Editor's notes.

- In light of the similarity of the statutory provisions, decisions under former Ga. L. 1972, p. 575, which was subsequently repealed but was succeeded by provisions in this Code section, are included in the annotations for this Code section.

Applicability of Act.

- Test for applicability of the Open Meetings Act, O.C.G.A. Ch. 14, T. 50, is two-pronged: first, is the meeting one of a "governing body of an agency" or any committee thereof; and second, is the meeting one "at which official business or policy of the agency is to be discussed or at which official action is to be taken?" Crosland v. Butts County Bd. of Zoning Appeals, 214 Ga. App. 295, 448 S.E.2d 454 (1994).

Construction of Act.

- Open Meetings Act, O.C.G.A. Ch. 14, T. 50, must be broadly construed to effect the Act's purpose of protecting the public and individuals from closed door meetings. Jersawitz v. Fortson, 213 Ga. App. 796, 446 S.E.2d 206 (1994); Crosland v. Butts County Bd. of Zoning Appeals, 214 Ga. App. 295, 448 S.E.2d 454 (1994).

In view of the General Assembly's intent, the correct reading of the Open Meetings Act, O.C.G.A. § 50-14-1(e)(2), and the one that is most natural and reasonable, is that, having first mandated that meeting minutes include a record of all votes, the paragraph then sets forth alternative requirements for accurately recording individuals' votes in the case of both roll-call and non-roll-call votes; in the case of a non-roll-call vote, the minutes must list the names of those voting against a proposal or abstaining, and if no such names are listed, the public may correctly presume that the vote was unanimous, but if such names are listed, a member of the public need only look at the list of voting officials in attendance at the meeting to determine who voted for a proposal. Cardinale v. City of Atlanta, 290 Ga. 521, 722 S.E.2d 732 (2012).

Physical access not required.

- Open Meetings Act, O.C.G.A. Ch. 14, T. 50, requires adequate, advance notice of a meeting, not physical access to all members of the public. Maxwell v. Carney, 273 Ga. 864, 548 S.E.2d 293 (2001).

Language of this section is clear, the language applies to the meetings of the variously described bodies which are empowered to act officially for the state and at which such official action is taken. McLarty v. Board of Regents of Univ. Sys., 231 Ga. 22, 200 S.E.2d 117 (1973) (decided under former Ga. L. 1972, p. 575).

Unauthorized groups.

- This section does not encompass the innumerable groups which are organized and meet for the purpose of collecting information, making recommendations, and rendering advice but which have no authority to make governmental decisions and act for the state. McLarty v. Board of Regents of Univ. Sys., 231 Ga. 22, 200 S.E.2d 117 (1973) (decided under former Ga. L. 1972, p. 575).

Agency did not include employees.

- County's sheriff and district attorney were not required to release records relating to an inmate's death in custody under the Open Records Act, O.C.G.A. § 50-14-1 et seq., because the records came within the "pending prosecution" exemption to disclosure in O.C.G.A. § 50-18-72(a)(4). The exception for agencies under investigation did not apply because "agency," as defined in O.C.G.A. §§ 50-14-1(a)(1)(C) and50-18-70(b), was not synonymous with "employee," and the agency itself was not under investigation. Media Gen. Operations, Inc. v. St. Lawrence, 337 Ga. App. 428, 787 S.E.2d 778 (2016).

Construed with Recall Act.

- Conduct of a public official who participates in a closed meeting that is required by law to be open can become a "ground for recall" under the Recall Act, O.C.G.A. § 21-4-1 et seq., if the circumstances of that participation come within the definition of "grounds for recall." Steele v. Honea, 261 Ga. 644, 409 S.E.2d 652 (1991).

"Meeting" defined.

- "Meeting," within the definition of the Open Meetings Act, O.C.G.A. Ch. 14, T. 50, may be conducted by written, telephonic, electronic, wireless, or other virtual means. A designated place may be a postal, Internet, or telephonic address. A designated time may be the date upon which requested responses are due. Claxton Enter. v. Evans County Bd. of Comm'rs, 249 Ga. App. 870, 549 S.E.2d 830 (2001).

Openness of governmental meetings.

- The "sunshine law" does not require notice to the public of governmental meetings; rather, the law merely requires meetings to be open to the public. Dozier v. Norris, 241 Ga. 230, 244 S.E.2d 853 (1978) (decided under former Ga. L. 1972, p. 575).

Scope of O.C.G.A. § 50-14-1. - The former statute sought to eliminate closed meetings which engender in the people a distrust of public officials who are clothed with the power to act in the name of the people. McLarty v. Board of Regents of Univ. Sys., 231 Ga. 22, 200 S.E.2d 117 (1973) (decided under former Ga. L. 1972, p. 575).

The former statute dealt with the openness of public meetings, not with notice of such meetings. Harms v. Adams, 238 Ga. 186, 232 S.E.2d 61 (1977) (decided under former Ga. L. 1972, p. 575).

"Official action" defined.

- Official action is action which is taken by virtue of power granted by law, or by virtue of the office held, to act for and in behalf of the state. McLarty v. Board of Regents of Univ. Sys., 231 Ga. 22, 200 S.E.2d 117 (1973) (decided under former Ga. L. 1972, p. 575).

Immunity for action within scope of official duties.

- Actions taken by members of county airport authority which may have violated the Open Meetings Act, O.C.G.A. Ch. 14, T. 50, did not lose their character as actions taken within the scope of the members' official duties for purposes of immunity. Atlanta Airmotive, Inc. v. Royal, 214 Ga. App. 760, 449 S.E.2d 315 (1994).

Some meetings closed to public.

- County board of education may have unofficial meetings or meetings closed to the public to discuss and decide questions that fall within the enumerated exceptions. Deriso v. Cooper, 245 Ga. 786, 267 S.E.2d 217 (1980) (decided under former Ga. L. 1972, p. 575).

Actions at nonpublic meetings violative of O.C.G.A. § 50-14-1. - When there was conflicting evidence whether the substantive merits of a petition for a special land use permit to develop a solid waste landfill were discussed at nonpublic meetings of county board of zoning appeal, summary judgment for the board was precluded. Crosland v. Butts County Bd. of Zoning Appeals, 214 Ga. App. 295, 448 S.E.2d 454 (1994).

Prior improper meetings.

- Open Meetings Act, O.C.G.A. Ch. 14, T. 50, contains no provision authorizing a court to invalidate an ordinance on the ground that the subject matter of the ordinance was previously discussed at meetings that violate the Act. Board of Comm'rs v. Levetan, 270 Ga. 544, 512 S.E.2d 627 (1999).

Injunctive relief not available to invalidate past acts of city council.

- City councilmembers' claims against a mayor under the Open Meetings Act, O.C.G.A. § 50-14-1 et seq., for injunctive relief to invalidate certain acts of the council were subject to dismissal because injunctive relief was not available to remedy past actions, and there was an adequate remedy at law under O.C.G.A. § 50-14-1(b)(2). Lue v. Eady, 297 Ga. 321, 773 S.E.2d 679 (2015).

One-year limitation period only applied to suits to invalidate acts.

- Trial court erred in dismissing an action by taxpayers alleging violations of the Open Meetings Act, O.C.G.A. § 50-14-1, et seq., by a local airport authority in planning and submitting an FAA application because the limitation period in O.C.G.A. § 50-14-1(b)(2) pertained only to suits to invalidate public agency actions, and the taxpayers sought only declaratory relief, injunctive relief, attorney fees, and civil penalties. Avery v. Paulding County Airport Auth., 343 Ga. App. 832, 808 S.E.2d 15 (2017).

Cited in Georgia Real Estate Comm'n v. Horne, 141 Ga. App. 226, 233 S.E.2d 16 (1977); Worthy v. Paulding County Hosp. Auth., 243 Ga. 851, 257 S.E.2d 271 (1979); Irvin v. Macon Tel. Publishing Co., 253 Ga. 43, 316 S.E.2d 449 (1984); Atlanta Journal v. Babush, 257 Ga. 790, 364 S.E.2d 560 (1988); Walker v. City of Warner Robins, 262 Ga. 551, 422 S.E.2d 555 (1992); Guthrie v. Dalton City Sch. Dist., 213 Ga. App. 849, 446 S.E.2d 526 (1994); Moon v. Terrell County, 260 Ga. App. 433, 579 S.E.2d 845 (2003); City of Baldwin v. Woodard & Curran, Inc., 293 Ga. 19, 743 S.E.2d 381 (2013).

Citizen lacked standing to initiate criminal prosecution.

- Portion of a citizen's complaint seeking to impose criminal liability on city council members for their violation of the Open Meetings Act, O.C.G.A. § 50-14-1(e)(2), was properly dismissed because the citizen lacked standing to initiate criminal prosecution; at most, only the Act, O.C.G.A. § 50-14-6, is subject to a strict construction. Cardinale v. City of Atlanta, 290 Ga. 521, 722 S.E.2d 732 (2012).

Inadequate notice to landfill operator.

- Although the county board of commissioners met the technical requirements of O.C.G.A. § 50-14-1(d), posting notice of the meeting in which the waste ordinance was adopted on the door of the county office building was not adequate as a matter of law since the board knew that the ordinance would affect the landfill operator's business in operating the landfill and notice was not published in the legal organ of the county because the meeting occurred before publication was possible. Diamond Waste, Inc. v. Monroe County, 796 F. Supp. 1511 (M.D. Ga. 1992).

Student groups.

- Committee of the University of Georgia which was organized by the dean of student affairs primarily for the purpose of reviewing the student senate's recommended allocation of student activity funds does not come within the purview of this section. McLarty v. Board of Regents of Univ. Sys., 231 Ga. 22, 200 S.E.2d 117 (1973) (decided under former Ga. L. 1972, p. 575).

Inapplicable to legislature.

- This chapter is applicable to the departments, agencies, boards, bureaus, etc. of this state and its political subdivisions. It is not applicable to the General Assembly. Coggin v. Davey, 233 Ga. 407, 211 S.E.2d 708 (1975) (decided under former Ga. L. 1972, p. 575).

Inapplicable to public officer dismissals.

- Open Meetings Act, O.C.G.A. Ch. 14, T. 50, is not applicable when the dismissal of a public officer, such as a county attorney, is under consideration in accordance with O.C.G.A. § 50-14-3(6). Brennan v. Chatham County Comm'rs, 209 Ga. App. 177, 433 S.E.2d 597 (1993).

Inapplicable to advisory group.

- Atlanta City Council can not constitutionally delegate subpoena power, power to punish by contempt, and the power to require sworn testimony before a court reporter to a purely private, advisory group (the Administrative Review Panel), and the attempt by the city council to do so is void. Accordingly, since the purported delegation of official power to the panel is constitutionally infirm, the panel has no lawful official power, and is a purely advisory group, not subject to the provisions of O.C.G.A. Ch. 14, T. 50. Atlanta Journal v. Hill, 257 Ga. 398, 359 S.E.2d 913 (1987) (decided prior to 1988 repeal and reenactment).

Meeting scheduled to avoid holiday.

- Owners of property annexed by a city did not show, under O.C.G.A. § 50-14-1(d), that the annexation ordinance was adopted at an improperly rescheduled city meeting held prior to the date on which the meeting would normally be held; the meeting was not rescheduled, as it was noted on the official notice of city government meetings that the meeting would not be held on the meeting's normal day of every other Thursday because that would fall on Christmas, and that the meeting date would be scheduled later, which it was, and the meeting was held on the date scheduled. Bradley Plywood Corp. v. Mayor & Aldermen of Savannah, 271 Ga. App. 828, 611 S.E.2d 105 (2005).

Committee meeting within purview of Act.

- Olympic Task Force Selection Committee of the Atlanta Housing Authority (AHA), formed with the knowledge and approval of AHA and consisting of several AHA decisionmakers, was a vehicle for the agency to carry out the agency's responsibilities and, thus, a meeting of the committee was within the purview of the Open Meetings Act, O.C.G.A. Ch. 14, T. 50. Jersawitz v. Fortson, 213 Ga. App. 796, 446 S.E.2d 206 (1994).

Coroner's inquest constitutes a "meeting" within the meaning of O.C.G.A. § 50-14-1(a)(2). Kilgore v. R.W. Page Corp., 261 Ga. 410, 405 S.E.2d 655 (1991).

Conference of county commissioners and county attorney to discuss zoning ruling was not a meeting.

- Conference among county commissioners, the county zoning administrator, the county attorney, and a zoning applicant, held immediately following a superior court ruling invalidating a zoning decision, was not a "meeting" under O.C.G.A. § 50-14-1(a)(2) because it was not held pursuant to schedule, call, or notice at a designated time and place. Even if any business or policy was discussed at the conference, no official action was taken that could be voided under § 50-14-1(b). Gumz v. Irvin, 300 Ga. App. 426, 685 S.E.2d 392 (2009).

Private, nonprofit hospital corporations that served as vehicles through which public hospital authorities carried out their official responsibilities were subject to the Open Meetings Act, O.C.G.A. Ch. 14, T. 50, and the Open Records Act, O.C.G.A. Ch. 14, T. 50. Northwest Ga. Health Sys. v. Times-Journal, Inc., 218 Ga. App. 336, 461 S.E.2d 297 (1995).

Student organization court hearings open.

- Trial court erred in concluding that the hearings of the student-run organization court were not subject to the Open Meetings Act, O.C.G.A. Ch. 14, T. 50, given that the court was the official vehicle by which the university carried out the university's responsibility, as directed by the Board of Regents, to regulate social organizations. Red & Black Publishing Co. v. Board of Regents, 262 Ga. 848, 427 S.E.2d 257 (1993).

Records of private university's police force.

- Records of a campus police force of a private university were not subject to disclosure under the Open Records Act, O.C.G.A. § 50-18-70 et seq., as the university was a private institution that did not receive any funding from the state, the campus police were employees of that entity pursuant to the authority of O.C.G.A. § 20-8-2, and the fact that the police performed a public function did not make their records into public records; the fact that the campus police were given authority to perform certain functions by the Campus Policemen Act, O.C.G.A. § 20-8-1 et seq., and the Georgia Peace Officer Standards and Training Act, O.C.G.A. § 35-8-1 et seq., did not make them officers or employees of a public office or agency for purposes of the Open Records Act. The Corp. of Mercer Univ. v. Barrett & Farahany, L.L.P., 271 Ga. App. 501, 610 S.E.2d 138 (2005).

When inquest was closed to public.

- Relief sought in a newspaper publisher's suit against a coroner to prohibit the coroner from closing to the public a scheduled inquest was governed by the Open Meetings Law, O.C.G.A. Ch. 14, T. 50, and the Open Records Law, O.C.G.A. § 50-18-70. Kilgore v. R.W. Page Corp., 259 Ga. 556, 385 S.E.2d 406 (1989).

Provision of videotape of meeting is not compliance.

- Atlanta Housing Authority did not substantially comply with the statute by providing a citizen with a videotape of a meeting of the Olympic Task Force Selection Committee after the agency accepted the recommendation of the committee. Jersawitz v. Fortson, 213 Ga. App. 796, 446 S.E.2d 206 (1994).

Open meetings cannot be closed by one citizen.

- Because the public has the right to access to a meeting declared open to the public, one citizen cannot elect to close a meeting that should be open. Moon v. Terrell County, 249 Ga. App. 567, 548 S.E.2d 680 (2001).

Error to hold closed executive session.

- Grand jury presentments questioning the propriety of certain policies of county commissioners did not amount to pending or potential litigation so the attorney-client privilege did not apply to a meeting conducted to fashion a response to the presentments, and the commissioners violated O.C.G.A. § 50-14-1(b) by conducting an executive session concerning the presentments. Decatur County v. Bainbridge Post Searchlight, Inc., 280 Ga. 706, 632 S.E.2d 113 (2006).

Injunctive relief not available to compel compliance in the future.

- Trial court erred in issuing temporary and permanent injunctions ordering a county board of commissioners to comply with the Open Records Act, O.C.G.A. § 50-14-1 et seq., in the future as the board already had a duty to obey the law, and the complaint for injunctive relief, which was filed by the director of a county agency, averred no more than apprehensions of future injury, for which injunctive relief was not available. Wiggins v. Bd. of Comm'rs, 258 Ga. App. 666, 574 S.E.2d 874 (2002).

Violation of agenda-posting requirement not found.

- Because no allegation, much less evidence, was presented by a county property buyer that a technical violation of the agenda-posting requirement under O.C.G.A. § 50-14-1(e)(1) deprived the buyer of a fair and open consideration of its claim or in any way impeded the remedial and protective purposes of the Open Meetings Act, the posting of the agenda at the regular meeting place of the county board of commissioners, rather than at the actual meeting site, sufficiently complied with the statute's requirements. EarthResources, LLC v. Morgan County, 281 Ga. 396, 638 S.E.2d 325 (2006).

County could not recover judge's salary paid in violation of act based on 90-day limitations.

- In a dispute between a county and a county state court judge over a supplement to the judge's salary, summary judgment for the judge was proper on the county's claim for reimbursement of the judge's salary supplement because the county failed to show that the supplement was paid with the total absence or want of power. Even if the supplement was paid in violation of the Open Meetings Act, O.C.G.A. § 50-14-1 et seq., the county's counterclaim was filed well outside the 90-day limitation period in O.C.G.A. § 50-14-1(b)(2). Heiskell v. Roberts, 342 Ga. App. 109, 802 S.E.2d 385 (2017).

Claims for lack of notice untimely.

- Because a citizens group's claims for lack of notice under the Georgia Open and Public Meetings Law, O.C.G.A. § 50-14-1(d), were untimely, and because the group failed to show that the actions by a county and a company in operating a landfill violated O.C.G.A. §§ 12-8-32 and48-8-121(a)(1), the company was entitled to summary judgment in the group's action for damages and declaratory and injunctive relief. Anti-Landfill Corp. v. North Am. Metal Co., LLC, 299 Ga. App. 509, 683 S.E.2d 88 (2009).

Chairperson of county school board in contempt for interfering with agenda items.

- Evidence supported a trial court's conclusion that the chairperson of a county board of education deliberately prevented board members from appealing the chairperson's decisions at a board meeting and would not recognize any appeals of the chairperson's decisions to the other members of the board, and the trial court properly held the chairperson in contempt of the court's order requiring that all board members be entitled to place matters on the agenda consistent with O.C.G.A. § 50-14-1. Cook v. Smith, 288 Ga. 409, 705 S.E.2d 847 (2010).

Public vote required for appointment of interim city manager.

- In a firefighter's suit against a city and officials alleging violation of the Open Meetings Act, O.C.G.A. § 50-14-1, et seq., summary judgment under O.C.G.A. § 50-14-1(b) was proper as to three officials appointed more than 90 days before the firefighter's suit was filed; as to a fourth official, as to whom suit was timely, because the city failed to hold any public vote on the official's interim position, summary judgment was improper. Martin v. City of College Park, 342 Ga. App. 289, 802 S.E.2d 292 (2017).

Names of persons voting omitted from minutes of meeting.

- Court of appeals erred in affirming the dismissal of a citizen's action alleging that a city and city counsel members violated the Open Meetings Act, O.C.G.A. § 50-14-1(e)(2), because the complaint stated claims for declaratory and injunctive relief under the Act, O.C.G.A. § 50-14-5(a), based upon alleged violations of O.C.G.A. § 50-14-1(e)(2) since the minutes of a counsel meeting omitted the names of council members who voted in the minority to amend certain council rules; the court of appeals erred in interpreting O.C.G.A. § 50-14-1(e)(2) to allow minutes of an agency meeting to omit the names of persons voting against a proposal or abstaining when the vote was not taken by roll-call and was not unanimous. Cardinale v. City of Atlanta, 290 Ga. 521, 722 S.E.2d 732 (2012).

Letter from single county commissioner was not a decision.

- Letter from a county to a developer advising that proposals would be considered under an amended ordinance limiting the development of private sewer systems was not a "decision" of the county for purposes of triggering the 30-day period to appeal under O.C.G.A. § 5-3-20; therefore, the developer's claim of inverse condemnation never ripened. Mortgage Alliance Corp. v. Pickens County, 294 Ga. 212, 751 S.E.2d 51 (2013).

Action challenging cell tower construction timely.

- Suit challenging the denial of an application to construct a cellular tower was timely because under Georgia's Open Meetings Act, O.C.G.A. § 50-14-1, et seq., the 30-day clock for filing suit under the Telecommunications Act of 1996. 47 U.S.C. § 332, commenced upon the county board's approval of the minutes of its prior meeting denying the tower application, rather than when the county clerk, according to custom, entered a document in the county's books. Athens Cellular, Inc. v. Oconee Cty., 886 F.3d 1094 (11th Cir. 2018).

Action time barred.

- Trial court properly denied a challenger's claim for injunctive relief against a city because the challenger failed to file the suit within 90 days of the city council meeting ratifying the purchase of the real property challenged, therefore, the action was untimely under the Open and Public Meetings Act, O.C.G.A. § 50-14-1(b)(2). Tisdale v. City of Cumming, 326 Ga. App. 19, 755 S.E.2d 833 (2014).

Editor's notes.

- In light of the similarity of the statutory provisions, opinions under former Ga. L. 1972, p. 575, which was subsequently repealed but was succeeded by provisions in this Code section, are included in the annotations for this Code section.

Applicability of O.C.G.A. § 50-14-1. - This section, the "sunshine law," does not cover meetings at which no official action may be taken. 1978 Op. Att'y Gen. No. U78-2 (decided under former Ga. L. 1972, p. 575).

County board of tax assessors and county board of equalization are subject to the Georgia Open Meetings Law, O.C.G.A. Ch. 14, T. 50. 1995 Op. Att'y Gen. No. U95-22.

Ad hoc "public record" evaluation.

- Question of whether specific investigation or inspection report is "public record" must be answered on a case-by-case basis. 1980 Op. Att'y Gen. No. 80-105 (decided under former Ga. L. 1972, p. 575).

Inspection of board-initiated investigation files.

- Unless files reflecting board-initiated investigation meet definition of former subsection (b) of this section, citizen does not have a right to inspect such a file as a public record under former Ga. L. 1959, p. 88, § 1 (see O.C.G.A. § 50-18-70). 1980 Op. Att'y Gen. No. 80-84 (decided under former Ga. L. 1972, p. 575).

Written memorials of final action disclosable.

- Investigative materials that are not prepared and kept as written memorials of final board action should not be disclosed to the public. However, those portions of board meeting minutes which deal with final action taken as to a particular applicant may be disclosed. 1980 Op. Att'y Gen. No. 80-84 (decided under former Ga. L. 1972, p. 575).

Insurer's individual loss ratio experience.

- Unless statistical information as to insurer's individual loss ratio experience submitted to Insurance Commissioner constitutes "written memorials of a final action" taken by the Insurance Department, a citizen does not have the right to inspect the information submitted as a public record and the Insurance Commissioner is not required to release the information. 1981 Op. Att'y Gen. No. 81-66.

Meetings of Organized Crime Prevention Council.

- Since the Organized Crime Prevention Council is a law enforcement agency, its proceedings and meetings are not required to be open to the public under the Georgia Open Meetings Statute. 1986 Op. Att'y Gen. No. U86-35 (decided under former Ga. L. 1972, p. 575).

Application to the Drug Utilization Review Board.

- Open Meetings Act, O.C.G.A. § 50-14-1, applies to the Drug Utilization Review Board created by the Georgia Department of Community Health. 2010 Op. Att'y Gen. No. U10-1.

School board meetings regarding personnel matters.

- School board may not close any meeting devoted to the airing of grievances about school personnel by interested members of the public; further, should the board conduct an inquiry into the actions of school personnel, any evidence or argument presented to the board must be held in an open meeting, but the board may close that portion of the meeting consisting of deliberation or discussion of disciplinary action upon proper compliance with the statutory closure provisions. 1995 Op. Att'y Gen. No. U95-15.

Student disciplinary hearings before local boards of education, including any deliberations of the board at which final action is taken or discussed, are required to be open to the public. 1983 Op. Att'y Gen. No. 83-9.

Meetings by telephone conference call.

- Meetings of the Stone Mountain Memorial Association may be conducted by speaker telephone conference when public access is provided. 1985 Op. Att'y Gen. No. 85-26, modifying 1970 Op. Att'y Gen. No. 70-122.

Utilization of a telephonic conference is permissible for a regular meeting of the State Properties Commission; such a meeting may be conducted to meet the requirements of the Open and Public Meetings Act, O.C.G.A. Ch. 14, T. 50, and members participating by telephonic means in such a meeting may be counted to reach a quorum. 1994 Op. Att'y Gen. No. 94-11.

State Ethics Commission is an "agency" as contemplated by O.C.G.A. Ch. 14, T. 50. 1989 Op. Att'y Gen. No. 89-6.

State Ethics Commission activities conducted in accordance with O.C.G.A. § 21-5-6(b)(10)(A), including convening a quorum to hear testimony, taking evidence, considering argument of the parties, deliberating, and imposing penalties, constitute a "meeting" within the meaning of Open Meetings Law, O.C.G.A. Ch. 14, T. 50. Accordingly, the commission must conduct all of these activities regarding the resolution of a contested case in accordance with the dictates of the Open Meetings Law. 1989 Op. Att'y Gen. No. 89-6.

Private Industry Councils are "agencies" for purposes of the Open Meetings Law, O.C.G.A. Ch. 14, T. 50, and records generally maintained by such PIC's are subject to the Open Records Law, O.C.G.A. § 50-18-70. 1989 Op. Att'y Gen. No. 89-5.

Access to deeds, liens, and plats. Georgia Superior Court Clerks' Cooperative Authority is required to produce images and index data in response to Open Records Act, O.C.G.A. § 50-18-70 et seq., requests for information contained on the online information system for deeds, liens, and plats, but may do so in accordance with a fee schedule adopted pursuant to O.C.G.A. § 15-6-94. 2012 Op. Att'y Gen. No. 12-5.

ALR.

- Emergency exception under state law making proceedings by public bodies open to the public, 33 A.L.R.5th 731.

Attorney-client exception under state law making proceedings by public bodies open to the public, 34 A.L.R.5th 591.