City sought review of determination by Freedom of Information Commission that gathering of four members of its city council, the city’s mayor, and the retiring city manager to discuss the search for a new city manager violated open meeting requirements of the Freedom of Information Act (FOIA).
The Superior Court dismissed. City appealed.
The Appellate Court held that gathering did not constitute a “meeting” triggering FOIA open meeting requirements.
Gathering of four political leaders of a city council, the city’s mayor, and the retiring city manager to discuss the search for a new city manager did not constitute a “meeting” triggering opening meeting requirements of the Freedom of Information Act, where no quorum was present and the gathering did not constitute a hearing or other proceeding.