Barrett v. Lode
Iowa Supreme Court
603 N.W.2d 766 (1999)
On November 14, 1994, the school board of directors for a school district located in Aurelia, Iowa, held a meeting to discuss the midsemester review of its superintendent, Marlin Lode (defendant). Prior to the meeting, each board member received a memorandum from Lode. The memorandum stated that one of the district’s board members recommended that Lode’s performance review be discussed in closed session unless the press voluntarily left the meeting. The memorandum also stated that the discussion was expected to include the district’s administrative needs for the following school year. However, the agenda for the meeting only identified the subject matter as a midsemester review of administrative performance. A news reporter who attended the meeting wrote an article stating that the meeting ended with the board convening in closed session. However, it was later discovered that because the members of the press left the meeting, the school board did not convene in closed session. Patricia Barrett (plaintiff), a member of the school board, filed suit against the remaining members of the school board (defendants) and Lode, asserting that they violated Iowa’s open-meetings law because they failed to properly identify the subject matter of the discussion on the agenda and because they held a de facto closed-session meeting without a vote by the board and without tape-recording the discussion. The news reporter submitted an affidavit to the court asserting that the only reason she left the meeting was because Lode advised her that the board would be completing the meeting in closed session. At trial, Lode challenged the news reporter’s testimony and denied asking the media to leave. The district court determined that the agenda’s identification of administrative performance reasonably encompassed both Lode’s job performance and the future staffing needs of the district. Accordingly, the district court held that the agenda did not violate the open-meetings law. The district court also concluded that there was not a de facto closed-session meeting, because Lode spoke to the news reporter independently and without the knowledge of the board members and Lode was not a member of the board. The district court granted summary judgment in favor of the board and Lode. Barrett filed an appeal.
Rule of Law
Holding and Reasoning (Carter, J.)
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