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When A Meeting Is Public

ORC 121.22 — open meetings, and what a closed one costs

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Ohio's open meetings law starts from a flat statement rather than a balancing test. All meetings of any public body are public meetings open to the public at all times, and a public body takes official action and conducts deliberations on official business only in open meetings, except where the law specifically says otherwise.

Action taken in the wrong room is invalid, not merely improper. A resolution, rule or formal action of any kind is invalid unless adopted in an open meeting. A formal action adopted in an open meeting that results from deliberations in a meeting not open to the public is also invalid, unless those deliberations were for a purpose the section specifically authorises and were conducted at an executive session held in compliance with the section. That is a stronger consequence than most people assume the law carries.

Executive session is the lawful way to close a door, and it is fenced. Members may hold one only after a majority of a quorum determines by roll call vote to do so, only at a regular or special meeting, and only for the sole purpose of considering specific matters the section lists. The motion and the vote have to state which of the authorised purposes the session is for, although they need not name any person to be considered.

  • A majority of a quorum, by roll call vote, at a regular or special meeting.
  • The motion states which listed purpose the session is for.
  • It need not name the person to be considered.
  • Listed purposes include personnel matters such as appointment, employment, dismissal, discipline, promotion, demotion or compensation, and the investigation of charges or complaints.
  • They also include conferring with legal counsel about pending or imminent court action, and preparing for collective bargaining.

Enforcement is not reserved to anyone in particular. Any person may bring an action within two years after the date of the alleged violation or threatened violation. On proof of a violation or threatened violation the court of common pleas shall issue an injunction compelling compliance, and where it issues one it shall order the public body to pay a civil forfeiture of five hundred dollars to the party who sought the injunction, along with court costs and reasonable attorney's fees, subject to the reduction the section describes.

The questionWhat 121.22 says
Who may sueAny person
By whenWithin two years of the violation or threatened violation
What the court does on proofShall issue an injunction
What follows an injunctionFive hundred dollar civil forfeiture, costs and fees
What a closed door vote is worthInvalid

The full list of authorised executive session purposes, the bodies the section does and does not reach, the notice rules each public body has to adopt for itself, and the circumstances in which attorney's fees are reduced are all in the section and are not reproduced here. Whether a particular gathering was a meeting of a public body at all is a contested question in its own right. The Ohio Attorney General publishes a Sunshine Laws manual covering both the open meetings and public records halves. Whether a specific action is invalid is a question for a court and for a licensed Ohio attorney.

Sources for this section (1)
  1. ORC 121.22Public meetings, executive sessions, and the exceptions

Legal information, not legal advice. Verified as of September 2026. Talk to a licensed Ohio attorney about your situation.

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