OMA section 2(a)

OMA

Openness required

5 ILCS 120/2(a). Openness required (the basic open-meetings mandate, subject to the Sec. 2(c) exceptions)

See every document citing this provision →

11 issues across 11 determination letters:7 violation found · 4 no violation.

Counts are per issue, not per letter, and come from automated extraction checked against sampled letters. Determination letters are not binding precedent.

Authorities the Bureau cites most on this issue

People ex rel. Difanis v. Barr, 83 Ill. 2d 191, 202 (1980) cited 3 times
Nabhani v. Coglianese, 552 F. Supp. 657, 661 (N.D. Ill. 1982) cited 3 times
Gosnell v. Hogan, 179 Ill. App. 3d 161, 170 (1989) cited 3 times
Closed-session discussion of employee pay raises (Pub. Acc. Op. No. 16-013) cited 2 times
Closed-session discussion of municipal budgetary matters (Pub. Acc. Op. No. 12-011) cited 2 times
Unannounced pre-meeting gatherings and a blocked board meeting (PAC Req. Rev. Ltr. 49828) cited 1 times
A finance committee's closed meeting on a hiring freeze (Pub. Acc. Op. No. 15-007) cited 1 times

How to challenge a denial on this issue

AI-generated summary of the decisions listed on this page, with each point linked to the letters it comes from. Determination letters are not binding precedent and this is not legal advice. Open the letter and check the PDF before relying on any point.

When a challenge is strong

The public body held a meeting at a location that was not convenient and open to the public. OMA requires meetings to be at a time and place specified in the agenda and at a location convenient and open to the public.Based on: 2019 · A committee's closed-session meet…
A majority of a quorum of the public body gathered and discussed public business without providing notice. Such a gathering is a meeting subject to OMA notice requirements.Based on: 2019 · A committee meeting with a quorum… · 2017 · An unannounced council gathering …
The public was effectively excluded from a portion of an open meeting. A public body violates OMA when it restricts the public from attending any part of an open meeting.Based on: 2024 · A planning commission's closed-do…
The public body held a secret pre-meeting discussion of public business without an applicable exception. All meetings must be open unless a specific exception applies.Based on: 2021 · A board's private discussion of e…
The closed session discussion went beyond the scope of the cited OMA exception, such as discussing general duties instead of specific employee performance. Discussing matters not within the exception violates OMA.Based on: 2018 · Closed-session discussion of a bi… · 2018 · Closed-session discussion of poli…

When the public body usually wins

A majority of a quorum gathered but did not deliberate public business, and precautions were taken to prevent such deliberation. A gathering is not a meeting unless members deliberate public business together.Based on: 2024 · A board's transit discussion of p…
The public body seated members before the meeting but did not begin discussing public business until the public was admitted and the meeting was called to order. Seating members beforehand is permissible absent improper deliberation.Based on: 2022 · A housing authority's locked meet…
The meeting was a truly political party meeting, not a meeting of a public body. OMA does not apply to such meetings.Based on: 2015 · A political party precinct commit…
The requester lacks sufficient evidence to show a notice or agenda violation. The available information did not show a violation.Based on: 2022 · Website posting of meeting agenda…

Points to put in your letter

State that the meeting was held at a location that was not convenient and open to the public, and provide details.Based on: 2019 · A committee's closed-session meet…
Explain that a majority of a quorum gathered and discussed public business without the required notice, and describe the gathering.Based on: 2019 · A committee meeting with a quorum… · 2017 · An unannounced council gathering …
Assert that the public was excluded from a portion of the open meeting, and specify when and how.Based on: 2024 · A planning commission's closed-do…
Argue that the closed session discussion exceeded the scope of the cited exception, and list the topics discussed.Based on: 2018 · Closed-session discussion of poli… · 2018 · Closed-session discussion of a bi…
Claim that a secret pre-meeting discussion of public business occurred without an applicable exception, and provide evidence.Based on: 2021 · A board's private discussion of e…

Common mistakes

Assuming that any gathering of a majority of a quorum is automatically a meeting, even if no public business was discussed.Based on: 2024 · A board's transit discussion of p…
Believing that seating members before a meeting is itself a violation, without evidence of improper deliberation.Based on: 2022 · A housing authority's locked meet…
Thinking that all closed sessions are improper, rather than focusing on whether the discussion stayed within the scope of the cited exception.Based on: 2018 · Closed-session discussion of a bi… · 2018 · Closed-session discussion of poli…
Failing to gather specific evidence of a notice or agenda violation, leading to an unsupported claim.Based on: 2022 · Website posting of meeting agenda…
Assuming OMA applies to political party meetings that are not meetings of a public body.Based on: 2015 · A political party precinct commit…

Facts to gather first

Whether a majority of a quorum was present and discussed public business.
The location of the meeting and whether it was accessible to the public.
Whether the public was excluded from any part of the meeting.
The topics discussed in closed session and the exceptions cited by the public body.
Any evidence of pre-meeting discussions, including what was discussed and when.

These determination letters are non-binding, and outcomes depend on specific facts; always verify the full PDF for context.

Drafting brief for an AI assistant

Copy this into your assistant to help draft a request, appeal, or challenge to a denial that turns on this issue. It carries the rules and decisions, not your facts: add those yourself. Machine-readable version: oma-2-a.json.

TOPIC: 5 ILCS 120/2(a) - Openness required
SOURCE: Illinois Attorney General Public Access Bureau decisions compiled at https://illinoisfoia.org/issues/oma-2-a/
NOTE: Determination letters are not binding precedent; they show how the Bureau applies the law. Verify every decision against the source PDF before citing it.

VIOLATION FOUND (7):
- Public excluded from portion of meeting
  Rule: A public body violates OMA when it effectively restricts the public from attending a portion of an open meeting.
  Decision: A planning commission's closed-door discussion after a public hearing (non-binding determination letter, July 2, 2024) https://illinoisfoia.org/opinions/letter-74390/
- Pre-meeting discussion violated open meeting requirement
  Rule: All meetings of public bodies must be open to the public unless a specific exception applies; no exception applied to the Board's secret pre-meeting discussion.
  Decision: A board's private discussion of equipment purchases (non-binding determination letter, January 26, 2021) https://illinoisfoia.org/opinions/letter-65448/
- Meeting held at location not convenient and open to public
  Rule: A public body must hold meetings at the time and place specified in the agenda and at a location convenient and open to the public.
  Decision: A committee's closed-session meeting at an undisclosed location without a recording (non-binding determination letter, March 7, 2019) https://illinoisfoia.org/opinions/letter-55379/
- Committee meeting transformed into unnotified Board meeting
  Rule: A gathering of a majority of a quorum of a public body for discussing public business is a meeting subject to OMA notice requirements.
  Decision: A committee meeting with a quorum of the village board (non-binding determination letter, December 6, 2019) https://illinoisfoia.org/opinions/letter-48812/
- Unauthorized closed session discussions
  Rule: The Committee discussed police department consolidation, which is not within any OMA exception, and other topics beyond the scope of the cited exceptions.
  Decision: Closed-session discussion of police service consolidation (non-binding determination letter, April 18, 2018) https://illinoisfoia.org/opinions/letter-51987/
- Closed session discussion outside scope of 2(c)(1) exception
  Rule: A public body violates OMA by discussing matters in closed session that do not fall within the scope of the cited exception, such as general duties rather than specific employee performance.
  Decision: Closed-session discussion of a bidding process (non-binding determination letter, March 28, 2018) https://illinoisfoia.org/opinions/letter-51599/
- City Council held meeting without OMA compliance
  Rule: A gathering of a majority of a quorum of a public body to discuss public business must comply with OMA's notice and other requirements.
  Decision: An unannounced council gathering to discuss water business (non-binding determination letter, November 1, 2017) https://illinoisfoia.org/opinions/letter-49874/

NO VIOLATION (4):
- Non-public meeting during train and shuttle trip
  Rule: A gathering of a majority of a quorum is not a meeting unless members deliberate public business together; precautions prevented such deliberation.
  Decision: A board's transit discussion of public business (non-binding determination letter, May 10, 2024) https://illinoisfoia.org/opinions/letter-77651/
- March 30, 2022 special meeting notice and agenda
  Rule: The available information did not show the Board violated OMA notice or agenda requirements for its March 30, 2022 special meeting.
  Decision: Website posting of meeting agendas and minutes (non-binding determination letter, September 20, 2022) https://illinoisfoia.org/opinions/letter-71528/
- Improper discussion of public business before public admitted
  Rule: No violation where the Board did not begin discussing public business until the public entered and the meeting was called to order; seating members beforehand is permissible absent improper deliberation.
  Decision: A housing authority's locked meeting room and delayed entry (non-binding determination letter, January 18, 2022) https://illinoisfoia.org/opinions/letter-68606/
- Whether partisan precinct committeemen meeting is a public body under OMA
  Rule: OMA does not apply to truly political meetings at which party business is discussed, as they are not meetings of a public body.
  Decision: A political party precinct committeemen meeting (non-binding determination letter, June 29, 2015) https://illinoisfoia.org/opinions/letter-35946/

MOST-CITED AUTHORITIES: People ex rel. Difanis v. Barr, 83 Ill. 2d 191, 202 (1980); Nabhani v. Coglianese, 552 F. Supp. 657, 661 (N.D. Ill. 1982); Gosnell v. Hogan, 179 Ill. App. 3d 161, 170 (1989); Ill. Att'y Gen. Pub. Acc. Op. No. 16-013; Ill. Att'y Gen. Pub. Acc. Op. No. 12-011; Ill. Att'y Gen. PAC Req. Rev. Ltr. 49828

TASK FOR THE ASSISTANT: Using only the decisions above, help draft a letter. Argue from the rule and cite the decision by name and date. Do not invent decisions.

Violation found (7)

Public excluded from portion of meeting
Rule: A public body violates OMA when it effectively restricts the public from attending a portion of an open meeting.
Violation found A planning commission's closed-door discussion after a public hearing · July 2, 2024
Pre-meeting discussion violated open meeting requirement
Rule: All meetings of public bodies must be open to the public unless a specific exception applies; no exception applied to the Board's secret pre-meeting discussion.
Violation found A board's private discussion of equipment purchases · January 26, 2021
Meeting held at location not convenient and open to public
Rule: A public body must hold meetings at the time and place specified in the agenda and at a location convenient and open to the public.
Violation found A committee's closed-session meeting at an undisclosed location without a recording · March 7, 2019
Committee meeting transformed into unnotified Board meeting
Rule: A gathering of a majority of a quorum of a public body for discussing public business is a meeting subject to OMA notice requirements.
Violation found A committee meeting with a quorum of the village board · December 6, 2019
Unauthorized closed session discussions
Rule: The Committee discussed police department consolidation, which is not within any OMA exception, and other topics beyond the scope of the cited exceptions.
Violation found Closed-session discussion of police service consolidation · April 18, 2018
Closed session discussion outside scope of 2(c)(1) exception
Rule: A public body violates OMA by discussing matters in closed session that do not fall within the scope of the cited exception, such as general duties rather than specific employee performance.
Violation found Closed-session discussion of a bidding process · March 28, 2018
City Council held meeting without OMA compliance
Rule: A gathering of a majority of a quorum of a public body to discuss public business must comply with OMA's notice and other requirements.
Violation found An unannounced council gathering to discuss water business · November 1, 2017

No violation (4)

Non-public meeting during train and shuttle trip
Rule: A gathering of a majority of a quorum is not a meeting unless members deliberate public business together; precautions prevented such deliberation.
No violation A board's transit discussion of public business · May 10, 2024
March 30, 2022 special meeting notice and agenda
Rule: The available information did not show the Board violated OMA notice or agenda requirements for its March 30, 2022 special meeting.
No violation Website posting of meeting agendas and minutes · September 20, 2022
Improper discussion of public business before public admitted
Rule: No violation where the Board did not begin discussing public business until the public entered and the meeting was called to order; seating members beforehand is permissible absent improper deliberation.
No violation A housing authority's locked meeting room and delayed entry · January 18, 2022
Whether partisan precinct committeemen meeting is a public body under OMA
Rule: OMA does not apply to truly political meetings at which party business is discussed, as they are not meetings of a public body.
No violation A political party precinct committeemen meeting · June 29, 2015