Missouri Revised Statutes

Mo. Rev. Stat. § 610.022 (2026)

Closed meetings, procedure and limitation

✓ current as of May 2026

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610.022. Closed meetings, procedure and limitation — public records presumed open unless exempt — objections to closing meetings or records, procedure. — 1. Except as set forth in subsection 2 of this section, no meeting or vote may be closed without an affirmative public vote of the majority of a quorum of the public governmental body. The vote of each member of the public governmental body on the question of closing a public meeting or vote and the specific reason for closing that public meeting or vote by reference to a specific section of this chapter shall be announced publicly at an open meeting of the governmental body and entered into the minutes.

2. A public governmental body proposing to hold a closed meeting or vote shall give notice of the time, date and place of such closed meeting or vote and the reason for holding it by reference to the specific exception allowed pursuant to the provisions of section 610.021. Such notice shall comply with the procedures set forth in section 610.020 for notice of a public meeting.

3. Any meeting or vote closed pursuant to section 610.021 shall be closed only to the extent necessary for the specific reason announced to justify the closed meeting or vote. Public governmental bodies shall not discuss any business in a closed meeting, record or vote which does not directly relate to the specific reason announced to justify the closed meeting or vote. Public governmental bodies holding a closed meeting shall close only an existing portion of the meeting facility necessary to house the members of the public governmental body in the closed session, allowing members of the public to remain to attend any subsequent open session held by the public governmental body following the closed session.

4. Nothing in sections 610.010 to 610.028 shall be construed as to require a public governmental body to hold a closed meeting, record or vote to discuss or act upon any matter.

5. Public records shall be presumed to be open unless otherwise exempt pursuant to the provisions of this chapter.

6. In the event any member of a public governmental body makes a motion to close a meeting, or a record, or a vote from the public and any other member believes that such motion, if passed, would cause a meeting, record or vote to be closed from the public in violation of any provision in this chapter, such latter member shall state his or her objection to the motion at or before the time the vote is taken on the motion. The public governmental body shall enter in the minutes of the public governmental body any objection made pursuant to this subsection. Any member making such an objection shall be allowed to fully participate in any meeting, record or vote that is closed from the public over the member's objection. In the event the objecting member also voted in opposition to the motion to close the meeting, record or vote at issue, the objection and vote of the member as entered in the minutes shall be an absolute defense to any claim filed against the objecting member pursuant to section 610.027.

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(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.)

(1993) A school board's workshop designed to improve effective communication and group interaction did not violate open meetings law because no public business was discussed. Kansas City Star Co. v. Fulson, 859 S.W.2d 934 (Mo. App. W.D.).

Notes of Decisions

Cited in 7 cases, 1991–2016 · leading case: State Ex Rel. Moore v. Brewster, 116 S.W.3d 630 (Mo. Ct. App. 2003).

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State Ex Rel. Moore v. Brewster, 116 S.W.3d 630 (Mo. Ct. App. 2003). · cites it 6× “Section 610.022 details the procedure to close meetings and the limitations imposed on closed meetings.”

Kansas City Star Co. v. Fulson, 859 S.W.2d 934 (Mo. Ct. App. 1993). · cites it 4× “*942 Section 610.022 sets forth the procedure a public governmental body must follow in closing a public meeting.”

Wilkendon P'ship v. St. Louis Cnty. Bd. of Equalization, Defendants/Respondents., 497 S.W.3d 873 (Mo. Ct. App. 2016). “§ 610.022. 1. Except as set forth in subsection 2 of this section, no meeting or vote may be closed without an affirmative public vote of the majority of a quorum of the public governmental body.”

Wolfskill v. Henderson, 823 S.W.2d 112 (Mo. Ct. App. 1991). “This is in contrast to the meeting closure method spelled out in § 610.022. Therefore, although the method employed by the City may be circuitous, it cannot be labelled invalid, as investigative files dealing with disciplinary matters are authorized to be closed under Missouri…”

Moynihan v. City of Manchester, 265 S.W.3d 350 (Mo. Ct. App. 2008). · cites it 2× “Section 610.022. The Board, at an open meeting, must give notice of the time, date and place of the closed meeting, and must state the reason for holding a closed meeting by reference to the specific exception allowed in section 610.”

SNL Sec., L.C. v. Nat'l Ass'n of Ins. Commissioners, 23 S.W.3d 734 (Mo. Ct. App. 2000). “4 of the Sunshine Law, insisted the NAIC provide the records at cost, as dictated by § 610.022, rather than through licensing agreements.”

State ex rel. Lohman v. Brown, 936 S.W.2d 607 (Mo. Ct. App. 1997). · cites it 2× “, and Sports and Fitness Management Corporation, brought an action against the Director of Revenue and the Department of Revenue seeking a writ of mandamus and a declaration that the Director of Revenue has violated § 610.022, RSMo 1994, the Missouri Open Meetings Law (the…”

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