020
March 30, 2020 conference call was a meeting
Rule: A gathering of a majority of a quorum discussing public business is a meeting subject to OMA.
Violation found City council conference call gatherings without public notice · September 11, 2020
April 6, 2020 conference call was a meeting
Rule: A gathering of a majority of a quorum discussing public business is a meeting subject to OMA.
Violation found City council conference call gatherings without public notice · September 11, 2020
Conference call as OMA meeting without notice
Rule: A conference call involving a majority of a quorum discussing public business is a meeting subject to OMA notice and open-meeting requirements.
Violation found Unannounced conference call among board members · February 25, 2020
Whether Advisory Committee is a public body under OMA
Rule: The Advisory Committee is a public body subject to OMA because it is a formal part of the City's structure with defined responsibilities and deliberative functions.
Violation found An advisory committee's closed meetings and missing records · July 31, 2020
Holding agency funding hearings in private without OMA compliance
Rule: A gathering of a majority of a quorum held for discussing public business, including collective inquiry and exchange of facts preliminary to a decision, is a meeting subject to OMA.
Violation found Private agency funding hearings and missing meeting agendas · April 12, 2019
6:30 p.m. gatherings as meetings
Rule: Gatherings where a quorum collectively acquires and exchanges facts preliminary to a decision on public business constitute meetings subject to OMA.
Violation found Unannounced pre-meeting gatherings and a blocked board meeting · February 20, 2018
Improper closed meeting on November 1, 2016
Rule: A quorum of a three-member board discussing public business triggers OMA even without a vote or final action.
Violation found Private discussion of employee insurance coverage · March 28, 2018
Whether the Advisory Board is a public body subject to OMA
Rule: The Advisory Board is a public body because it lacks independent legal existence, performs governmental functions, and is accountable to the Designating Units of Government.
Violation found An enterprise zone advisory board's OMA compliance · February 15, 2018
Whether the Task Force is a public body under OMA
Rule: An entity is a public body if it is an advisory body supported by tax revenue or expending tax revenue, applying the Stukel factors.
Violation found A city task force's compliance with the Open Meetings Act · May 18, 2018
Whether RTACs are public bodies subject to OMA
Rule: RTACs are advisory bodies of the State because their duties and composition are set by statute, they are accountable to entities controlled by the Department, have a formal role in decision-making, and make impactful recommendations.
Violation found Regional trauma advisory committees' OMA status · December 6, 2017
Private gathering as meeting under OMA
Rule: A gathering of a majority of a quorum engaged in contemporaneous interactive communication about public business is a meeting, even if members rotate to avoid simultaneous presence.
Violation found A committee's private discussion of a redistricting map · August 12, 2011
No violation (43)
Whether serial one-on-one communications constituted a meeting
Rule: A meeting requires contemporaneous interactive communications involving at least a majority of a quorum; serial one-on-one communications do not qualify.
No violation A school board's letter signed by a majority of members · July 31, 2026
Facebook comments by trustees as OMA meeting
Rule: Facebook comments by trustees directed at constituents, without interactive deliberation among a majority of a quorum, did not constitute a meeting under OMA.
No violation Trustees' Facebook comments as a public meeting · May 28, 2025
Whether Zoom gathering was an OMA meeting
Rule: A gathering is not an OMA meeting unless members engage in collective inquiry or deliberative discussions of public business beyond mere attendance at a presentation.
No violation A county board's Zoom gathering of committee members · September 10, 2025
Whether the November 23, 2024 gathering was a 'meeting' under OMA
Rule: A gathering is not a 'meeting' unless a majority of a quorum engages in collective inquiry or deliberation on public business.
No violation Informal gatherings of a village board · October 20, 2025
Whether serial one-on-one discussions constituted a meeting
Rule: A meeting requires a gathering of a majority of a quorum; serial one-on-one discussions involving fewer than three members do not constitute a meeting under the plain language of OMA.
No violation Board deliberation on a censure resolution outside a public meeting · March 26, 2025
Whether the CAG is a public body subject to OMA
Rule: An ad hoc group of external volunteers with no formal appointment, no bylaws, no budget, and no binding authority is not a public body under OMA.
No violation A Community Advisory Group meeting under OMA · November 4, 2024
Quorum and vote requirement to fill park district board vacancy
Rule: For a five-member park district board, the more specific and recently amended Park District Code vacancy-filling procedure prevails over OMA's general three-vote quorum requirement.
No violation Appointment of a new board member by a sub-quorum · March 1, 2024
Board gathering as OMA meeting
Rule: A gathering is not a meeting if members make only limited informational remarks and do not engage in interactive deliberation or exchange facts for future action.
No violation Proof-of-residency requirement for a public meeting · March 15, 2024
Interviews by First Assistant Commissioners as meeting
Rule: A gathering is a meeting only if members of the public body participate; subordinates acting as proxies are not members subject to OMA.
No violation Hiring of a General Counsel and Chief Ethics Officer · October 22, 2024
Alleged secret meeting on committee assignments
Rule: A 'meeting' requires a gathering of a majority of a quorum for discussing public business; one-on-one conversations do not meet this definition.
No violation A city council's agenda description for a censure vote · February 23, 2024
Whether March 16, 2023 Zoom call was an OMA meeting
Rule: A campaign event where board members communicate their views to the public to promote candidacies, without deliberating among themselves on public business, is not a meeting under OMA.
No violation A campaign town hall attended by a school board quorum · November 19, 2024
Whether Board members' attendance at Committee hearing constituted an OMA meeting
Rule: A gathering of a majority of a quorum is a meeting only if members collectively engage in deliberative discussions of public business; merely attending and conveying information to another body does not trigger OMA.
No violation Board members' presence at a committee budget hearing · October 6, 2023
Alleged unnoticed meeting on March 25, 2022
Rule: Separate conversations among trustees in the boardroom did not constitute a meeting because there was no deliberation of public business together.
No violation Private board meetings to discuss appointing a village president · June 13, 2023
Alleged secret meeting to select Village President before April 4, 2022
Rule: Communications among trustees were not contemporaneous and interactive, so they did not constitute a meeting under OMA.
No violation Private board meetings to discuss appointing a village president · June 13, 2023
Alleged serial meetings or walking quorum
Rule: Separate one-on-one conversations over a longer period were not close enough in time to be contemporaneous and interactive.
No violation Private board meetings to discuss appointing a village president · June 13, 2023
Whether the Committee is a public body under OMA
Rule: An informal parent support group that is not formally appointed, has no deliberative function, and is not subject to government control is not a public body under OMA.
No violation A school district parent committee meeting · December 30, 2022
Improper private meeting via electronic communication
Rule: No facts indicate a majority of a quorum engaged in contemporaneous interactive communication constituting a meeting subject to OMA.
No violation Informal straw polls to set a board agenda · April 11, 2022
Whether the Committee is a public body under OMA
Rule: An entity is a public body only if it is an advisory or subsidiary body of a public body, considering appointment, duties, control, funding, and functions.
No violation A violence prevention planning committee's meeting openness · March 10, 2021
Whether Board held improper meeting via separate discussions
Rule: Separate conversations between an employee and individual board members are not a meeting because no majority of a quorum gathered for contemporaneous discussion.
No violation A park district board's discussion of a citizen's agenda motion · February 4, 2021
May 8, 2020 conference call not a meeting
Rule: Communications involving less than a majority of a quorum are not meetings subject to OMA.
No violation City council conference call gatherings without public notice · September 11, 2020
Comments after adjournment as improper meeting
Rule: OMA applies to gatherings of a majority of a quorum for discussing public business; only one member made a statement after adjournment, so no meeting occurred.
No violation A special city council meeting's agenda and member training · February 21, 2020
Whether the Committee is a public body under OMA
Rule: An entity is an advisory body subject to OMA if it has defined responsibilities and is a formal part of the public body's structure, considering factors like appointment, duties, autonomy, and impact.
No violation A bilingual parent advisory committee's OMA status · July 10, 2020
Whether community meeting was a City Council meeting under OMA
Rule: A gathering is not a meeting unless a majority of a quorum deliberates or discusses public business; mere attendance by members does not trigger OMA.
No violation A community meeting attended by a council member · October 2, 2019
Gathering at McGuire's was not a meeting
Rule: Private social and political gatherings of public body members do not violate OMA unless they deliberate about public business.
No violation Private meetings of city council members at local establishments · May 2, 2019
Alleged absence of agenda items and private electoral work
Rule: The absence of agenda items and private electoral collaboration does not indicate an OMA violation because political gatherings are distinct from meetings to transact public business.
No violation Private meetings of city council members at local establishments · May 2, 2019
Whether the President's Staff Committee is a public body under OMA
Rule: The committee is not a public body because it lacks clearly assigned composition, service periods, oversight, and formal grounding in the University Council structure.
No violation Closed meetings of a university president's staff committee · April 29, 2019
Whether the Senior Leadership Roundtable is a public body under OMA
Rule: The Roundtable is not a public body for the same reasons as the Staff Committee, as it is merely the Staff Committee by another name.
No violation Closed meetings of a university president's staff committee · April 29, 2019
Whether e-mail exchanges constituted a meeting under OMA
Rule: A meeting requires contemporaneous interactive communication among a majority of a quorum; e-mails sent over an hour apart are not contemporaneous.
No violation Board members' emails coordinating a public statement · January 31, 2019
Whether Council gathering with reporter was an OMA meeting
Rule: A gathering of a majority of a quorum is a meeting only if held for the purpose of discussing public business; mere attendance without deliberative discussion does not trigger OMA.
No violation A council's gathering with a reporter · July 17, 2018
Whether breakfast event was a public meeting under OMA
Rule: A gathering is an OMA meeting only if a majority of a quorum discusses public business; a single member's speech at a chamber event is not.
No violation A chamber of commerce breakfast with local officials · April 3, 2018
January 31, 2018 public forum
Rule: A gathering is not an OMA meeting unless a majority of a quorum engages in deliberative discussions of public business; mere attendance or separated comments do not suffice.
No violation Village board members' attendance at public forums · June 13, 2018
February 26, 2018 informational forum
Rule: A gathering is not an OMA meeting unless a majority of a quorum engages in deliberative discussions of public business; discussions with the public do not constitute deliberations among Board members.
No violation Village board members' attendance at public forums · June 13, 2018
Whether the Board held an undisclosed meeting
Rule: A gathering of a majority of a quorum is a meeting only if held for the purpose of discussing public business; the Board asserted no public business was discussed and no contradicting evidence was presented.
No violation A board retreat at a remote location · March 9, 2018
Whether Board members' e-mails constituted a meeting
Rule: E-mails among Board members about filing objections to a referendum petition were private political activity, not public business, so no meeting occurred.
No violation Email correspondence between school board members about a referendum petition · January 31, 2018
Whether gathering was an OMA 'meeting'
Rule: A gathering of a majority of a quorum is a meeting only if held to discuss public business in a deliberative manner.
No violation A city council's campaign fundraiser gathering · November 28, 2017
Whether Evaluation Committee is a public body under OMA
Rule: An ad hoc committee that functions independently of the City Council, is not part of its formal organizational structure, and has limited advisory duties is not a public body subject to OMA.
No violation An ad-hoc committee evaluating redevelopment RFQs · December 20, 2017
Whether August 8, 2017 gathering was an OMA meeting
Rule: A gathering of a majority of a quorum is a meeting only if held for the purpose of discussing public business; informational site visits without deliberation are not meetings.
No violation A village committee's gathering at a private residence · October 3, 2017
Whether joint sessions constituted an OMA meeting
Rule: A gathering of a majority of a quorum is not a meeting unless held to discuss public business in a deliberative manner.
No violation Joint sessions of a university board with affiliated foundation members · August 18, 2017
Whether the Superintendent's Task Force is a public body under OMA
Rule: A group is not a public body if it is an internal advisory group without formal structure, deliberative functions, or accountability to a public body.
No violation Superintendent's task force as a public body · April 6, 2017
E-mails on vacant Board seat
Rule: E-mails separated by more than an hour and more than two days are not contemporaneous interactive communication, so no meeting occurred.
No violation Board members' emails on a board seat and contract · February 18, 2016
E-mails on Executive Director contract
Rule: No Board member responded to the e-mails, so there was no contemporaneous interactive communication among Board members.
No violation Board members' emails on a board seat and contract · February 18, 2016
Whether meeting was subject to OMA as gathering of majority of quorum
Rule: OMA applies only to gatherings of a majority of a quorum of a public body held to discuss public business.
No violation A political party precinct committeemen meeting · June 29, 2015
E-mail communications as OMA meeting
Rule: E-mails among Board members did not constitute a meeting because no majority of a quorum contemporaneously discussed public business.
No violation School board members' emails about appointments · June 8, 2015