Ky. Rev. Stat. » Chapter 61
Kentucky Revised Statutes

Ky. Rev. Stat. § 61.810 (2026)

Exceptions to open meetings

✓ current as of May 2026
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(1) All meetings of a quorum of the members of any public agency at which any public business is discussed or at which any action is taken by the agency, shall be public meetings, open to the public at all times, except for the following: (a) Deliberations for decisions of the Kentucky Parole Board; (b) Deliberations on the future acquisition or sale of real property by a public agency, but only when publicity would be likely to affect the value of a specific piece of property to be acquired for public use or sold by a public agency; (c) Discussions of proposed or pending litigation against or on behalf of the public agency; (d) Grand and petit jury sessions; (e) Collective bargaining negotiations between public employers and their employees or their representatives; (f) Discussions or hearings which might lead to the appointment, discipline, or dismissal of an individual employee, member, or student without restricting that employee's, member's, or student's right to a public hearing if requested. This exception shall not be interpreted to permit discussion of general personnel matters in secret; (g) Discussions between a public agency and a representative of a business entity and discussions concerning a specific proposal, if open discussions would jeopardize the siting, retention, expansion, or upgrading of the business; (h) State and local cabinet meetings and executive cabinet meetings; (i) Committees of the General Assembly other than standing committees; (j) Deliberations of judicial or quasi-judicial bodies regarding individual adjudications or appointments, at which neither the person involved, his representatives, nor any other individual not a member of the agency's governing body or staff is present, but not including any meetings of planning commissions, zoning commissions, or boards of adjustment; (k) Meetings which federal or state law specifically require to be conducted in privacy; (l) Meetings which the Constitution provides shall be held in secret; (m) That portion of a meeting devoted to a discussion of a specific public record exempted from disclosure under KRS 61.878(1)(m). However, that portion of any public agency meeting shall not be closed to a member of the Kentucky General Assembly; and (n) Meetings of any selection committee, evaluation committee, or other similar group established under KRS Chapter 45A or 56 or other state or local law, to select a successful bidder for award of a state or local contract. (2) Any series of less than quorum meetings, where the members attending one (1) or more of the meetings collectively constitute at least a quorum of the members of the public agency and where the meetings are held for the purpose of avoiding the requirements of subsection (1) of this section, shall be subject to the requirements of subsection (1) of this section. Nothing in this subsection shall be construed to prohibit discussions between individual members where the purpose of the discussions is to educate the members on specific issues. Effective: July 14, 2022 History: Amended 2022 Ky. Acts ch. 37, sec. 1, effective July 14, 2022. -- Amended 2018 Ky. Acts ch. 176, sec. 4, effective July 14, 2018. -- Amended 2005 Ky. Acts ch. 93, sec. 1, effective March 16, 2005. -- Amended 1992 Ky. Acts ch. 162, sec. 3, effective July 14, 1992. -- Created 1974 Ky. Acts ch. 377, sec. 2. Legislative Research Commission Note (3/16/2005). The Office of the Kentucky Attorney General requested that amendments in 2005 Ky. Acts ch. 93, sec. 1, to the arrangement of the paragraphs of subsection (1) of this section be changed. The change was requested "in the interest of preventing confusion to the public and public agencies" and was made by the Statute Reviser under the authority of KRS 7.136.

Notes of Decisions
Cited in 32 cases (4 in the last 5 years), 1977–2025 · leading case: Floyd Cnty. Bd. of Educ. v. Ratliff, 955 S.W.2d 921 (Ky. 1997).
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Floyd Cnty. Bd. of Educ. v. Ratliff, 955 S.W.2d 921 (Ky. 1997). · cites it 22× “850 is that the formation of public policy is public business and shall not be conducted in secret and the exceptions provided for KRS 61.810 or otherwise provided for by law shall be strictly construed.”
Carter v. Smith, 366 S.W.3d 414 (Ky. 2012). · cites it 13× “The few exceptions to this open meetings requirement are located in KRS 61.810. These exceptions must be strictly construed “so as to avoid improper or unauthorized closed, executive or secret meetings.”
Yeoman v. Com., Health Policy Bd., 983 S.W.2d 459 (Ky. 1998). · cites it 8× “KRS § 61.810(2). Accordingly, since neither instance presented by appellants constitutes a meeting in violation of the Act, we find this claim to be devoid of merit.”
Palmer v. Driggers, 60 S.W.3d 591 (Ky. Ct. App. 2001). · cites it 6× “Now KRS 61.810(1)©. 15 . However, in that case, as to a portion of the evidence which included a statement by a police officer, the Attorney General went on to state, "[w]e do not believe that a police officer has any right to privacy as to any of his actions while on duty.”
Webster Cnty. Bd. of Educ. v. Franklin, 392 S.W.3d 431 (Ky. Ct. App. 2013). · cites it 7× “According to the Webster County Clerk, as a public agency, the Board violated KRS 61.810, KRS 61.805(3), and the Open Meetings Act.”
Jefferson Cnty. Bd. of Educ. v. Courier-Journal, 551 S.W.2d 25 (Ky. Ct. App. 1977). · cites it 7× “815 before a closed session can be held on select topics and the coverage of certain of the enumerated exceptions to open meetings in KRS 61.810. The appellants have also raised as an issue the propriety of the relief granted.”
Courier-Journal & Louisville Times Co. v. Univ. of Louisville Bd. of Trs., 596 S.W.2d 374 (Ky. Ct. App. 1979). · cites it 6× “When we examine KRS 61.810 we find that this statute states as follows: All meetings of a quorum of the members of any public agency at which any public business is discussed .”
Bd. of Commissioners of the City of Danville, Kentucky v. Advocate Commc'ns, Inc. D/B/A the Advocate-Messenger, 527 S.W.3d 803 (Ky. 2017). · cites it 3× “While exceptions to the open meeting requirement are set forth in KRS 61.810, KRS 61.800 provides that the exceptions are to be “strictly construed.”
Reed v. City of Richmond, 582 S.W.2d 651 (Ky. Ct. App. 1979). · cites it 4× “KRS 61.810 requires that all meetings of public agencies at which any business is discussed or any action taken shall be open to the public, subject to certain enumerated exceptions.”
Univ. of Ky. v. Lexington H-L Servs., Inc., 579 S.W.3d 858 (Ky. Ct. App. 2018). “ssion at the dinner meeting with the outside counsel was not privileged; (3) the University was required to create minutes that "reflect the substance" of that discussion; (4) even if the Board of Trustee's discussion with counsel was privileged, the privilege is not an…”
Carter v. Smith, 170 S.W.3d 402 (Ky. Ct. App. 2004). “In her amended complaint, Smith included a third count, alleging that the Board went into a closed session at a December 19, 2002, meeting for a stated purpose of discussing pending *405 litigation and personnel without giving notice of the specific provision of KRS 61.810…”
Howard v. City of Indep., 199 S.W.3d 741 (Ky. Ct. App. 2005). · cites it 3× “Howard argues that the judgment should be reversed because he was denied a public hearing in violation of KRS 61.810, the Open Meetings Act. We disagree.”
Show all 32 citing cases →
— Ky. Rev. Stat. § 61.810(1) — 9 cases
Floyd Cnty. Bd. of Educ. v. Ratliff, 955 S.W.2d 921 (Ky. 1997). “850 is that the formation of public policy is public business and shall not be conducted in secret and the exceptions provided for KRS 61.810 or otherwise provided for by law shall be strictly construed.”
Carter v. Smith, 366 S.W.3d 414 (Ky. 2012). “The few exceptions to this open meetings requirement are located in KRS 61.810. These exceptions must be strictly construed “so as to avoid improper or unauthorized closed, executive or secret meetings.”
Palmer v. Driggers, 60 S.W.3d 591 (Ky. Ct. App. 2001). “Now KRS 61.810(1)©. 15 . However, in that case, as to a portion of the evidence which included a statement by a police officer, the Attorney General went on to state, "[w]e do not believe that a police officer has any right to privacy as to any of his actions while on duty.”
Webster Cnty. Bd. of Educ. v. Franklin, 392 S.W.3d 431 (Ky. Ct. App. 2013). “According to the Webster County Clerk, as a public agency, the Board violated KRS 61.810, KRS 61.805(3), and the Open Meetings Act.”
Bd. of Commissioners of the City of Danville, Kentucky v. Advocate Commc'ns, Inc. D/B/A the Advocate-Messenger, 527 S.W.3d 803 (Ky. 2017). “While exceptions to the open meeting requirement are set forth in KRS 61.810, KRS 61.800 provides that the exceptions are to be “strictly construed.”
— Ky. Rev. Stat. § 61.810(1)(b) — 2 cases
Bd. of Commissioners of the City of Danville, Kentucky v. Advocate Commc'ns, Inc. D/B/A the Advocate-Messenger, 527 S.W.3d 803 (Ky. 2017). “While exceptions to the open meeting requirement are set forth in KRS 61.810, KRS 61.800 provides that the exceptions are to be “strictly construed.”
Deters v. Kenton Cnty. Pub. Library, 168 S.W.3d 62 (Ky. Ct. App. 2005).
— Ky. Rev. Stat. § 61.810(1)(c) — 4 cases
Floyd Cnty. Bd. of Educ. v. Ratliff, 955 S.W.2d 921 (Ky. 1997). “850 is that the formation of public policy is public business and shall not be conducted in secret and the exceptions provided for KRS 61.810 or otherwise provided for by law shall be strictly construed.”
Univ. of Ky. v. Lexington H-L Servs., Inc., 579 S.W.3d 858 (Ky. Ct. App. 2018). “ssion at the dinner meeting with the outside counsel was not privileged; (3) the University was required to create minutes that "reflect the substance" of that discussion; (4) even if the Board of Trustee's discussion with counsel was privileged, the privilege is not an…”
Webster Cnty. Bd. of Educ. v. Franklin, 392 S.W.3d 431 (Ky. Ct. App. 2013). “According to the Webster County Clerk, as a public agency, the Board violated KRS 61.810, KRS 61.805(3), and the Open Meetings Act.”
Lexington-Fayette Urban Cnty. Gov't v. Lexington Herald-Leader Co., 941 S.W.2d 469 (Ky. 1997).
— Ky. Rev. Stat. § 61.810(1)(f) — 3 cases
Floyd Cnty. Bd. of Educ. v. Ratliff, 955 S.W.2d 921 (Ky. 1997). “850 is that the formation of public policy is public business and shall not be conducted in secret and the exceptions provided for KRS 61.810 or otherwise provided for by law shall be strictly construed.”
Terri Bradshaw v. Capital Cmty. Econ./Indus. Dev. Auth. (Ky. Ct. App. 2025).
Oliver v. Lexington Fayette Urban Cnty. Gov't (E.D. Ky. 2020).
— Ky. Rev. Stat. § 61.810(10) — 1 case
Miller v. Bd. of Educ. of Hardin Cnty., 610 S.W.2d 935 (Ky. Ct. App. 1980).
— Ky. Rev. Stat. § 61.810(2) — 1 case
Yeoman v. Com., Health Policy Bd., 983 S.W.2d 459 (Ky. 1998). “KRS § 61.810(2). Accordingly, since neither instance presented by appellants constitutes a meeting in violation of the Act, we find this claim to be devoid of merit.”
— Ky. Rev. Stat. § 61.810(2)(c) — 1 case
Floyd Cnty. Bd. of Educ. v. Ratliff, 955 S.W.2d 921 (Ky. 1997). “850 is that the formation of public policy is public business and shall not be conducted in secret and the exceptions provided for KRS 61.810 or otherwise provided for by law shall be strictly construed.”
— Ky. Rev. Stat. § 61.810(5) — 1 case
Jefferson Cnty. Bd. of Educ. v. Courier-Journal, 551 S.W.2d 25 (Ky. Ct. App. 1977). “815 before a closed session can be held on select topics and the coverage of certain of the enumerated exceptions to open meetings in KRS 61.810. The appellants have also raised as an issue the propriety of the relief granted.”
— Ky. Rev. Stat. § 61.810(6) — 8 cases
Palmer v. Driggers, 60 S.W.3d 591 (Ky. Ct. App. 2001). “Now KRS 61.810(1)©. 15 . However, in that case, as to a portion of the evidence which included a statement by a police officer, the Attorney General went on to state, "[w]e do not believe that a police officer has any right to privacy as to any of his actions while on duty.”
Courier-Journal & Louisville Times Co. v. Univ. of Louisville Bd. of Trs., 596 S.W.2d 374 (Ky. Ct. App. 1979). “When we examine KRS 61.810 we find that this statute states as follows: All meetings of a quorum of the members of any public agency at which any public business is discussed .”
Stinson v. State Bd. of Acct., 625 S.W.2d 589 (Ky. Ct. App. 1981).
Carter v. Craig, 574 S.W.2d 352 (Ky. Ct. App. 1978).
Jefferson Cnty. Bd. of Educ. v. Courier-Journal, 551 S.W.2d 25 (Ky. Ct. App. 1977). “815 before a closed session can be held on select topics and the coverage of certain of the enumerated exceptions to open meetings in KRS 61.810. The appellants have also raised as an issue the propriety of the relief granted.”
— Ky. Rev. Stat. § 61.810(a) — 1 case
Yeoman v. Com., Health Policy Bd., 983 S.W.2d 459 (Ky. 1998). “KRS § 61.810(2). Accordingly, since neither instance presented by appellants constitutes a meeting in violation of the Act, we find this claim to be devoid of merit.”
— Ky. Rev. Stat. § 61.810(c) — 1 case
Floyd Cnty. Bd. of Educ. v. Ratliff, 955 S.W.2d 921 (Ky. 1997). “850 is that the formation of public policy is public business and shall not be conducted in secret and the exceptions provided for KRS 61.810 or otherwise provided for by law shall be strictly construed.”
— Ky. Rev. Stat. § 61.810(l) — 1 case
Grace v. LVNV Funding, Inc., 22 F. Supp. 3d 700 (W.D. Ky. 2014).
— Ky. Rev. Stat. § 61.810(l)(c) — 3 cases
Carter v. Smith, 366 S.W.3d 414 (Ky. 2012). “The few exceptions to this open meetings requirement are located in KRS 61.810. These exceptions must be strictly construed “so as to avoid improper or unauthorized closed, executive or secret meetings.”
Webster Cnty. Bd. of Educ. v. Franklin, 392 S.W.3d 431 (Ky. Ct. App. 2013). “According to the Webster County Clerk, as a public agency, the Board violated KRS 61.810, KRS 61.805(3), and the Open Meetings Act.”
Cunningham v. Whalen, 373 S.W.3d 438 (Ky. 2012).
— Ky. Rev. Stat. § 61.810(l)(e) — 2 cases
Carter v. Smith, 366 S.W.3d 414 (Ky. 2012). “The few exceptions to this open meetings requirement are located in KRS 61.810. These exceptions must be strictly construed “so as to avoid improper or unauthorized closed, executive or secret meetings.”
Lexington-Fayette Urban Cnty. Gov't v. Lexhl, LP, 315 S.W.3d 331 (Ky. Ct. App. 2009).
— Ky. Rev. Stat. § 61.810(l)(f) — 3 cases
Carter v. Smith, 366 S.W.3d 414 (Ky. 2012). “The few exceptions to this open meetings requirement are located in KRS 61.810. These exceptions must be strictly construed “so as to avoid improper or unauthorized closed, executive or secret meetings.”
Palmer v. Driggers, 60 S.W.3d 591 (Ky. Ct. App. 2001). “Now KRS 61.810(1)©. 15 . However, in that case, as to a portion of the evidence which included a statement by a police officer, the Attorney General went on to state, "[w]e do not believe that a police officer has any right to privacy as to any of his actions while on duty.”
Floyd Cnty. Bd. of Educ. v. Ratliff, 955 S.W.2d 921 (Ky. 1997). “850 is that the formation of public policy is public business and shall not be conducted in secret and the exceptions provided for KRS 61.810 or otherwise provided for by law shall be strictly construed.”
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