OMA section 2a
OMA5 ILCS 120/2a. Section 2a overview: A closed session requires an actual roll-call vote, taken in open session, citing the specific exception being relied on -- you can't just decide to go behind closed doors informally.
16 issues across 14 determination letters:6 violation found · 9 no violation · 1 no determination / resolved.
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 Determination letters are not binding precedent.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
- A finance committee's closed meeting on a hiring freeze (Pub. Acc. Op. No. 15-007) cited 5 times
- Wyman v. Schweighart, 385 Ill. App. 3d 1099, 1105 (2008) cited 4 times
- Closed-session discussion of a police services contract (Pub. Acc. Op. No. 15-005) cited 1 times
- Closed-session vote citing pending litigation (PAC Req. Rev. Ltr. 59813) 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 Determination letters are not binding precedent and this is not legal advice.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 used only a general term like 'personnel' instead of citing the specific statutory exception when voting to close the meeting. The OMA requires public disclosure of the specific exception; a mere reference to 'personnel' is insufficient.Based on: 2022 · A school board's closed-session d… · 2019 · A board's failure to cite a close… · 2019 · A village board's closed-session …
- The public body failed to record the specific statutory exception in the open session minutes. The OMA requires that the specific exception be recorded in the minutes; a generic reference is not enough.Based on: 2022 · Closed-session minutes and remote… · 2019 · A village board's closed-session …
- The public body did not hold an open session vote before entering closed session. A public body must convene an open session and publicly vote to enter closed session, even if the meeting's purpose is a closed session.Based on: 2018 · A public meeting on a legal holid…
- The public body only referenced an agenda item instead of identifying the specific exception at the time of the vote. The body must adequately identify the specific section 2(c) exception at the time of the vote, not merely reference the agenda item.Based on: 2016 · A school board's public comment r…
- The minutes do not show the vote of each member on the motion to close the meeting. The vote of each member on closing a meeting must be recorded in the minutes.Based on: 2025 · A board's meeting minutes and vot…
When the public body usually wins
- The public body did not list the closed session exception on the meeting agenda. OMA does not require the agenda to list the specific closed session exceptions; the body only needs to cite the exception at the time of the vote.Based on: 2026 · Appointment of a park district bo… · 2018 · Closed-session discussion of a bi…
- The public body used descriptive language that sufficiently identified the exception, like 'pending litigation,' rather than a statutory number. Section 2a does not require a specific statutory citation as long as the body adequately identifies the exception.Based on: 2019 · Closed-session vote citing pendin… · 2024 · Closed-session discussion of a vo…
- The public body conducted a unanimous voice vote rather than a roll call vote to enter closed session. Section 2a does not require a roll call vote; a unanimous voice vote publicly discloses each member's vote.Based on: 2019 · Closed-session vote citing pendin… · 2022 · Closed-session minutes and remote…
- The public body cited the specific exception numbers (e.g., 'section 2(c)(1)') before closing. Citing the specific exception numbers is sufficient to meet the requirement.Based on: 2018 · Closed-session discussion of pote…
Points to put in your letter
- If the body only said 'personnel' or another general term, state that the OMA requires the specific statutory exception to be cited publicly and recorded in the minutes.Based on: 2022 · A school board's closed-session d… · 2019 · A board's failure to cite a close… · 2019 · A village board's closed-session …
- If the minutes do not include the specific exception cited for closing, point out that the open session minutes must record that exception.Based on: 2022 · Closed-session minutes and remote… · 2019 · A village board's closed-session …
- If there was no open session vote before the closed session, argue that the body must convene an open session and publicly vote to close.Based on: 2018 · A public meeting on a legal holid…
- If the body only referenced an agenda item, argue that the exception must be identified at the time of the vote, not just by reference to the agenda.Based on: 2016 · A school board's public comment r…
- If the minutes do not show each member's vote on closing, point out that the vote of each member must be recorded.Based on: 2025 · A board's meeting minutes and vot…
Common mistakes
- Assuming that the agenda must list the closed session exception.Based on: 2026 · Appointment of a park district bo… · 2018 · Closed-session discussion of a bi…
- Assuming that a roll call vote is required to enter closed session.Based on: 2019 · Closed-session vote citing pendin… · 2022 · Closed-session minutes and remote…
- Assuming that a descriptive phrase like 'pending litigation' is insufficient because it's not a statutory number.Based on: 2019 · Closed-session vote citing pendin… · 2024 · Closed-session discussion of a vo…
- Assuming that the body must discuss every topic it anticipated in closed session.Based on: 2019 · County board minutes of closed-se…
Facts to gather first
- Whether the public body stated a specific statutory exception (like a section number) or only used a general term like 'personnel'.
- Whether the open session minutes record the specific exception cited for closing.
- Whether the body held an open session and took a public vote before going into closed session.
- Whether the minutes show the vote of each member on the motion to close.
- Whether the body's citation at the vote matched the exception or was just a reference to an agenda item.
These notes are based on non-binding determination letters from the Public Access Bureau; outcomes depend on specific facts, and you should verify the full text of any cited decision.
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-2a.json.
Violation found (6)
Closed session procedure at May 25, 2021 meeting
Rule: Before entering closed session, a public body must publicly disclose a citation to the specific exception in Section 2 of OMA that authorizes closing, not just a general reference like "personnel."
Violation found A school board's closed-session discussions and failure to review minutes · April 14, 2022
Closed session minutes lacked exception citation
Rule: When voting to close a meeting, the public body must publicly disclose and record in the minutes the specific statutory exception authorizing the closure.
Violation found Closed-session minutes and remote meeting notice · March 16, 2022
Inadequate citation of closed session exception
Rule: A public body must publicly cite the specific statutory exception authorizing a closed session; a mere reference to 'personnel' is insufficient.
Violation found A board's failure to cite a closed-session exception · July 12, 2019
Closed session procedure and minutes exception citation
Rule: A public body must record the specific statutory exception for closing a meeting in the open session minutes; a generic reference to 'personnel' is insufficient.
Violation found A village board's closed-session discussion of personnel matters · May 6, 2019
Closed session without open vote
Rule: A public body must convene an open session and publicly vote to enter closed session, even if the meeting's purpose is a closed session.
Violation found A public meeting on a legal holiday at a locked facility · March 28, 2018
Failure to identify closed session exception at vote
Rule: A public body must adequately identify the specific section 2(c) exception at the time of the vote to close, not merely reference the agenda item.
Violation found A school board's public comment restrictions and closed-session justification · December 12, 2016
No violation (9)
Failure to list closed session exception in agenda
Rule: OMA does not require a public body to list the specific closed session exceptions in the meeting agenda, though it must still follow section 2a procedures for closing a meeting.
No violation Appointment of a park district board commissioner · June 12, 2026
Closed meeting procedure citation
Rule: A public body may satisfy section 2a by stating the statutory subsection of the exception or reciting language that sufficiently identifies it.
No violation Closed-session discussion of a volunteer's performance and FOIA strategy · January 12, 2024
Minutes vote tally complied with section 2a
Rule: Section 2a does not require a roll call vote to enter closed session; a unanimous vote with each member listed satisfies the requirement to publicly disclose each member's vote.
No violation Closed-session minutes and remote meeting notice · March 16, 2022
Closed session procedure and citation to exception
Rule: The public body publicly identified the correct exception by subsection and language before closing, and corrected a typographical error in the minutes, so no violation of section 2a occurred.
No violation Closed-session discussion of a mayor's salary · April 29, 2022
Closed session minutes inadequate for collective bargaining discussion
Rule: OMA does not require a public body to discuss in closed session all topics it anticipated, and speculative allegations without supporting facts do not warrant further action.
No violation County board minutes of closed-session motions · December 19, 2019
Voice vote procedure for entering closed session
Rule: Section 2a does not require a roll call vote; a unanimous voice vote publicly discloses each member's vote and the chairman has discretion in conducting the vote.
No violation Closed-session vote citing pending litigation · September 26, 2019
Citation to exception for entering closed session
Rule: Section 2a does not require a specific statutory citation as long as the public body adequately identifies the exception; referencing 'pending litigation' sufficiently identified section 2(c)(11).
No violation Closed-session vote citing pending litigation · September 26, 2019
Agenda did not list exception for closed session
Rule: A public body may decide to go into closed session during a properly noticed open meeting without listing the closed session or its topics on the agenda, as long as it publicly cites the specific exception at the time of the vote.
No violation Closed-session discussion of a bidding process · March 28, 2018
Sufficiency of public citation before closed session
Rule: Citing the specific exception numbers in the Open Meetings Act is sufficient to meet the requirement to publicly disclose the citation to the specific exception authorizing closed session.
No violation Closed-session discussion of potential litigation · February 1, 2018
No determination / resolved (1)
Failure to record closed session vote in April 23, 2025 minutes
Rule: The vote of each member on closing a meeting must be recorded in the minutes; the Board acknowledged failure and agreed to approve revised minutes, resolving the issue.
No determination / resolved A board's meeting minutes and vote documentation · December 12, 2025