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Sacramento Newspaper Guild v. Sacramento County Board of Supervisors
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Sacramento Newspaper Guild v. Sacramento County Bd. of Supervisors was a case before California's Third District Court of Appeal in 1968 concerning open meetings.
Important precedents
This case established that the California Open Meeting Act did not apply in situations where the attorney-client privilege of the public body would be violated.
Background
- On February 8, 1967 the "five county supervisors, the county counsel, county executive, county director of welfare and several members of the Central Labor Council, AFL-CIO" attended lunch at a luncheon at the Elks Club in Sacramento. The subject of discussion was a local social workers strike affecting the county. The press was denied access to the meeting.
- The newspaper guild filed suit, seeking to prevent future closed meeting of the county counsel under the California Open Meeting Act(Brown Act).
- The county argued that the Open Meetings Act only applied to interest persons, and is an aspect of citizenship, and did not apply to groups or organizations relying on Adler v. City Council of Culver City.
Ruling of the court
The Supreme Court found that the intention of the Brown Act was to expose all deliberation and action by government bodies to open, public review. The gathering at the Elks club clearly fell under this expansive concept of meeting. Also, while the court found that the meeting was not exempt because of attorney-client privilege because the meeting was not convened with the intent of communicating special legal matters that needed to be maintained in confidence, it established an important precedent in declaring that the Brown Act was not meant to strip the attorney-client privilege from governmental bodies and thus amended the injunction against future meetings to not include meetings that fell under the category of attorney-client privilege. Thus, the court ruled in favor of the guild, affirming the district courts decision.