Haskell v. Grand Forks Public Schools

Citations

• 2026 ND 40

Syllabus

An attorney at a public meeting explaining the legal position of a governing body did not waive the governing body's ability to enter an executive session. A governing body can discuss the value requested by an adverse party without waiving the ability to discuss other adverse fiscal impacts in an executive session. A party seeking disclosure of records withheld as exempt from open records laws does not have a due process right to participate in an in camera review or to access the records for the purpose of fully arguing why the party should have access to them. A district court abuses its discretion if it grants a public entity summary judgment dismissal of an open meetings violation claim without reviewing in camera the short executive session recording that the public entity claims is exempt from disclosure under the attorney consultation exemption.