{
 "topic": "OMA section 2.06(b)",
 "statute": "5 ILCS 120/2.06(b)",
 "family": "Minutes and verbatim recordings",
 "page": "https://illinoisfoia.org/issues/oma-2-06-b/",
 "note": "Determination letters are non-binding. Verify against the source PDF before citing.",
 "counts": {
  "violation_found": 4,
  "no_violation": 5,
  "no_determination": 0,
  "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": "The public body did not approve minutes of an open meeting within 30 days or by the second subsequent regular meeting, whichever is later.",
    "why": "The Bureau repeatedly found this violates Section 2.06(b) when minutes are approved late or not at all.",
    "decisions": [
     {
      "title": "Agenda notice and approval of meeting minutes",
      "url": "https://illinoisfoia.org/opinions/letter-50418/#issue-2"
     },
     {
      "title": "Meeting minutes approval and website posting",
      "url": "https://illinoisfoia.org/opinions/letter-71408/#issue-1"
     },
     {
      "title": "Procedures for approving and publishing committee meeting minutes",
      "url": "https://illinoisfoia.org/opinions/letter-57900/#issue-2"
     }
    ]
   },
   {
    "text": "The governing body has a website maintained by full-time staff but did not post regular meeting minutes within 10 days of approval, and the body blames part-time or elected staff for the failure.",
    "why": "The Bureau held that delegation of the posting duty to part-time or elected staff does not excuse non-compliance.",
    "decisions": [
     {
      "title": "Meeting minutes approval and website posting",
      "url": "https://illinoisfoia.org/opinions/letter-71408/#issue-3"
     }
    ]
   }
  ],
  "when_the_body_usually_wins": [
   {
    "text": "The public body does not post meeting minutes on its website because the website is maintained by a third party or not maintained by full-time staff.",
    "why": "The OMA posting requirement applies only when the website is maintained by the public body's full-time staff.",
    "decisions": [
     {
      "title": "City council meeting minutes",
      "url": "https://illinoisfoia.org/opinions/letter-85881/#issue-1"
     },
     {
      "title": "Meeting minutes approval and website posting",
      "url": "https://illinoisfoia.org/opinions/letter-71408/#issue-2"
     }
    ]
   },
   {
    "text": "The public body refuses to provide copies of minutes and instead tells the requester to file a FOIA request.",
    "why": "OMA requires only that minutes be available for inspection; the right to copies is governed by FOIA, not OMA.",
    "decisions": [
     {
      "title": "City council meeting minutes",
      "url": "https://illinoisfoia.org/opinions/letter-85881/#issue-2"
     }
    ]
   },
   {
    "text": "A committee or advisory body of a public body did not post its meeting minutes on the public body's website.",
    "why": "Only the governing body—not committees or advisory bodies—must post meeting minutes online under Section 2.06(b).",
    "decisions": [
     {
      "title": "Advisory committee meeting minutes posted online",
      "url": "https://illinoisfoia.org/opinions/letter-40638/#issue-1"
     },
     {
      "title": "Procedures for approving and publishing committee meeting minutes",
      "url": "https://illinoisfoia.org/opinions/letter-57900/#issue-3"
     }
    ]
   }
  ],
  "points_to_put_in_the_letter": [
   {
    "text": "State the exact date of the meeting and the date the minutes were approved. Show that the approval happened more than 30 days after the meeting or after the second subsequent regular meeting, whichever was later.",
    "why": "",
    "decisions": [
     {
      "title": "Agenda notice and approval of meeting minutes",
      "url": "https://illinoisfoia.org/opinions/letter-50418/#issue-2"
     },
     {
      "title": "Meeting minutes approval and website posting",
      "url": "https://illinoisfoia.org/opinions/letter-71408/#issue-1"
     },
     {
      "title": "Procedures for approving and publishing committee meeting minutes",
      "url": "https://illinoisfoia.org/opinions/letter-57900/#issue-2"
     }
    ]
   },
   {
    "text": "If the public body has a website run by full-time staff, note that the governing body must post regular meeting minutes within 10 days of approval. Point out that shifting the task to part-time or elected staff does not meet this requirement.",
    "why": "",
    "decisions": [
     {
      "title": "Meeting minutes approval and website posting",
      "url": "https://illinoisfoia.org/opinions/letter-71408/#issue-3"
     }
    ]
   }
  ],
  "facts_to_gather": [
   "Date the meeting took place and date the minutes were approved (or whether they remain unapproved).",
   "Whether the public body's website is maintained by full-time staff (ask the body or check public records).",
   "Whether the body that held the meeting is the governing body or a committee/advisory body.",
   "The date the approved minutes were actually posted on the website, if at all."
  ],
  "common_mistakes": [
   {
    "text": "Insisting that the Open Meetings Act entitles you to free copies of minutes, when the Bureau has clarified that OMA only requires inspection.",
    "why": "",
    "decisions": [
     {
      "title": "City council meeting minutes",
      "url": "https://illinoisfoia.org/opinions/letter-85881/#issue-2"
     }
    ]
   },
   {
    "text": "Demanding that a committee or advisory body post its meeting minutes on the website.",
    "why": "",
    "decisions": [
     {
      "title": "Advisory committee meeting minutes posted online",
      "url": "https://illinoisfoia.org/opinions/letter-40638/#issue-1"
     },
     {
      "title": "Procedures for approving and publishing committee meeting minutes",
      "url": "https://illinoisfoia.org/opinions/letter-57900/#issue-3"
     }
    ]
   },
   {
    "text": "Assuming that any website—even one maintained by an outside vendor—triggers the duty to post minutes.",
    "why": "",
    "decisions": [
     {
      "title": "City council meeting minutes",
      "url": "https://illinoisfoia.org/opinions/letter-85881/#issue-1"
     }
    ]
   },
   {
    "text": "A records coordinator believing that assigning minute posting to an elected official or part-time staff member removes the public body's obligation to post.",
    "why": "",
    "decisions": [
     {
      "title": "Meeting minutes approval and website posting",
      "url": "https://illinoisfoia.org/opinions/letter-71408/#issue-3"
     }
    ]
   }
  ],
  "caution": "These non-binding decision letters reflect the Bureau's past views; outcomes depend on the specific facts, and you should verify the relevant PDF decisions directly."
 },
 "issues": [
  {
   "issue": "Posting meeting minutes on website",
   "outcome": "no_violation",
   "rule": "OMA requires posting minutes online only if full-time staff maintain the website; third-party maintenance does not trigger the requirement.",
   "decision": {
    "title": "City council meeting minutes",
    "date": "2025-07-14",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-85881/"
   },
   "authorities": [
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 71408, issued April 12, 2024",
     "url": "https://illinoisfoia.org/opinions/letter-71408/"
    }
   ]
  },
  {
   "issue": "Requiring FOIA request for copies of minutes",
   "outcome": "no_violation",
   "rule": "OMA requires minutes be available for inspection, not that copies be provided; FOIA governs copy requests.",
   "decision": {
    "title": "City council meeting minutes",
    "date": "2025-07-14",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-85881/"
   },
   "authorities": []
  },
  {
   "issue": "Timely approval of minutes by Council and Board",
   "outcome": "violation_found",
   "rule": "A public body must approve open meeting minutes within 30 days or at its second subsequent regular meeting, whichever is later.",
   "decision": {
    "title": "Meeting minutes approval and website posting",
    "date": "2024-04-12",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-71408/"
   },
   "authorities": [
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 46954, issued May 23, 2017",
     "url": "https://illinoisfoia.org/opinions/letter-46954/"
    }
   ]
  },
  {
   "issue": "Website posting of minutes by the Board",
   "outcome": "no_violation",
   "rule": "OMA's website posting requirement applies only if the public body has a website maintained by its full-time staff; the Township had no such website.",
   "decision": {
    "title": "Meeting minutes approval and website posting",
    "date": "2024-04-12",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-71408/"
   },
   "authorities": [
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 21667, issued October 31, 2012",
     "url": null
    },
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. 21343, issued September 20, 2012",
     "url": null
    }
   ]
  },
  {
   "issue": "Website posting of minutes by the Council",
   "outcome": "violation_found",
   "rule": "A public body with a website maintained by full-time staff must post regular meeting minutes within 10 days of approval; delegating to part-time or elected staff does not avoid the requirement.",
   "decision": {
    "title": "Meeting minutes approval and website posting",
    "date": "2024-04-12",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-71408/"
   },
   "authorities": [
    {
     "text": "Hayashi v. Illinois Department of Financial and Professional Regulation, 2014 IL 116023",
     "url": null
    }
   ]
  },
  {
   "issue": "Committees failed to approve minutes within required timeframe",
   "outcome": "violation_found",
   "rule": "A public body that holds a meeting must approve the minutes of that meeting within 30 days or at its second subsequent regular meeting, whichever is later.",
   "decision": {
    "title": "Procedures for approving and publishing committee meeting minutes",
    "date": "2019-09-17",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-57900/"
   },
   "authorities": []
  },
  {
   "issue": "Committees' meeting minutes not posted online",
   "outcome": "no_violation",
   "rule": "Only a public body that maintains a website and is the governing body must post regular meeting minutes online; committees are not the governing body.",
   "decision": {
    "title": "Procedures for approving and publishing committee meeting minutes",
    "date": "2019-09-17",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-57900/"
   },
   "authorities": []
  },
  {
   "issue": "Timeliness of approval of prior meeting minutes",
   "outcome": "violation_found",
   "rule": "A public body must approve open meeting minutes within 30 days after the meeting or at its second subsequent regular meeting, whichever is later.",
   "decision": {
    "title": "Agenda notice and approval of meeting minutes",
    "date": "2018-04-17",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-50418/"
   },
   "authorities": []
  },
  {
   "issue": "Advisory committee minutes not posted on website",
   "outcome": "no_violation",
   "rule": "Section 2.06(b) requires only the governing body to post its meeting minutes on the public body's website, not advisory committees.",
   "decision": {
    "title": "Advisory committee meeting minutes posted online",
    "date": "2016-03-18",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-40638/"
   },
   "authorities": []
  }
 ]
}