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Oregon Revised Statutes

Or. Rev. Stat. § 192.680 (2026)

Enforcement of ORS 192.610 to 192.705; effect of violation on validity of decision of governing body; liability of members

✓ current as of May 2026
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      192.680 Enforcement of ORS 192.610 to 192.705; effect of violation on validity of decision of governing body; liability of members. (1) A decision made by a governing body of a public body in violation of ORS 192.610 to 192.705 shall be voidable. The decision shall not be voided if the governing body of the public body reinstates the decision while in compliance with ORS 192.610 to 192.705. A decision that is reinstated is effective from the date of its initial adoption.

      (2) Any person affected by a decision of a governing body of a public body may commence a suit in the circuit court for the county in which the governing body ordinarily meets, for the purpose of requiring compliance with, or the prevention of violations of ORS 192.610 to 192.705, by members of the governing body, or to determine the applicability of ORS 192.610 to 192.705 to matters or decisions of the governing body.

      (3) Notwithstanding subsection (1) of this section, if the court finds that the public body made a decision while in violation of ORS 192.610 to 192.705, the court shall void the decision of the governing body if the court finds that the violation was the result of intentional disregard of the law or willful misconduct by a quorum of the members of the governing body, unless other equitable relief is available. The court may order such equitable relief as it deems appropriate in the circumstances. The court may order payment to a successful plaintiff in a suit brought under this section of reasonable attorney fees at trial and on appeal, by the governing body, or public body of which it is a part or to which it reports.

      (4) If the court makes a finding that a violation of ORS 192.610 to 192.705 has occurred under subsection (2) of this section and that the violation is the result of willful misconduct by any member or members of the governing body, that member or members shall be jointly and severally liable to the governing body or the public body of which it is a part for the amount paid by the body under subsection (3) of this section.

      (5) Any suit brought under subsection (2) of this section must be commenced within 60 days following the date that the decision becomes public record.

      (6) The provisions of this section shall be the exclusive remedy for an alleged violation of ORS 192.610 to 192.705, except that this subsection does not apply to proceedings of the Oregon Government Ethics Commission. [1973 c.172 §8; 1975 c.664 §3; 1979 c.644 §6; 1981 c.897 §42; 1983 c.453 §2; 1989 c.544 §1; 2023 c.417 §8]

Notes of Decisions
Cited in 22 cases (1 in the last 5 years), 1975–2023 · leading case: Handy v. Lane Cnty., 362 P.3d 867 (Or. Ct. App. 2015).
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Handy v. Lane Cnty., 362 P.3d 867 (Or. Ct. App. 2015). · cites it 5× “When a plaintiff presents prima facie evidence of a violation of the open meetings law, the burden to prove that the provisions of ORS 192.”
People for the Ethical Treatment of Animals v. Institutional Animal Care & Use Comm., 817 P.2d 1299 (Or. 1991). · cites it 3× “, because PETA “did not bring its challenge as an action seeking remedies under ORS 192.680.” Id. at 283 . PETA petitioned this court for review, arguing that the Court of Appeals erred in its interpretation of Marbet v.”
Wood v. Wasco Cnty., 430 P.3d 575 (Or. Ct. App. 2018). · cites it 10× “2 Plaintiff also argues *578 that both Harris and ORS 192.680 support his position that the case was not rendered moot when Wasco County rescinded its decision because a completed decision is not required to initiate a lawsuit under the public meetings law.”
Harris v. Nordquist, 771 P.2d 637 (Or. Ct. App. 1989). · cites it 4× “ORS 192.680 provides for the right to bring an action under the Open Meetings Law and is the exclusive remedy for an alleged violation of that law.”
Dental v. City of Salem, 103 P.3d 1150 (Or. Ct. App. 2004). · cites it 5× “Tape Recording, Senate Local Government and Elections Committee, SB 190, Mar 21, 1983, Tape 40, Side A (statement of Legislative Counsel Kathleen Beaufait). ORS 192.”
Krisor v. Henry, 300 P.3d 199 (Or. Ct. App. 2013). · cites it 3× “640, which requires public notice of any governing body’s meetings, and that he was therefore entitled to challenge the decision in court and, if successful, void it, under ORS 192.680: “(1) A decision made by a governing body of a public body in violation of ORS 192.”
Anaconda Co. v. Dep't of Revenue, 565 P.2d 1084 (Or. 1977). · cites it 2× “NOTES [1] ORS 192.680, which provides for enforcement of the Public Meetings Law by suit, also provides: "No decision shall be voided by the court in a suit under this subsection solely because of a violation .”
Tri-Cnty. Metro. Transp. Dist. of Or. (Trimet) v. Amalgamated Transit Union Local 757, 412 P.3d 162 (Or. 2018). “, governing public meetings" as well as a declaration that, "because collective bargaining sessions between ATU and TriMet's negotiating team are not public meetings, any actions taken in those meetings are not subject to challenge under ORS 192.680." As noted, both parties…”
Krisor v. Lake Cnty. Fair Bd., 302 P.3d 455 (Or. Ct. App. 2013). · cites it 2× “Further, the only relief that plaintiff sought in Krisor I was the injunctive remedy provided for in ORS 192.680(1): a declaration that the appointment made by the board at the allegedly unlawful meeting be declared void.”
Pre-Hosp. Med. Servs., Inc. v. Malheur Cnty., 896 P.2d 585 (Or. Ct. App. 1995). · cites it 7× “20 See ORS 192.680(1). A judgment in favor of defendants was entered on June 11, 1993.”
Oregon Ass'n of Classified Employees v. Salem-Keizer Sch. Dist. 24J, 767 P.2d 1365 (Or. Ct. App. 1989). · cites it 6× “3 ORS 192.680. The trial court ruled that an “actual emergency” existed and that there was therefore no violation of the statute.”
Bd. of Cty. Comm. of Columbia Cty. v. Rosenblum, 526 P.3d 798 (Or. Ct. App. 2023). “See ORS 192.680(5), (6) (providing 60 days to challenge a decision made in violation of the public meetings law and providing exclusive remedy).”
Show all 22 citing cases →
— Or. Rev. Stat. § 192.680(1) — 8 cases
Harris v. Nordquist, 771 P.2d 637 (Or. Ct. App. 1989). “ORS 192.680 provides for the right to bring an action under the Open Meetings Law and is the exclusive remedy for an alleged violation of that law.”
Smith v. Sch. Dist. No. 45, 666 P.2d 1345 (Or. Ct. App. 1983).
Krisor v. Lake Cnty. Fair Bd., 302 P.3d 455 (Or. Ct. App. 2013). “Further, the only relief that plaintiff sought in Krisor I was the injunctive remedy provided for in ORS 192.680(1): a declaration that the appointment made by the board at the allegedly unlawful meeting be declared void.”
Oregon Ass'n of Classified Employees v. Salem-Keizer Sch. Dist. 24J, 767 P.2d 1365 (Or. Ct. App. 1989). “3 ORS 192.680. The trial court ruled that an “actual emergency” existed and that there was therefore no violation of the statute.”
Gugler v. Baker Cnty. Educ. Serv. Dist., 754 P.2d 891 (Or. 1988).
— Or. Rev. Stat. § 192.680(2) — 5 cases
Wood v. Wasco Cnty., 430 P.3d 575 (Or. Ct. App. 2018). “2 Plaintiff also argues *578 that both Harris and ORS 192.680 support his position that the case was not rendered moot when Wasco County rescinded its decision because a completed decision is not required to initiate a lawsuit under the public meetings law.”
People for the Ethical Treatment of Animals v. Institutional Animal Care & Use Comm., 817 P.2d 1299 (Or. 1991). “, because PETA “did not bring its challenge as an action seeking remedies under ORS 192.680.” Id. at 283 . PETA petitioned this court for review, arguing that the Court of Appeals erred in its interpretation of Marbet v.”
Rivas v. Bd. of Parole & Post-Prison Supervision, 369 P.3d 1239 (Or. Ct. App. 2016).
People for the Ethical Treatment of Animals v. Institutional Animal Care & Use Comm. of the Univ. of Oregon, 794 P.2d 1224 (Or. Ct. App. 1990).
Peta v. Inst. Animal Care & Use Com., 794 P.2d 1224 (Or. Ct. App. 1990).
— Or. Rev. Stat. § 192.680(3) — 5 cases
Handy v. Lane Cnty., 362 P.3d 867 (Or. Ct. App. 2015). “When a plaintiff presents prima facie evidence of a violation of the open meetings law, the burden to prove that the provisions of ORS 192.”
Pre-Hosp. Med. Servs., Inc. v. Malheur Cnty., 896 P.2d 585 (Or. Ct. App. 1995). “20 See ORS 192.680(1). A judgment in favor of defendants was entered on June 11, 1993.”
Harris v. Nordquist, 771 P.2d 637 (Or. Ct. App. 1989). “ORS 192.680 provides for the right to bring an action under the Open Meetings Law and is the exclusive remedy for an alleged violation of that law.”
Wood v. Wasco Cnty., 430 P.3d 575 (Or. Ct. App. 2018). “2 Plaintiff also argues *578 that both Harris and ORS 192.680 support his position that the case was not rendered moot when Wasco County rescinded its decision because a completed decision is not required to initiate a lawsuit under the public meetings law.”
Oregon Ass'n of Classified Employees v. Salem-Keizer Sch. Dist. 24J, 767 P.2d 1365 (Or. Ct. App. 1989). “3 ORS 192.680. The trial court ruled that an “actual emergency” existed and that there was therefore no violation of the statute.”
— Or. Rev. Stat. § 192.680(4) — 1 case
Krisor v. Lake Cnty. Fair Bd., 302 P.3d 455 (Or. Ct. App. 2013). “Further, the only relief that plaintiff sought in Krisor I was the injunctive remedy provided for in ORS 192.680(1): a declaration that the appointment made by the board at the allegedly unlawful meeting be declared void.”
— Or. Rev. Stat. § 192.680(5) — 2 cases
Bd. of Cty. Comm. of Columbia Cty. v. Rosenblum, 526 P.3d 798 (Or. Ct. App. 2023). “See ORS 192.680(5), (6) (providing 60 days to challenge a decision made in violation of the public meetings law and providing exclusive remedy).”
Krisor v. Henry, 300 P.3d 199 (Or. Ct. App. 2013). “640, which requires public notice of any governing body’s meetings, and that he was therefore entitled to challenge the decision in court and, if successful, void it, under ORS 192.680: “(1) A decision made by a governing body of a public body in violation of ORS 192.”
— Or. Rev. Stat. § 192.680(6) — 2 cases
People for the Ethical Treatment of Animals v. Institutional Animal Care & Use Comm. of the Univ. of Oregon, 794 P.2d 1224 (Or. Ct. App. 1990).
Peta v. Inst. Animal Care & Use Com., 794 P.2d 1224 (Or. Ct. App. 1990).
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