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OMADetermination Letter (non-binding)Closed no further actionMeeting Conduct & Participation

Thornton Township Board not required to intervene in post-meeting public confrontation

The requester alleged that the Board failed to maintain order and address hostile behavior by an attendee following a special meeting.

Date issued
December 30, 2025
Request number(s)
90893
Public body
Thornton Township Board of Trustees
Statute(s)
5 ILCS 120/2.015 ILCS 120/2.06(g)
Outcome
Closed, no further action

Plain-language summary

A citizen complained to the Attorney General that the Thornton Township Board failed to stop a hostile confrontation that occurred after a public meeting, arguing it discouraged public participation. The PAC reviewed the complaint and concluded that no violation of the Open Meetings Act occurred, though they suggested the Board consider additional security measures if tensions continue. The file is now closed.

Legal question

Whether a public body violates the Open Meetings Act by failing to intervene in a confrontation between members of the public that occurs after a meeting has concluded.

Holding

The PAC determined that no further action is warranted regarding the alleged failure to maintain order at a public meeting.

Summary

A requester alleged that the Thornton Township Board of Trustees violated the Open Meetings Act by failing to maintain order and address hostile behavior from an attendee following a public meeting. The PAC determined that no further action was warranted as the alleged conduct did not constitute a violation of the Act's requirements for meeting procedures.

public meetingmeeting conductpublic participationTownship Board

Reading view (1,515 words)

This reading view follows the source PDF's positioned text blocks. Page headers, repeated office furniture, and lower-margin notes are kept out of the narrative; source notes are available below. Reconstruction is automatic and imperfect — the PDF is the authoritative version, and it's linked on this page.

Dear and Mr. Harris:

This determination is issued pursuant to section 3. 5 (b) of the Open Meetings Act OMA) ( 5 ILCS 120/ 3. 5( b) ( West 2024)). For the reasons set forth below, the Public Access Bureau has determined that no further action is warranted in this matter.

On November 28, 2025, submitted this Request for Review alleging that the Board of Trustees ( Board) for Thornton Township ( Township) violated sections 2. 01 and 2. 06( g) of OMA1 in connection with its November 25, 2025, special meeting. claimed that the Board failed to maintain order after this meeting concluded when an aggressive individual confronted him in the presence of the Board members.

alleged that Board failed to address this behavior and that "[ a] llowing hostile individuals to confront, intimidate, or follow attendees creates a chilling effect on public participation [.]" 2 15 ILCS 120/ 2. 01 ( West 2024); see also 5 ILCS 120/ 2.06( g) (West 2024).

2E- mail from to Public Access Counselor ( November 28, 2025).

During the public comment portion of the meeting, a speaker, Nina Graham ( President of School Board District 205, board member ofDemocrats ofThornton Township, and advisor to Thornton Township Supervisor Napoleon Harris), directly targeted me, pointed at me, and said:

you. When we step outside this door I got a question to ask Told me to " be quiet." Made false accusations against me.

This was not simply commentary — it was targeted personal intimidation directed at a member of the public who was lawfully present. l31 ( Emphasis in original).

Section 3. 5( a) of OMA4 provides:

A person who believes that a violation of this Act by a public body has occurred may file a request for review with the Public Access Counselor established in the Office of the Attorney General not later than 60 days after the alleged violation. * * * The requirement that meetings be open to the public.

Public Comment Section 2. 06( g) of OMA provides that "[ a] ny person shall be permitted an opportunity to address public officials under the rules established and recorded by the public body." The intention of section 2. 06( g) is to guarantee members of the public the right to In its advisory capacity,? the Public Access Bureau reiterates that the General Assembly "declares it to be the public policy ofthis State that its citizens shall be given advance notice of and the right to attend all meetings at which any business of a public body is discussed or acted upon in any way." ( Emphasis added.) 5 ILCS 120/ 1 ( West 2024). It appears from submission that there have been ongoing conflicts between members of the public during and/ or after Board meetings, and that the Board already provides security at meetings and in the parking lot. If these tensions persist or escalate, the Board may wish to consider whether additional measures are necessary to ensure that members of the public are not discouraged from exercising their right to attend Board meetings.

This letter serves to close this file. If you have questions, please contact me at the Chicago address listed on the first page of this letter.

Very truly yours,

CHRISTINA LUCENTE- MCCULLOUGH

Assistant Attorney General Public Access Bureau 90893 ono fi war twp

Notes from the original PDF (4)
  1. 115 South LaSalle Street Chicago, Illinois 60603 Carbondale, Illinois 62903 217) 782- 1090 • Fax: ( 217) 782- 7046 312) 814- 3000 • Fax: ( 312) 814- 3806 618) 529- 6400 • Fax: ( 618) 529- 6416 www. IllinoisAttorneyGeneral. gov
  2. request for review * * * must include a summary of the facts supporting the allegation. ( Emphasis added.) Access to Meetings Under OMA, it is " the public policy of this State that its citizens shall be given advance notice of and the right to attend all meetings at which any business of a public body is discussed or acted upon in any way." 5 OMA provides that "[ a] ll meetings required by this Act to be public shall be held at specified times and places which are convenient and open to the public." 6 3E- mail from to Public Access Counselor ( November 28, 2025). 45 ILCS 120/ 3. 5( a) ( West 2024). 5See 5 ILCS 120/ 1 ( West 2024). 65 ILCS 120/ 2. 01 ( West 2024). Office of the Illinois Attorney General
  3. address public bodies under the rules established by the public body. A public body violates section 2. 06( g) of OMA when it: ( 1) prohibits a member of the public from addressing its members in a manner inconsistent with its established and recorded rules, or (2) prohibits a member of the public from providing public comment pursuant to its established and recorded rules, but those rules unreasonably restrict that person's right to address public officials. I11. Att'y Gen. Pub. Acc. Op. No. 14- 009, issued September 4, 2014, at 5- 7. The Public Access Bureau has previously determined that to warrant further action by this office, a Request for Review concerning public comment must set forth facts indicating that a member of the public attempted to address public officials during an open meeting but was improperly restricted by the public body from doing so. See, for example, I11. Att'y Gen. PAC Req. Rev. Ltr. 42017, issued June 1, 2016, at 1- 2 ( determining that a Request for Review alleging that a board' s public comment rules violated section 2. 06( g) of OMA did not warrant further inquiry because the Request for Review did not allege that anyone who attempted to address the board during an open meeting was improperly denied an opportunity to speak). alleged that during the meeting's public comment period, an individual, Ms. Graham, told him to be quiet and made false accusations against him. However, has not alleged that he was improperly prevented from addressing the Board during the November 25, 2025, meeting. According to his submitted materials, provided public comment about nine minutes into the meeting, just before Ms. Graham spoke. There is no indication that public comments were improperly disrupted by any Office of the Illinois Attorney General
  4. 715 ILCS 205/ 7( a), ( c) ( West 2024) ( authorizing the Public Access Counselor to provide advice and education to public officials and members of the public). Office of the Illinois Attorney General