{
 "topic": "OMA section 2.01",
 "statute": "5 ILCS 120/2.01",
 "family": "Notice, agendas, and meeting access",
 "page": "https://illinoisfoia.org/issues/oma-2-01/",
 "note": "Determination letters are non-binding. Verify against the source PDF before citing.",
 "counts": {
  "violation_found": 10,
  "no_violation": 17,
  "no_determination": 2,
  "other": 0
 },
 "challenge_notes": {
  "generated_by": "AI summary of the decisions listed on this page; not legal advice; verify each decision against its PDF",
  "when_a_challenge_is_strong": [
   {
    "text": "A person was prohibited from entering the meeting room even though they were not disruptive, there was no court order barring them, and no demonstrable threat to safety.",
    "why": "A public body may not exclude a person from an open meeting absent a court order, actual disruption, or demonstrable evidence of a threat to safety.",
    "decisions": [
     {
      "title": "Restricted physical access and in-person comment at a township board meeting",
      "url": "https://illinoisfoia.org/opinions/letter-77728/#issue-2"
     }
    ]
   },
   {
    "text": "The public was unable to enter because the meeting room doors were locked and there were no measures to admit people.",
    "why": "Locking doors without providing a way for the public to enter violates the requirement that meetings be open to the public.",
    "decisions": [
     {
      "title": "Unannounced pre-meeting gatherings and a blocked board meeting",
      "url": "https://illinoisfoia.org/opinions/letter-49828/#issue-7"
     }
    ]
   },
   {
    "text": "A municipal public body held a meeting where a quorum of members participated remotely, and no specific OMA exception (such as a gubernatorial disaster proclamation) applied.",
    "why": "A quorum of members must be physically present at open meetings unless a specific OMA exception applies.",
    "decisions": [
     {
      "title": "A village board's fully remote meetings",
      "url": "https://illinoisfoia.org/opinions/letter-91361/#issue-1"
     }
    ]
   },
   {
    "text": "A majority of a quorum of the public body gathered before the official meeting and had a contemporaneous, interactive, deliberative discussion about public business.",
    "why": "Such a gathering is a 'meeting' that must be held at a time and place open to the public.",
    "decisions": [
     {
      "title": "A board's private discussion of equipment purchases",
      "url": "https://illinoisfoia.org/opinions/letter-65448/#issue-1"
     }
    ]
   },
   {
    "text": "The public body held a special meeting on a legal holiday, and that holiday did not fall on the body's regular meeting day.",
    "why": "No public meeting may be held on a legal holiday unless the regular meeting day falls on that holiday, regardless of the meeting's purpose.",
    "decisions": [
     {
      "title": "A public meeting on a legal holiday at a locked facility",
      "url": "https://illinoisfoia.org/opinions/letter-51417/#issue-1"
     }
    ]
   }
  ],
  "when_the_body_usually_wins": [
   {
    "text": "The requester complained about access to a meeting after it concluded, without providing facts that the public body's actions or inaction prevented or dissuaded the public from attending the meeting itself.",
    "why": "No OMA violation where requester fails to provide facts that the public body's actions or inaction prevented or dissuaded the public from attending the meeting.",
    "decisions": [
     {
      "title": "A board's handling of post-meeting attendee behavior",
      "url": "https://illinoisfoia.org/opinions/letter-90893/#issue-1"
     }
    ]
   },
   {
    "text": "The meeting was held in a building where visitors had to be buzzed in and escorted to the meeting room, but the public could still attend.",
    "why": "Security measures like buzzing in and escorting do not violate OMA, which requires only reasonable accessibility, not absolute accessibility.",
    "decisions": [
     {
      "title": "A housing authority's locked meeting room and delayed entry",
      "url": "https://illinoisfoia.org/opinions/letter-68606/#issue-2"
     }
    ]
   },
   {
    "text": "The requester argued the meeting time was inconvenient because it conflicted with their personal work schedule.",
    "why": "A meeting time is convenient if it is reasonable for the public in general; inconvenience to some individuals does not make the time unreasonable.",
    "decisions": [
     {
      "title": "A council's meeting notices and member OMA training",
      "url": "https://illinoisfoia.org/opinions/letter-54184/#issue-5"
     }
    ]
   },
   {
    "text": "The meeting was held during regular business hours and no facts showed the public was unreasonably deterred from attending.",
    "why": "A meeting held during regular business hours is not inherently inconvenient, and absent evidence of deterrence, it satisfies the convenient and open requirement.",
    "decisions": [
     {
      "title": "A TIF joint review board's 10:00 a.m. meeting time",
      "url": "https://illinoisfoia.org/opinions/letter-41771/#issue-1"
     }
    ]
   },
   {
    "text": "The public body met at a restaurant, and there was no evidence that attendance was deterred.",
    "why": "A restaurant meeting is not inherently improper if it does not deter attendance; OMA requires only reasonable accessibility.",
    "decisions": [
     {
      "title": "School committee meetings at a restaurant",
      "url": "https://illinoisfoia.org/opinions/letter-75047/#issue-2"
     }
    ]
   }
  ],
  "points_to_put_in_the_letter": [
   {
    "text": "If you were excluded from the meeting room, state that you were not disruptive and had no court order banning you. The public body may not bar a person without those grounds.",
    "why": "",
    "decisions": [
     {
      "title": "Restricted physical access and in-person comment at a township board meeting",
      "url": "https://illinoisfoia.org/opinions/letter-77728/#issue-2"
     }
    ]
   },
   {
    "text": "If the meeting doors were locked and no one let the public in, explain that locking doors without measures to admit the public violates the requirement that meetings be open to the public.",
    "why": "",
    "decisions": [
     {
      "title": "Unannounced pre-meeting gatherings and a blocked board meeting",
      "url": "https://illinoisfoia.org/opinions/letter-49828/#issue-7"
     }
    ]
   },
   {
    "text": "If a quorum of members participated remotely and no specific OMA exception applied, argue that a quorum must be physically present at the open meeting.",
    "why": "",
    "decisions": [
     {
      "title": "A village board's fully remote meetings",
      "url": "https://illinoisfoia.org/opinions/letter-91361/#issue-1"
     }
    ]
   },
   {
    "text": "If a majority of a quorum gathered and deliberated about public business before the official meeting, argue that this gathering was a meeting that should have been open to the public.",
    "why": "",
    "decisions": [
     {
      "title": "A board's private discussion of equipment purchases",
      "url": "https://illinoisfoia.org/opinions/letter-65448/#issue-1"
     }
    ]
   },
   {
    "text": "If the public body held a special meeting on a legal holiday that was not its regular meeting day, point out that no public meeting may be held on a legal holiday unless the regular meeting falls on that day.",
    "why": "",
    "decisions": [
     {
      "title": "A public meeting on a legal holiday at a locked facility",
      "url": "https://illinoisfoia.org/opinions/letter-51417/#issue-1"
     }
    ]
   }
  ],
  "facts_to_gather": [
   "Whether the meeting doors were locked and whether there was any way for the public to enter (e.g., buzzer, escort, staff present to open doors).",
   "Whether you were prohibited from entering the meeting room, and whether you were disruptive or subject to a court order.",
   "Whether a quorum of the public body's members attended remotely, and whether any statutory exception (such as a disaster declaration) applied at the time.",
   "The date of the meeting, whether it was a legal holiday, and whether the body's regular meeting day fell on that holiday or it was a special meeting.",
   "Whether a majority of a quorum of the public body gathered and discussed public business before the official meeting in a contemporaneous, interactive way."
  ],
  "common_mistakes": [
   {
    "text": "Arguing that a locked building that requires buzzing in and being escorted violates OMA, even though security measures allow the public to attend.",
    "why": "",
    "decisions": [
     {
      "title": "A housing authority's locked meeting room and delayed entry",
      "url": "https://illinoisfoia.org/opinions/letter-68606/#issue-2"
     }
    ]
   },
   {
    "text": "Claiming a meeting time is unreasonable solely because it conflicts with a personal work schedule, without showing the time is unreasonable for the public in general.",
    "why": "",
    "decisions": [
     {
      "title": "A council's meeting notices and member OMA training",
      "url": "https://illinoisfoia.org/opinions/letter-54184/#issue-5"
     }
    ]
   },
   {
    "text": "Assuming that a meeting held at a restaurant is automatically not open and convenient, without any evidence that attendance was actually deterred.",
    "why": "",
    "decisions": [
     {
      "title": "School committee meetings at a restaurant",
      "url": "https://illinoisfoia.org/opinions/letter-75047/#issue-2"
     }
    ]
   },
   {
    "text": "Assuming any meeting on a legal holiday violates OMA, without checking whether the holiday falls on the body's regular meeting day.",
    "why": "",
    "decisions": [
     {
      "title": "A public hearing scheduled on a legal holiday",
      "url": "https://illinoisfoia.org/opinions/letter-60394/#issue-1"
     }
    ]
   },
   {
    "text": "Demanding that all members be physically present for an entirely in-person meeting where no one participates remotely, confusing the physical quorum rule that applies only to remote attendance.",
    "why": "",
    "decisions": [
     {
      "title": "School board meetings without a physical quorum",
      "url": "https://illinoisfoia.org/opinions/letter-48860/#issue-1"
     }
    ]
   }
  ],
  "caution": "These notes are based on non-binding determination letters from the Public Access Bureau; outcomes depend on the specific facts of each case and the current version of the Open Meetings Act, so always verify the full text of cited decisions and the statute."
 },
 "issues": [
  {
   "issue": "Remote meetings without physical quorum",
   "outcome": "violation_found",
   "rule": "A quorum of members of a municipal public body must be physically present at open meetings unless a specific OMA exception applies.",
   "decision": {
    "title": "A village board's fully remote meetings",
    "date": "2026-03-13",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-91361/"
   },
   "authorities": []
  },
  {
   "issue": "Open meetings access after meeting concluded",
   "outcome": "no_violation",
   "rule": "No OMA violation where requester fails to provide facts that the public body's actions or inaction prevented or dissuaded the public from attending the meeting.",
   "decision": {
    "title": "A board's handling of post-meeting attendee behavior",
    "date": "2025-12-30",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-90893/"
   },
   "authorities": []
  },
  {
   "issue": "Board denied public access to meeting",
   "outcome": "no_violation",
   "rule": "A public body does not violate OMA when security personnel not under its control delay a person's entry, and the body waits and allows the person to speak.",
   "decision": {
    "title": "Denial of entry to an open meeting",
    "date": "2024-05-08",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-80495/"
   },
   "authorities": [
    {
     "text": "2023 PAC 78367",
     "url": null
    }
   ]
  },
  {
   "issue": "Convenient and open meeting access",
   "outcome": "violation_found",
   "rule": "Public meetings must be held at times and places convenient and open to the public, requiring reasonable accessibility, not absolute accessibility.",
   "decision": {
    "title": "Restricted physical access and in-person comment at a township board meeting",
    "date": "2024-08-05",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-77728/"
   },
   "authorities": [
    {
     "text": "Gerwin v. Livingston County Board, 345 Ill. App. 3d 352, 362 (2003)",
     "url": null
    }
   ]
  },
  {
   "issue": "Prohibiting individual from entering meeting room",
   "outcome": "violation_found",
   "rule": "A public body may not exclude a person from an open meeting absent a court order, actual disruption, or demonstrable evidence of a threat to safety.",
   "decision": {
    "title": "Restricted physical access and in-person comment at a township board meeting",
    "date": "2024-08-05",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-77728/"
   },
   "authorities": [
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 37043, issued September 1, 2015",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 35101, issued July 13, 2015",
     "url": null
    }
   ]
  },
  {
   "issue": "Reasonable access to meeting",
   "outcome": "no_violation",
   "rule": "During the COVID-19 pandemic, a public body may satisfy the convenient and open requirement by providing legitimate remote access, even if some individuals are admitted in person.",
   "decision": {
    "title": "Meeting agendas, public comment periods, and COVID-19 meeting access",
    "date": "2024-02-09",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-65997/"
   },
   "authorities": [
    {
     "text": "Gerwin v. Livingston Co. Board, 345 Ill. App. 3d 352, 362 (2003)",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 63372, issued September 17, 2020, at 4-5",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 64497, issued September 3, 2020, at 3",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 64541 64857, issued April 8, 2021, at 5",
     "url": null
    }
   ]
  },
  {
   "issue": "Meeting location not sufficiently open and convenient",
   "outcome": "no_violation",
   "rule": "Section 2.01 requires reasonable accessibility, not absolute accessibility; without facts showing attendees were deterred or restricted, the location was sufficiently open and convenient.",
   "decision": {
    "title": "A school board's conduct of public comment and meeting venue",
    "date": "2023-10-03",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-78138/"
   },
   "authorities": [
    {
     "text": "Gerwin v. Livingston County Board, 345 Ill. App. 3d 352 (2003)",
     "url": null
    },
    {
     "text": "State ex rel. Badke v. Village Board of Village of Greendale, 173 Wis. 2d 553, 494 N.W.2d 408 (Wis. 1993)",
     "url": null
    }
   ]
  },
  {
   "issue": "Whether City Council meetings were sufficiently audible to comply with OMA section 2.01",
   "outcome": "no_determination",
   "rule": "OMA requires public bodies to provide reasonable access to meetings, including taking reasonable measures to ensure proceedings are audible to the public.",
   "decision": {
    "title": "Inaudible audio at a city council meeting",
    "date": "2023-07-14",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-77191/"
   },
   "authorities": [
    {
     "text": "Gerwin v. Livingston County Board, 345 Ill. App. 3d 352 (4th Dist. 2003)",
     "url": null
    },
    {
     "text": "State ex rel. Bratenahl v. Village of Bratenahl, 157 Ohio St. 3d 309 (Ohio 2019)",
     "url": null
    },
    {
     "text": "State ex rel. Ames v. Portage County Board of Commissioners, 165 Ohio St. 3d 292 (Ohio 2021)",
     "url": null
    },
    {
     "text": "Goetschius v. Board of Education, 281 A.D.2d 416 (N.Y. App. Div. 2001)",
     "url": null
    },
    {
     "text": "State ex rel. Badke v. Village Board of the Village of Greendale, 173 Wis. 2d 553 (Wis. 1993)",
     "url": null
    }
   ]
  },
  {
   "issue": "Meeting location convenience under OMA",
   "outcome": "no_determination",
   "rule": "A meeting location is convenient if it provides reasonable accessibility; the requester must provide facts showing attendees were deterred.",
   "decision": {
    "title": "A village board's special meeting location",
    "date": "2023-05-23",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-76467/"
   },
   "authorities": [
    {
     "text": "Exelon Corp. v. Dept. of Revenue, 234 Ill. 2d 266, 275 (2009)",
     "url": null
    },
    {
     "text": "Gerwin v. Livingston Co. Board, 345 Ill. App. 3d 352, 361 (4th Dist. 2003)",
     "url": null
    },
    {
     "text": "State ex rel. Badke v. Village Board of the Village of Greendale, 173 Wis. 2d 553, 579, 494 N.W.2d 408, 418 (Wis. 1993)",
     "url": null
    }
   ]
  },
  {
   "issue": "Convenient and open meeting access",
   "outcome": "no_violation",
   "rule": "Locked building does not violate OMA if measures allow public access; lack of location notice impeded access but not deterrence.",
   "decision": {
    "title": "Meeting location notice on a hospital board agenda",
    "date": "2023-06-13",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-75513/"
   },
   "authorities": [
    {
     "text": "Gerwin v. Livingston County Board, 345 Ill. App. 3d 352 (4th Dist. 2003)",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Ltr. 17711",
     "url": null
    }
   ]
  },
  {
   "issue": "Meeting location not convenient and open to the public",
   "outcome": "no_violation",
   "rule": "Section 2.01 requires reasonable accessibility, not absolute accessibility; a restaurant meeting is not inherently improper if it does not deter attendance.",
   "decision": {
    "title": "School committee meetings at a restaurant",
    "date": "2023-03-06",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-75047/"
   },
   "authorities": [
    {
     "text": "Gerwin v. Livingston County Board, 345 Ill. App. 3d 352, 359 (4th Dist. 2003)",
     "url": null
    },
    {
     "text": "State ex rel. Badke v. Village Board of Greendale, 173 Wis. 2d 553, 579, 494 N.W.2d 408, 418 (Wis. 1993)",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. Pub. Acc. Op. No. 12-008, issued April 4, 2012",
     "url": "https://illinoisfoia.org/opinions/2012-pac-18008/"
    },
    {
     "text": "Ill. Att'y Gen. Pub. Acc. Op. No. 13-014, issued September 5, 2013",
     "url": "https://illinoisfoia.org/opinions/2013-pac-24845/"
    }
   ]
  },
  {
   "issue": "Removal of speaker during business portion of meeting",
   "outcome": "no_violation",
   "rule": "The head of a public body may remove a person who disrupts the orderly conduct of business, even if the person was previously allowed to speak during public comment.",
   "decision": {
    "title": "Final action on unlisted fire department ordinance amendments",
    "date": "2022-10-28",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-73114/"
   },
   "authorities": [
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 53888, issued April 30, 2020",
     "url": "https://illinoisfoia.org/opinions/letter-53888/"
    }
   ]
  },
  {
   "issue": "Conflict between OMA section 2.01 and local ordinance",
   "outcome": "no_violation",
   "rule": "Section 2.01 is permissive and does not require a public body to allow remote participation in closed session, so a local ordinance restricting such participation does not conflict with OMA.",
   "decision": {
    "title": "A village board trustee's request to attend a closed session remotely",
    "date": "2022-03-10",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-69969/"
   },
   "authorities": []
  },
  {
   "issue": "Meeting not convenient and open due to locked doors and escort",
   "outcome": "no_violation",
   "rule": "Section 2.01 requires only reasonable accessibility, not absolute accessibility; security measures like buzzing in and escorting do not violate OMA.",
   "decision": {
    "title": "A housing authority's locked meeting room and delayed entry",
    "date": "2022-01-18",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-68606/"
   },
   "authorities": [
    {
     "text": "Gerwin v. Livingston County Board, 345 Ill. App. 3d 352 (4th Dist. 2003)",
     "url": null
    },
    {
     "text": "State ex rel. Badke v. Village Board of the Village of Greendale, 173 Wis. 2d 553, 494 N.W.2d 408 (Wis. 1993)",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 17711, issued March 27, 2012",
     "url": null
    }
   ]
  },
  {
   "issue": "Pre-meeting discussion by majority of quorum violated OMA",
   "outcome": "violation_found",
   "rule": "A gathering of a majority of a quorum of a public body for a contemporaneous, interactive, deliberative discussion of public business constitutes a meeting subject to OMA.",
   "decision": {
    "title": "A board's private discussion of equipment purchases",
    "date": "2021-01-26",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-65448/"
   },
   "authorities": [
    {
     "text": "People ex rel. Difanis v. Barr, 83 Ill. 2d 191, 202 (1980)",
     "url": "https://illinoisfoia.org/cases/pre1996-46324/"
    },
    {
     "text": "Gosnell v. Hogan, 179 Ill. App. 3d 161, 171 (5th Dist. 1989)",
     "url": "https://illinoisfoia.org/cases/pre1996-128527/"
    },
    {
     "text": "Hinds County Republican Party v. Hinds County, Mississippi, 432 F. Supp. 3d 684, 702 (S.D. Miss. 2020)",
     "url": null
    },
    {
     "text": "Sacramento Newspaper Guild, Local 92 v. Sacramento County Board of Supervisors, 263 Cal. App. 2d 41, 50 (Cal. App. 1968)",
     "url": null
    },
    {
     "text": "Jackson v. Board of Election Commissioners, 2012 IL 111928, 148, 975 N.E. 2d 583, 596 (2012)",
     "url": null
    },
    {
     "text": "Tepfer v. Deerfield Savings & Loan Ass'n, 118 Ill. App. 3d 77, 80-82 (1st Dist. 1983)",
     "url": null
    }
   ]
  },
  {
   "issue": "Failure to hold meeting at specified time and place open to public",
   "outcome": "violation_found",
   "rule": "Meetings must be held at a specified time and place open to the public.",
   "decision": {
    "title": "City council conference call gatherings without public notice",
    "date": "2020-09-11",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-62981/"
   },
   "authorities": []
  },
  {
   "issue": "Meeting location not convenient or open to public",
   "outcome": "no_violation",
   "rule": "A public body must provide reasonable accessibility, not absolute accessibility, and the Board's steps to accommodate an unusually large crowd satisfied this requirement.",
   "decision": {
    "title": "A school board's meeting room capacity and overflow accommodations",
    "date": "2020-05-14",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-62002/"
   },
   "authorities": [
    {
     "text": "Gerwin v. Livingston County Board, 345 Ill. App. 3d 352 (4th Dist. 2003)",
     "url": null
    },
    {
     "text": "State ex rel. Badke v. Village Board of the Village of Greendale, 173 Wis. 2d 553, 494 N.W.2d 408 (Wis. 1993)",
     "url": null
    }
   ]
  },
  {
   "issue": "Public hearing held on legal holiday",
   "outcome": "no_violation",
   "rule": "A public body may hold a meeting on a legal holiday if the holiday falls on its regular meeting day, even if the regular meeting is not held that day.",
   "decision": {
    "title": "A public hearing scheduled on a legal holiday",
    "date": "2020-11-18",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-60394/"
   },
   "authorities": [
    {
     "text": "Argo High School Council of Local 571 v. Argo Community High School District 217, 163 Ill. App. 3d 578 (1st Dist. 1987)",
     "url": "https://illinoisfoia.org/cases/pre1996-126160/"
    }
   ]
  },
  {
   "issue": "Convenience of July 16, 2018 meeting time",
   "outcome": "no_violation",
   "rule": "A meeting time is convenient if it is reasonable for the public in general; inconvenience to some individuals does not make the time unreasonable.",
   "decision": {
    "title": "A council's meeting notices and member OMA training",
    "date": "2018-12-19",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-54184/"
   },
   "authorities": [
    {
     "text": "Exelon Corp. v. Dep't of Revenue, 234 Ill. 2d 266, 275 (2009)",
     "url": null
    },
    {
     "text": "Gerwin v. Livingston Co. Board, 345 Ill. App. 3d 352, 361 (4th Dist. 2003)",
     "url": null
    },
    {
     "text": "State ex rel. Badke v. Village Board of the Village of Greendale, 173 Wis. 2d 553, 579, 494 N.W.2d 408, 418 (Wis. 1993)",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 38389",
     "url": null
    }
   ]
  },
  {
   "issue": "Special meeting held on legal holiday",
   "outcome": "violation_found",
   "rule": "No public meeting may be held on a legal holiday unless the regular meeting day falls on that holiday, regardless of the meeting's purpose.",
   "decision": {
    "title": "A public meeting on a legal holiday at a locked facility",
    "date": "2018-03-28",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-51417/"
   },
   "authorities": [
    {
     "text": "Argo High School Council of Local 571 v. Argo Community High School District 217, 163 Ill. App. 3d 578 (1st Dist. 1987)",
     "url": "https://illinoisfoia.org/cases/pre1996-126160/"
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 46019, issued April 4, 2017",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 32330, issued November 30, 2015",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 28047, issued May 19, 2014",
     "url": null
    }
   ]
  },
  {
   "issue": "Failure to hold 6:30 p.m. gatherings at open times and places",
   "outcome": "violation_found",
   "rule": "All meetings required to be public must be held at specified times and places convenient and open to the public.",
   "decision": {
    "title": "Unannounced pre-meeting gatherings and a blocked board meeting",
    "date": "2018-02-20",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-49828/"
   },
   "authorities": []
  },
  {
   "issue": "Locked doors restricting access to September 26, 2017 meeting",
   "outcome": "violation_found",
   "rule": "Public meetings must be open to the public; locking doors without measures to admit the public violates OMA.",
   "decision": {
    "title": "Unannounced pre-meeting gatherings and a blocked board meeting",
    "date": "2018-02-20",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-49828/"
   },
   "authorities": [
    {
     "text": "Gerwin v. Livingston County Board, 345 Ill. App. 3d 352, 359 (4th Dist. 2003)",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 17711, issued March 27, 2012",
     "url": null
    }
   ]
  },
  {
   "issue": "Meeting room accessibility under OMA",
   "outcome": "violation_found",
   "rule": "A public body must take steps in response to increased public interest to ensure meetings are reasonably accessible, even if not every attendee can be accommodated.",
   "decision": {
    "title": "Locked school doors during a public meeting",
    "date": "2018-01-31",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-32435/"
   },
   "authorities": [
    {
     "text": "Gerwin v. Livingston County Board, 345 Ill. App. 3d 352 (4th Dist. 2003)",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 37216, 37291, 37970, issued February 24, 2016",
     "url": null
    }
   ]
  },
  {
   "issue": "Physical quorum requirement for open meetings",
   "outcome": "no_violation",
   "rule": "The physical quorum requirement applies only when members participate remotely by audio or video conference, not to in-person gatherings.",
   "decision": {
    "title": "School board meetings without a physical quorum",
    "date": "2017-12-07",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-48860/"
   },
   "authorities": [
    {
     "text": "Slepicka v. Illinois Dept. of Public Health, 2014 IL 116927",
     "url": null
    },
    {
     "text": "In re Marriage of Mathis, 2012 IL 113496",
     "url": null
    }
   ]
  },
  {
   "issue": "Adequacy of notice for relocated meeting",
   "outcome": "no_violation",
   "rule": "Public meetings must be held at specified times and places convenient and open to the public; the Board's measures to notify the public of the location change were sufficient.",
   "decision": {
    "title": "Notice of a school board meeting's relocated location",
    "date": "2017-07-05",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-47809/"
   },
   "authorities": []
  },
  {
   "issue": "Failure to specify committee meeting times and places",
   "outcome": "no_violation",
   "rule": "Section 2.01 requires public meetings to be held at specified times and places convenient and open to the public, but committees that do not meet regularly have no schedule of regular meetings to publish.",
   "decision": {
    "title": "A village's committee meeting schedule",
    "date": "2017-08-08",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-46079/"
   },
   "authorities": []
  },
  {
   "issue": "Meeting room accessibility under section 2.01",
   "outcome": "no_violation",
   "rule": "Section 2.01 requires only reasonable accessibility, not absolute accessibility; the room was reasonably accessible despite some attendees standing.",
   "decision": {
    "title": "A county board",
    "date": "2017-04-06",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-45191/"
   },
   "authorities": [
    {
     "text": "Gerwin v. Livingston County Board, 345 Ill. App. 3d 352 (4th Dist. 2003)",
     "url": null
    },
    {
     "text": "State ex rel. Badke v. Village Board of the Village of Greendale, 173 Wis. 2d 553, 494 N.W.2d 408 (Wis. 1993)",
     "url": null
    }
   ]
  },
  {
   "issue": "Failure to hold meeting at specified time and place open to public",
   "outcome": "violation_found",
   "rule": "A public body must hold meetings at a specified time and place that is convenient and open to the public.",
   "decision": {
    "title": "An advisory committee's special meeting notice and agenda",
    "date": "2017-04-07",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-44652/"
   },
   "authorities": []
  },
  {
   "issue": "Meeting time convenience under OMA",
   "outcome": "no_violation",
   "rule": "A public meeting held during regular business hours is not inherently inconvenient, and the facts did not show the public was unreasonably deterred from attending.",
   "decision": {
    "title": "A TIF joint review board's 10:00 a.m. meeting time",
    "date": "2016-06-30",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-41771/"
   },
   "authorities": [
    {
     "text": "Gosnell v. Hogan, 179 Ill. App. 3d 161 (5th Dist. 1989)",
     "url": "https://illinoisfoia.org/cases/pre1996-128527/"
    },
    {
     "text": "Exelon Corp. v. Dept. of Revenue, 234 Ill. 2d 266 (2009)",
     "url": null
    },
    {
     "text": "Gerwin v. Livingston Co. Board, 345 Ill. App. 3d 352 (4th Dist. 2003)",
     "url": null
    },
    {
     "text": "State ex rel. Badke v. Village Board of the Village of Greendale, 173 Wis. 2d 553, 494 N.W.2d 408 (1993)",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 39854",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 29045",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 20968",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 14311",
     "url": null
    }
   ]
  }
 ]
}