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Wood v. Battleground School District is a 2001 decision of the State of Washington Court of Appeals. The court ruled that e-mails between school board members to decide on the termination of an employee violated the intent of the state's Open Public Meetings Act.
The court determined that an exchange of emails can constitute a meeting and thus be subject to Washington's open meetings act. They further ruled that members-elect of a government body are still subject to open records law.
Jennifer Wood, an employee of the Battle Ground public school district, was terminated from her employment. She filed a lawsuit which said that in its discussions about terminating her, the school district and others violated the state's public disclosure act and the Open Public Meetings Act. Wood also sought damages from the president of the school board for defamation.
The Superior Court for Clark County found in favor of the plaintiff on November 5, 1999 with respect to her claim about the school district violating the open meetings law. The plaintiff's claim that she had been defamed was dismissed.
The judgment in Wood's favor included a $200 statutory penalty against each individual defendant for two Open Public Meetings Act violations and an award of attorney fees.
This decision was appealed. The Court of Appeals vacated both parts of the lower court's determination and ordered it to re-consider.
One issue in the case was whether members-elect of a school board are subject to the state's open meetings law. The lower court, in finding in favor of the plaintiff, assumed that members-elect are subject to the law. The Court of Appeals ruled against this concept, saying it is up to the legislature to determine whether or not people who have been elected to a position but who have not yet been sworn-in are subject to open disclosure laws.
Meeting by e-mail
The appellate court ruled that the exchange of e-mails can constitute a "meeting."
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