Missouri Revised Statutes

Mo. Rev. Stat. § 610.010 (2026)

Definitions

✓ current as of May 2026

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610.010. Definitions. — As used in this chapter, unless the context otherwise indicates, the following terms mean:

(1) "Closed meeting", "closed record", or "closed vote", any meeting, record or vote closed to the public;

(2) "Copying", if requested by a member of the public, copies provided as detailed in section 610.026, if duplication equipment is available;

(3) "Public business", all matters which relate in any way to the performance of the public governmental body's functions or the conduct of its business;

(4) "Public governmental body", any legislative, administrative or governmental entity created by the Constitution or statutes of this state, by order or ordinance of any political subdivision or district, judicial entities when operating in an administrative capacity, or by executive order, including:

(a) Any body, agency, board, bureau, council, commission, committee, board of regents or board of curators or any other governing body of any institution of higher education, including a community college, which is supported in whole or in part from state funds, including but not limited to the administrative entity known as "The Curators of the University of Missouri" as established by section 172.020;

(b) Any advisory committee or commission appointed by the governor by executive order;

(c) Any department or division of the state, of any political subdivision of the state, of any county or of any municipal government, school district or special purpose district including but not limited to sewer districts, water districts, and other subdistricts of any political subdivision;

(d) Any other legislative or administrative governmental deliberative body under the direction of three or more elected or appointed members having rulemaking or quasi-judicial power;

(e) Any committee appointed by or at the direction of any of the entities and which is authorized to report to any of the above-named entities, any advisory committee appointed by or at the direction of any of the named entities for the specific purpose of recommending, directly to the public governmental body's governing board or its chief administrative officer, policy or policy revisions or expenditures of public funds including, but not limited to, entities created to advise bi-state taxing districts regarding the expenditure of public funds, or any policy advisory body, policy advisory committee or policy advisory group appointed by a president, chancellor or chief executive officer of any college or university system or individual institution at the direction of the governing body of such institution which is supported in whole or in part with state funds for the specific purpose of recommending directly to the public governmental body's governing board or the president, chancellor or chief executive officer policy, policy revisions or expenditures of public funds provided, however, the staff of the college or university president, chancellor or chief executive officer shall not constitute such a policy advisory committee. The custodian of the records of any public governmental body shall maintain a list of the policy advisory committees described in this subdivision;

(f) Any quasi-public governmental body. The term "quasi-public governmental body" means any person, corporation or partnership organized or authorized to do business in this state pursuant to the provisions of chapter 352, 353, or 355, or unincorporated association which either:

a. Has as its primary purpose to enter into contracts with public governmental bodies, or to engage primarily in activities carried out pursuant to an agreement or agreements with public governmental bodies; or

b. Performs a public function as evidenced by a statutorily based capacity to confer or otherwise advance, through approval, recommendation or other means, the allocation or issuance of tax credits, tax abatement, public debt, tax-exempt debt, rights of eminent domain, or the contracting of leaseback agreements on structures whose annualized payments commit public tax revenues; or any association that directly accepts the appropriation of money from a public governmental body, but only to the extent that a meeting, record, or vote relates to such appropriation; and

(g) Any bi-state development agency established pursuant to section 70.370;

(5) "Public meeting", any meeting of a public governmental body subject to sections 610.010 to 610.030 at which any public business is discussed, decided, or public policy formulated, whether such meeting is conducted in person or by means of communication equipment, including, but not limited to, conference call, video conference, internet chat, or internet message board. The term "public meeting" shall not include an informal gathering of members of a public governmental body for ministerial or social purposes when there is no intent to avoid the purposes of this chapter, but the term shall include a public vote of all or a majority of the members of a public governmental body, by electronic communication or any other means, conducted in lieu of holding a public meeting with the members of the public governmental body gathered at one location in order to conduct public business;

(6) "Public record", any record, whether written or electronically stored, retained by or of any public governmental body including any report, survey, memorandum, or other document or study prepared for the public governmental body by a consultant or other professional service paid for in whole or in part by public funds, including records created or maintained by private contractors under an agreement with a public governmental body or on behalf of a public governmental body; provided, however, that personally identifiable student records maintained by public educational institutions shall be open for inspection by the parents, guardian or other custodian of students under the age of eighteen years and by the parents, guardian or other custodian and the student if the student is over the age of eighteen years. The term "public record" shall not include any internal memorandum or letter received or prepared by or on behalf of a member of a public governmental body consisting of advice, opinions and recommendations in connection with the deliberative decision-making process of said body, unless such records are retained by the public governmental body or presented at a public meeting. Any document or study prepared for a public governmental body by a consultant or other professional service as described in this subdivision shall be retained by the public governmental body in the same manner as any other public record;

(7) "Public vote", any vote, whether conducted in person, by telephone, or by any other electronic means, cast at any public meeting of any public governmental body.

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(L. 1973 S.B. 1 § 1, A.L. 1977 H.B. 130, A.L. 1978 H.B. 882, A.L. 1982 H.B. 1253, A.L. 1987 S.B. 2, A.L. 1993 H.B. 170, A.L. 1998 H.B. 1095, A.L. 2004 S.B. 1020, et al.)

(1979) Springfield board of public utilities is a "public governmental body" within the meaning of the Open Meetings Act. State ex rel. Board of Public Utilities v. Crow (A.), 592 S.W.2d 285.

(1984) A single member body may be a "governmental entity" for purposes of sunshine law, which is to be liberally construed in favor of open government. McLachlan v. McNary (Mo. App.), 684 S.W.2d 534.

(1996) Official meetings of federal governmental bodies are not subject to the Missouri Sunshine Act. In Re Kansas City Star Co., 73 F.3d 191 (8th Cir.).

(2002) For-profit telecommunications utility with the power of eminent domain, but without the power to tax, to formulate policies, or to promulgate statutes, ordinances, or regulations, does not constitute a public governmental body within meaning of section. Stewart v. Williams Communications, Inc., 85 S.W.3d 29 (Mo.App.W.D.).

Notes of Decisions

Cited in 149 cases (29 in the last 5 years), 1975–2026 · leading case: Rachal Laut, f/k/a Rachal Govro, & John M. Soellner v. City of Arnold, 491 S.W.3d 191 (Mo. 2016).

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Rachal Laut, f/k/a Rachal Govro, & John M. Soellner v. City of Arnold, 491 S.W.3d 191 (Mo. 2016). · cites it 41× “027 expressly states that a knowing violation occurs when the public entity “has knowingly violated sections 610.010 to 610.026.” § 610.027.3.”

Spradlin v. City of Fulton, 982 S.W.2d 255 (Mo. 1998). · cites it 34× “2 provides that the public governmental body and its members bear the burden of persuasion to demonstrate compliance with sections 610.010 to 610.026. C. The evidence indicating what was discussed at the meetings in question includes minutes from the closed meetings and…”

Tribune Publ'g Co. v. Curators of the Univ. of Missouri, 661 S.W.2d 575 (Mo. Ct. App. 1983). · cites it 27× “Tribune’s petition was predicated on §§ 610.010, 610.015, 610.020, 610.-025 and 610.”

Champ v. Poelker, 755 S.W.2d 383 (Mo. Ct. App. 1988). · cites it 23× “In Count III, paragraph four, appellants claim that on September 20, 1982, the Convention Bureau held a closed meeting without public notice in violation of section 610.010, RSMo 1986. Appellants incorporate these allegations into Count IV, and add the allegation that the…”

Hemeyer v. KRCG-TV, 6 S.W.3d 880 (Mo. 1999). · cites it 20× “Sections 610.010 to 610.028 shall be liberally construed and their exceptions strictly construed to promote this public policy.”

Stewart v. Williams Commc'ns, Inc., 85 S.W.3d 29 (Mo. Ct. App. 2002). · cites it 29× “Stewart’s petition alleges facts which establish the elements of a recognized cause of action, it will be necessary to interpret the provisions of § 610.010 of the Sunshine Law. “The primary rule of statutory construction is to ascertain the intent of the legislature from the…”

Bauer v. Kincaid, 759 F. Supp. 575 (W.D. Mo. 1991). · cites it 11× “Plaintiff agrees that defendants could produce evidence, which plaintiff does not refute, that the incident reports in possession of the Springfield Police Department are available to plaintiff, and all members of the public, in the same fashion as all investigation records of…”

Oregon Cnty. R-IV Sch. Dist. v. LeMon, 739 S.W.2d 553 (Mo. Ct. App. 1987). · cites it 15× “” 1 The petition alleged that the school district, “a public governmental body,” § 610.010, 2 on June 2, 1986, informed LeMon that it “was concerned about the confidentiality of the records requested and, therefore, could not furnish the information until that issue had been…”

Colombo v. Buford, 935 S.W.2d 690 (Mo. Ct. App. 1996). · cites it 13× “This is an appeal from an order in a judge-tried case sustaining respondents’ “motion for directed verdict” at the close of appellants’ evidence on appellants’ petition alleging violations of the Sunshine Law, §§ 610.010 — 610.026. 1 Appellants raise four points on appeal; three…”

Remington v. City of Boonville, 701 S.W.2d 804 (Mo. Ct. App. 1985). · cites it 22× “015, RSMo 1978, and §§ 610.010, 610.020 and 610.025, RSMo Supp.”

Aaron M. Malin v. Cole Cnty. Prosecuting Attorney, 565 S.W.3d 748 (Mo. Ct. App. 2019). · cites it 11× “3 provides the possible consequences, stating: Upon a finding by a preponderance of the evidence that a public governmental body or a member of a public governmental body has knowingly violated sections 610.010 to 610.026, the public governmental body or the member shall be…”

Tipton v. Barton, 747 S.W.2d 325 (Mo. Ct. App. 1988). · cites it 10× “Appellants initially contend that the trial court erred in holding that appellant Roscoe, city coordinator of the City of Wentzville, is a “public governmental body” under the Missouri Open Meetings Act, §§ 610.010 — 610.030 RSMo 1986. The Act defines a public governmental body…”

Show all 149 citing cases →

— Mo. Rev. Stat. § 610.010(1) — 6 cases

Oregon Cnty. R-IV Sch. Dist. v. LeMon, 739 S.W.2d 553 (Mo. Ct. App. 1987). “” 1 The petition alleged that the school district, “a public governmental body,” § 610.010, 2 on June 2, 1986, informed LeMon that it “was concerned about the confidentiality of the records requested and, therefore, could not furnish the information until that issue had been…”

State Ex Rel. Goodman v. St. Louis Bd. of Police Comm'n, 181 S.W.3d 156 (Mo. Ct. App. 2005).

State ex rel. Jackson Cnty. Grand Jury v. Shinn, 835 S.W.2d 347 (Mo. Ct. App. 1992).

State ex rel. Goodman v. St. Louis Bd. of Police Commissioners, 181 S.W.3d 156 (Mo. Ct. App. 2005).

Elad Gross v. Michael Parson (Mo. 2021).

— Mo. Rev. Stat. § 610.010(13) — 1 case

Ben Sansone v. Governor of Missouri (Mo. Ct. App. 2022).

— Mo. Rev. Stat. § 610.010(2) — 20 cases

Champ v. Poelker, 755 S.W.2d 383 (Mo. Ct. App. 1988). “In Count III, paragraph four, appellants claim that on September 20, 1982, the Convention Bureau held a closed meeting without public notice in violation of section 610.010, RSMo 1986. Appellants incorporate these allegations into Count IV, and add the allegation that the…”

Tribune Publ'g Co. v. Curators of the Univ. of Missouri, 661 S.W.2d 575 (Mo. Ct. App. 1983). “Tribune’s petition was predicated on §§ 610.010, 610.015, 610.020, 610.-025 and 610.”

Remington v. City of Boonville, 701 S.W.2d 804 (Mo. Ct. App. 1985). “015, RSMo 1978, and §§ 610.010, 610.020 and 610.025, RSMo Supp.”

Hyde v. City of Columbia, 637 S.W.2d 251 (Mo. Ct. App. 1982).

Stewart v. Williams Commc'ns, Inc., 85 S.W.3d 29 (Mo. Ct. App. 2002). “Stewart’s petition alleges facts which establish the elements of a recognized cause of action, it will be necessary to interpret the provisions of § 610.010 of the Sunshine Law. “The primary rule of statutory construction is to ascertain the intent of the legislature from the…”

— Mo. Rev. Stat. § 610.010(2)(3) — 1 case

Tribune Publ'g Co. v. Curators of the Univ. of Missouri, 661 S.W.2d 575 (Mo. Ct. App. 1983). “Tribune’s petition was predicated on §§ 610.010, 610.015, 610.020, 610.-025 and 610.”

— Mo. Rev. Stat. § 610.010(3) — 6 cases

Kansas City Star Co. v. Fulson, 859 S.W.2d 934 (Mo. Ct. App. 1993).

Tribune Publ'g Co. v. Curators of the Univ. of Missouri, 661 S.W.2d 575 (Mo. Ct. App. 1983). “Tribune’s petition was predicated on §§ 610.010, 610.015, 610.020, 610.-025 and 610.”

Kansas City Star Co. v. Shields, 771 S.W.2d 101 (Mo. Ct. App. 1989).

MacLachlan v. McNary, 684 S.W.2d 534 (Mo. Ct. App. 1984).

Remington v. City of Boonville, 701 S.W.2d 804 (Mo. Ct. App. 1985). “015, RSMo 1978, and §§ 610.010, 610.020 and 610.025, RSMo Supp.”

— Mo. Rev. Stat. § 610.010(4) — 30 cases

Tipton v. Barton, 747 S.W.2d 325 (Mo. Ct. App. 1988). “Appellants initially contend that the trial court erred in holding that appellant Roscoe, city coordinator of the City of Wentzville, is a “public governmental body” under the Missouri Open Meetings Act, §§ 610.010 — 610.030 RSMo 1986. The Act defines a public governmental body…”

North Kansas City Hosp. Bd. of Trs. v. St. Luke's Northland Hosp., 984 S.W.2d 113 (Mo. Ct. App. 1998).

News-Press & Gazette Co. v. Cathcart, 974 S.W.2d 576 (Mo. Ct. App. 1998).

— Mo. Rev. Stat. § 610.010(4)(a) — 1 case

Nat'l Council of Teachers Quality, Inc. v. Curators of the Univ. of Missouri, 446 S.W.3d 723 (Mo. Ct. App. 2014).

— Mo. Rev. Stat. § 610.010(4)(c) — 1 case

Sylvia Pride v. Boone Cnty. Sheriff's Dep't & Diana O'Neill (Mo. Ct. App. 2023).

— Mo. Rev. Stat. § 610.010(4)(d) — 1 case

Wilkendon P'ship v. St. Louis Cnty. Bd. of Equalization, Defendants/Respondents., 497 S.W.3d 873 (Mo. Ct. App. 2016).

— Mo. Rev. Stat. § 610.010(4)(e) — 2 cases

Colombo v. Buford, 935 S.W.2d 690 (Mo. Ct. App. 1996). “This is an appeal from an order in a judge-tried case sustaining respondents’ “motion for directed verdict” at the close of appellants’ evidence on appellants’ petition alleging violations of the Sunshine Law, §§ 610.010 — 610.026. 1 Appellants raise four points on appeal; three…”

Opinion No. (2004) (Mo. Att'y Gen. 2004).

— Mo. Rev. Stat. § 610.010(4)(f) — 5 cases

Aaron M. Malin v. Missouri Ass'n of Cmty. Task Forces (d/b/a/ ACT Missouri) (Mo. Ct. App. 2023).

SNL Sec., L.C. v. Nat'l Ass'n of Ins. Commissioners, 23 S.W.3d 734 (Mo. Ct. App. 2000).

Burnside v. Gilliam Cement. Ass'n of Gilliam, 96 S.W.3d 155 (Mo. Ct. App. 2003).

Aaron Malin v. Missouri Ass'n of Cmty. Task Forces, D/B/A ACT Missouri (Mo. Ct. App. 2020).

— Mo. Rev. Stat. § 610.010(4)(f)(a) — 1 case

Aaron Malin v. Missouri Ass'n of Cmty. Task Forces, D/B/A ACT Missouri (Mo. Ct. App. 2020).

— Mo. Rev. Stat. § 610.010(4)(f)(b) — 1 case

Aaron Malin v. Missouri Ass'n of Cmty. Task Forces, D/B/A ACT Missouri (Mo. Ct. App. 2020).

— Mo. Rev. Stat. § 610.010(4)(g) — 1 case

KMOV TV, INC. v. Bi-State Dev. Agency, 625 F. Supp. 2d 808 (E.D. Mo. 2008).

— Mo. Rev. Stat. § 610.010(5) — 2 cases

State Ex Rel. Moore v. Brewster, 116 S.W.3d 630 (Mo. Ct. App. 2003).

— Mo. Rev. Stat. § 610.010(6) — 31 cases

Hemeyer v. KRCG-TV, 6 S.W.3d 880 (Mo. 1999). “Sections 610.010 to 610.028 shall be liberally construed and their exceptions strictly construed to promote this public policy.”

State Ex Rel. Moore v. Brewster, 116 S.W.3d 630 (Mo. Ct. App. 2003).

Jones v. Jackson Cnty. Circuit Court, 162 S.W.3d 53 (Mo. Ct. App. 2005).

Petruska v. City of Kinloch, 559 S.W.3d 386 (Mo. Ct. App. 2018).

John P. Strake v. Robinwood West Cmty. Improvement Dist., 473 S.W.3d 642 (Mo. 2015).

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