Michigan Compiled Laws

Mich. Comp. Laws § 15.267 (2026)

Closed sessions; roll call vote; separate set of minutes.

✓ current as of July 2026

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OPEN MEETINGS ACT

Act 267 of 1976

15.267 Closed sessions; roll call vote; separate set of minutes.

Sec. 7.

(1) A 2/3 roll call vote of members elected or appointed and serving is required to call a closed session, except for the closed sessions permitted under section 8(a), (b), (c), (g), (i), and (j). The roll call vote and the purpose or purposes for calling the closed session shall be entered into the minutes of the meeting at which the vote is taken.

(2) A separate set of minutes shall be taken by the clerk or the designated secretary of the public body at the closed session. These minutes shall be retained by the clerk of the public body, are not available to the public, and shall only be disclosed if required by a civil action filed under section 10, 11, or 13. These minutes may be destroyed 1 year and 1 day after approval of the minutes of the regular meeting at which the closed session was approved.

History: 1976, Act 267, Eff. Mar. 31, 1977 ;-- Am. 1993, Act 81, Eff. Apr. 1, 1994 ;-- Am. 1996, Act 464, Imd. Eff. Dec. 26, 1996

Notes of Decisions

Cited in 34 cases (9 in the last 5 years), 1988–2025 · leading case: Harlan Vermilya v. Delta Coll. Bd. of Trs., 925 N.W.2d 897 (Mich. Ct. App. 2018).

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Harlan Vermilya v. Delta Coll. Bd. of Trs., 925 N.W.2d 897 (Mich. Ct. App. 2018). · cites it 8× “116(I)(2) (nonmoving party entitled to judgment), ruling that defendant's failure to identify the "specific pending litigation" it would be discussing in closed session violated MCL 15.267(1) and MCL 15.269(1). Defendant appeals by right.”

Local Area Watch v. City of Grand Rapids, 683 N.W.2d 745 (Mich. Ct. App. 2004). · cites it 5× “In the response, it was revealed that the requested executive session minutes from the dates of November 21, 2000, through April 17, 2001, were probably destroyed pursuant to § 7(2) of the OMA, MCL 15.267(2), which provides that minutes from closed sessions “may be destroyed 1…”

Kitchen v. Ferndale City Council, 654 N.W.2d 918 (Mich. Ct. App. 2002). · cites it 3× “With respect to minutes of closed session meetings, however, MCL 15.267 expressly provides that any minutes generated be retained by the clerk for at least one year and one day after approval of the minutes of the meeting at which the closed session was approved, after which the…”

Herald Co., Inc. v. Tax Tribunal, 669 N.W.2d 862 (Mich. Ct. App. 2003). · cites it 2× “[MCL 15.267.] Section 9 of the oma provides: (1) Each public body shall keep minutes [the record] of each meeting showing .”

Manning v. City of East Tawas, 593 N.W.2d 649 (Mich. Ct. App. 1999). · cites it 2× “PROCEDURAL SUFFICIENCY OF THE DECISION TO GO INTO CLOSED SESSION Subsection 7(1) of the OMA, MCL 15.267(1); MSA 4.1800(17)(1), prescribing roll call votes for closed sessions, states, “The roll call vote and the purpose or purposes for calling the closed session shall be entered…”

Booth Newspapers, Inc v. Wyoming City Council, 425 N.W.2d 695 (Mich. Ct. App. 1988). · cites it 2× “The public’s ability to monitor what occurred in closed session is amply protected by oma’s requirement that a roll call vote be taken in public session and the purpose for calling the closed session be entered in the minutes of the meeting at which the vote is taken, MCL 15.”

Omdahl v. West Iron Cnty. Bd. of Educ., 722 N.W.2d 691 (Mich. Ct. App. 2006). · cites it 4× “The trial court concluded that defendants violated MCL 15.267(2), and plaintiff was obviously a "person" under MCL 15.”

Nicholas v. Meridian Charter Twp. Bd., 609 N.W.2d 574 (Mich. Ct. App. 2000). “[1] 1 The oma provides for certain exceptions to the requirement that the deliberations of a public body be conducted at a public meeting, none of which are applicable in this case.”

Willis v. Deerfield Twp., 669 N.W.2d 279 (Mich. Ct. App. 2003). “[MCL 15.267(1).] *550 MCL 15.268 provides that a public body may meet in a closed session for specific delineated purposes.”

Local Area Watch v. City of Grand Rapids, 683 N.W.2d 745 (Mich. Ct. App. 2004). · cites it 5× “§ 15.267(2), which provides that minutes from closed sessions "may be destroyed 1 year and 1 day after approval of the minutes of the regular meeting at which the closed session was approved.”

Titus v. Shelby Charter Twp., 574 N.W.2d 391 (Mich. Ct. App. 1998). “The township denied the request, contending that the records were exempt from disclosure under § 7(2) of the Open Meetings Act (oma), MCL 15.267(2); MSA 4.1800 (17)(2), and § 13(l)(d) of the Freedom of Information Act (FOIA), MCL 15.”

Harlan Vermilya v. Delta Coll. Bd. of Trs. (Mich. Ct. App. 2018). · cites it 8× “116(I)(2) (nonmoving party entitled to judgment), ruling that defendant’s failure to identify the “specific pending litigation” it would be discussing in closed session violated MCL 15.267(1) and MCL 15.269(1). Defendant appeals by right.”

Show all 34 citing cases →

— Mich. Comp. Laws § 15.267(1) — 18 cases

Harlan Vermilya v. Delta Coll. Bd. of Trs., 925 N.W.2d 897 (Mich. Ct. App. 2018). “116(I)(2) (nonmoving party entitled to judgment), ruling that defendant's failure to identify the "specific pending litigation" it would be discussing in closed session violated MCL 15.267(1) and MCL 15.269(1). Defendant appeals by right.”

Herald Co., Inc. v. Tax Tribunal, 669 N.W.2d 862 (Mich. Ct. App. 2003). “[MCL 15.267.] Section 9 of the oma provides: (1) Each public body shall keep minutes [the record] of each meeting showing .”

Manning v. City of East Tawas, 593 N.W.2d 649 (Mich. Ct. App. 1999). “PROCEDURAL SUFFICIENCY OF THE DECISION TO GO INTO CLOSED SESSION Subsection 7(1) of the OMA, MCL 15.267(1); MSA 4.1800(17)(1), prescribing roll call votes for closed sessions, states, “The roll call vote and the purpose or purposes for calling the closed session shall be entered…”

Booth Newspapers, Inc v. Wyoming City Council, 425 N.W.2d 695 (Mich. Ct. App. 1988). “The public’s ability to monitor what occurred in closed session is amply protected by oma’s requirement that a roll call vote be taken in public session and the purpose for calling the closed session be entered in the minutes of the meeting at which the vote is taken, MCL 15.”

Willis v. Deerfield Twp., 669 N.W.2d 279 (Mich. Ct. App. 2003). “[MCL 15.267(1).] *550 MCL 15.268 provides that a public body may meet in a closed session for specific delineated purposes.”

— Mich. Comp. Laws § 15.267(2) — 15 cases

Local Area Watch v. City of Grand Rapids, 683 N.W.2d 745 (Mich. Ct. App. 2004). “In the response, it was revealed that the requested executive session minutes from the dates of November 21, 2000, through April 17, 2001, were probably destroyed pursuant to § 7(2) of the OMA, MCL 15.267(2), which provides that minutes from closed sessions “may be destroyed 1…”

Kitchen v. Ferndale City Council, 654 N.W.2d 918 (Mich. Ct. App. 2002). “With respect to minutes of closed session meetings, however, MCL 15.267 expressly provides that any minutes generated be retained by the clerk for at least one year and one day after approval of the minutes of the meeting at which the closed session was approved, after which the…”

Omdahl v. West Iron Cnty. Bd. of Educ., 722 N.W.2d 691 (Mich. Ct. App. 2006). “The trial court concluded that defendants violated MCL 15.267(2), and plaintiff was obviously a "person" under MCL 15.”

— Mich. Comp. Laws § 15.267(7) — 1 case

Harlan Vermilya v. Delta Coll. Bd. of Trs. (Mich. Ct. App. 2014).

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