Cal. Codes » Government Code / TITLE 5. LOCAL AGENCIES / DIVISION 2. CITIES, COUNTIES, AND OTHER AGENCIES / PART 1. POWERS AND DUTIES COMMON TO CITIES, COUNTIES, AND OTHER AGENCIES / CHAPTER 9. Meetings
California Codes

Cal. Government Code § 54952.2 (2026)

Meetings — Powers And Duties Common To Cities, Counties, And Other Agencies

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(a)As used in this chapter, “meeting” means any congregation of a majority of the members of a legislative body at the same time and location, including teleconference location as permitted by Section 54953, to hear, discuss, deliberate, or take action on any item that is within the subject matter jurisdiction of the legislative body.

(b)(1)A majority of the members of a legislative body shall not, outside a meeting authorized by this chapter, use a series of communications of any kind, directly or through intermediaries, to discuss, deliberate, or take action on any item of business that is within the subject matter jurisdiction of the legislative body.

(2)Paragraph (1) shall not be construed as preventing an employee or official of a local agency, from engaging in separate conversations or communications outside of a meeting authorized by this chapter with members of a legislative body in order to answer questions or provide information regarding a matter that is within the subject matter jurisdiction of the local agency, if that person does not communicate to members of the legislative body the comments or position of any other member or members of the legislative body.

(3)(A)Paragraph (1) shall not be construed as preventing a member of the legislative body from engaging in separate conversations or communications on an internet-based social media platform to answer questions, provide information to the public, or to solicit information from the public regarding a matter that is within the subject matter jurisdiction of the legislative body provided that a majority of the members of the legislative body do not use the internet-based social media platform to discuss among themselves business of a specific nature that is within the subject matter jurisdiction of the legislative body. A member of the legislative body shall not respond directly to any communication on an internet-based social media platform regarding a matter that is within the subject matter jurisdiction of the legislative body that is made, posted, or shared by any other member of the legislative body.

(B)For purposes of this paragraph, all of the following definitions shall apply:

(i)“Discuss among themselves” means communications made, posted, or shared on an internet-based social media platform between members of a legislative body, including comments or use of digital icons that express reactions to communications made by other members of the legislative body.

(ii)“Internet-based social media platform” means an online service that is open and accessible to the public.

(iii)“Open and accessible to the public” means that members of the general public have the ability to access and participate, free of charge, in the social media platform without the approval by the social media platform or a person or entity other than the social media platform, including any forum and chatroom, and cannot be blocked from doing so, except when the internet-based social media platform determines that an individual violated its protocols or rules.

(c)Nothing in this section shall impose the requirements of this chapter upon any of the following:

(1)Individual contacts or conversations between a member of a legislative body and any other person that do not violate subdivision (b).

(2)The attendance of a majority of the members of a legislative body at a conference or similar gathering open to the public that involves a discussion of issues of general interest to the public or to public agencies of the type represented by the legislative body, provided that a majority of the members do not discuss among themselves, other than as part of the scheduled program, business of a specified nature that is within the subject matter jurisdiction of the local agency. Nothing in this paragraph is intended to allow members of the public free admission to a conference or similar gathering at which the organizers have required other participants or registrants to pay fees or charges as a condition of attendance.

(3)The attendance of a majority of the members of a legislative body at an open and publicized meeting organized to address a topic of local community concern by a person or organization other than the local agency, provided that a majority of the members do not discuss among themselves, other than as part of the scheduled program, business of a specific nature that is within the subject matter jurisdiction of the legislative body of the local agency.

(4)The attendance of a majority of the members of a legislative body at an open and noticed meeting of another body of the local agency, or at an open and noticed meeting of a legislative body of another local agency, provided that a majority of the members do not discuss among themselves, other than as part of the scheduled meeting, business of a specific nature that is within the subject matter jurisdiction of the legislative body of the local agency.

(5)The attendance of a majority of the members of a legislative body at a purely social or ceremonial occasion, provided that a majority of the members do not discuss among themselves business of a specific nature that is within the subject matter jurisdiction of the legislative body of the local agency.

(6)The attendance of a majority of the members of a legislative body at an open and noticed meeting of a standing committee of that body, provided that the members of the legislative body who are not members of the standing committee attend only as observers.

Notes of Decisions
Cited in 13 cases (6 in the last 5 years), 1998–2025 · leading case: Golightly v. Molina, 229 Cal. App. 4th 1501 (Cal. Ct. App. 2014).
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Golightly v. Molina, 229 Cal. App. 4th 1501 (Cal. Ct. App. 2014). · cites it 2× “(Gov. Code, § 54952.2.) The four SPA signatories do not constitute a legislative body and do not deliberate collectively in approving an SPA.”
Pac. Shores Props., LLC v. City of Newport Beach, 730 F.3d 1142 (9th Cir. 2013). “The Plaintiffs suggest that having committee meetings in private violated California's open meeting law, Cal. Gov't Code § 54952.2 . This appears to be incorrect.”
Wood v. Battle Ground Sch. Dist., 27 P.3d 1208 (Wash. Ct. App. 2001). “, CAL. GOV'T CODE § 54952.2(a) and (b) (1994) (defining "meeting" as "any congregation of a majority of the members of a legislative body at the same time and place to hear, discuss, or deliberate" and directing that "any use of direct communication, personal intermediaries, or…”
Del Papa v. Bd. of Regents of the Univ. & Cmty. Coll. Sys., 956 P.2d 770 (Nev. 1998). · cites it 2× “[A]ny use of direct communication, personal intermediaries, or technological devices that is employed by a majority of the members of the legislative body to develop a collective concurrence as to action to be taken on an item by members of the legislative body is prohibited.”
Untitled California Attorney Gen. Opinion, No. 18-201 (Cal. Att'y Gen. Sept. 17, 2021). · cites it 7× “4 18-201 them from holding closed sessions, with certain statutory exceptions. 18 Further, the Act’s open meetings requirement may not be evaded through “serial” meetings.”
JHS Fam. Ltd. P'ship v. Cnty. of Fresno, No. F087092 (Cal. Ct. App. Nov. 15, 2024). · cites it 2× “(Gov. Code, § 54952.2, former subds. (a), (b)(1), added by Stats.”
Atwell Island Water Dist. v. Atwell Island Water Dist., 258 Cal. Rptr. 3d 917 (Cal. Ct. App. 2020). “4th 1196, 1198 ; Gov. Code, § 54952.2, subd. (a).) “ ‘[T]wo or more persons are required in order to conduct a “meeting” within the meaning of the [Brown] Act.”
Atwell Island Water Dist. v. Atwell Island Water Dist., No. F076043M (Cal. Ct. App. Feb. 27, 2020). “4th 1196, 1198 ; Gov. Code, § 54952.2, subd. (a).) “ ‘[T]wo or more persons are required in order to conduct a “meeting” within the meaning of the [Brown] Act.”
Daly v. San Bernardino Cnty. Bd. of Supervisors, 492 P.3d 921 (Cal. 2021). “Plaintiffs sought a judicial determination that the initial nomination process violated two provisions of the Brown Act: Government Code section 54952.2, subdivision (b)(1), barring the use of seriatim communications in lieu of a meeting, and Government Code section 54953,…”
LNSU 1, LLC v. Alta Del Mar Coastal Collection Cmty. Assn., 94 Cal. App. 5th 1050 (Cal. Ct. App. 2023). “475 ), the Legislature provided: “A majority of the members of a legislative body shall not, outside a meeting authorized by this chapter, use a series of communications of any kind, directly or through intermediaries, to discuss, deliberate, or take action on any item of…”
Royer v. Los Rios Cmty. Coll. Dist., No. C096484 (Cal. Ct. App. Mar. 5, 2024). “” (Gov. Code, § 54952.2, subd. (a).) A legislative body includes the governing board of a community college district.”
California Attorney Gen. Opinion 24-102, No. 24-102 (Cal. Att'y Gen. May 8, 2025). “60 Gov. Code, § 54952.2, subd. (a); see also Sacramento Newspaper Guild v.”
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Cal. Government Code § 54952.2(a): 1 case
Wood v. Battle Ground Sch. Dist., 27 P.3d 1208 (Wash. Ct. App. 2001). “, CAL. GOV'T CODE § 54952.2(a) and (b) (1994) (defining "meeting" as "any congregation of a majority of the members of a legislative body at the same time and place to hear, discuss, or deliberate" and directing that "any use of direct communication, personal intermediaries, or…”
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