PaFOIC

PNA Legal Hotline: Sunshine Act not violated if quorum not present

From the PNA Legal Hotline

By Teri Henning, General Counsel
and Melissa Melewsky, Media Law Counsel

Pennsylvania Newspaper Association

Q: Our township supervisors held a non-public meeting where two of five current supervisors and one supervisor-elect were present. Is this a Sunshine Law violation?

A: Probably not, although depending upon the topics discussed, the meeting may be inconsistent with the spirit of the law.

The basic rule of the Sunshine Act is that any time a quorum of an agency deliberates agency business; it must do so at an open meeting. There are limited exceptions to this rule, the most common of which are the executive session exceptions, which allow agencies to discuss certain matters behind closed doors, including personnel, litigation, collective bargaining and the purchase or lease of real estate.

In this case, there probably isn’t a quorum because the supervisor-elect isn’t officially a member of the agency and has no real power of office; that typically doesn’t happen until the formal swearing in.

However, if the two supervisors and the supervisor-elect discussed agency business that was not appropriate for a closed-door discussion, the discussion is inconsistent with the intent and spirit of the law. It also sets a bad precedent for future similar discussions.

Elected officials must be very careful to acknowledge the requirements of the Sunshine Act and the rights it creates for the public. The Sunshine Act seeks to create an informed public which is active in government, resulting in better representative government overall. It also provides a measure of accountability that is necessary and appropriate.



Pennsylvania Newspaper Association attorneys provide member newspapers with advice on government access issues.