RECENT CALIFORNIA DECISIONS

May 2002

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Court of Appeal Legislative Bodies Must Provide Detail of Items Noticed for Closed Session Discussions, and Confine Discussions to Those Items Noticed, to Be in Compliance under Brown Act
Shapiro v. San Diego City Council

The Fourth District Court of Appeal affirmed the decision of the Superior Court of San Diego County, holding that the San Diego City Council violated the Brown Act when it held closed-session discussions with its real estate negotiators regarding the construction of a major league ballpark for the San Diego Padres. The court also found that the San Diego City Counsel improperly noticed the closed-session discussions, and exceeded the scope of the notice provided.