Monitor v. Jefferson High School District No. 1
Montana Supreme Court
316 P.3d 848 (2013)
The Jefferson County High School Board (the board) established a three-member budget subcommittee. Open-meeting statutes, as well as right-to-know state constitutional protections, granted the public the right to attend public-agency meetings held with an agency quorum. For the board, four members constituted a quorum. During a meeting of the whole school board, the board gave notice that its budget subcommittee would meet. All three subcommittee members attended the meeting; a fourth board member asked several questions from the audience. At the meeting, the subcommittee decided to recommend a lower salary for an open principal position to the full school board. The superintendent present at the subcommittee meeting opined that the proposed salary might only attract two of four candidates. At the next full school board meeting, the board accepted the subcommittee’s budget recommendations. The Boulder Monitor (plaintiff) routinely sent reporters to attend full board meetings. The Monitor received notice of the subcommittee meeting but chose not to send a reporter. The Monitor sued the board’s school district (defendant) in state court, claiming the subcommittee meeting constituted a meeting of the whole school board because there were four members in attendance. The Monitor also claimed that the subcommittee’s actions went beyond the budgetary purpose of the meeting as stated in the meeting notice and actually involved making personnel decisions. The school district argued instead that it complied with all notice and open-meeting requirements, that the Monitor had received notice, and that the Monitor chose not to send a reporter to the subcommittee meeting. Both sides filed motions for summary judgment with the state trial court. The trial court granted the Monitor’s motion for summary judgment. The school district appealed to the state supreme court.
Rule of Law
Holding and Reasoning (McGrath, C.J.)
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