The Ohio Court of Appeals recently ruled on a case involving allegations against the Chardon Township Board of Trustees for violating the Open Meetings Act (OMA). The court's decision impacts how public bodies must conduct meetings and maintain transparency with the public. The case, State ex rel. Ames v. Chardon Twp. Bd. of Trustees (2025-G-0038), highlights the importance of adhering to legal requirements for public meetings.
The dispute began when Brian M. Ames, a resident of Mogadore, Ohio, filed a complaint against the Chardon Township Board. Ames claimed that the Board committed multiple violations of the OMA, which is designed to ensure that public officials conduct business openly and transparently. The case was filed in the Geauga County Court of Common Pleas and later appealed to the Ohio Court of Appeals.
Ames alleged four specific violations in his complaint. First, he argued that the Board held executive sessions without properly stating the statutory purpose for those sessions, as required by R.C. 121.22(G). Second, he claimed the Board failed to keep full and accurate minutes of its meetings, violating R.C. 121.22(C). Third, Ames asserted that the Board did not establish a proper rule for notifying the public of its meetings, as mandated by R.C. 121.22(F). Lastly, he contended that the Board held a special meeting without having a valid notification rule in place.
The case reached the Ohio Court of Appeals after the trial court denied Ames' motion for judgment on the pleadings and granted summary judgment to the Board. The trial court found that the Board had complied with the OMA, but Ames appealed, arguing that the court made errors in its rulings.
In its ruling on June 8, 2026, the Ohio Court of Appeals affirmed the trial court's denial of Ames' motion for judgment on the pleadings but reversed the grant of summary judgment to the Board. The court determined that the Board did not meet its burden of proof to show that there were no genuine issues of material fact, particularly regarding the alleged violations of the OMA.
Judge Matt Lynch, writing for the court, stated, "The Board failed its initial burden to introduce evidentiary quality material demonstrating it was entitled to judgment as a matter of law on Count 1 of Ames’ complaint." This indicates that the court found the Board's evidence insufficient to justify its actions regarding the executive sessions and the minutes of the meetings.
The court emphasized that the purpose of the OMA is to prevent public officials from meeting secretly and to ensure accountability to the public. The OMA requires that all meetings of public bodies be open to the public, and any actions taken in violation of this law are deemed invalid.
In its analysis, the court looked closely at the minutes from the Board's meetings and the affidavit provided by the Board's administrative assistant. The court found that the minutes did not adequately reflect the statutory purposes for the executive sessions, as required by law. This lack of clarity raised concerns about whether the public could determine if the sessions were held for proper purposes.
Additionally, the court found that the Board's argument that its minutes were accurate based on the affidavit was flawed. The minutes themselves did not contain sufficient detail to meet the requirements of the OMA, and therefore, the court ruled that the Board was not entitled to summary judgment on this count.
The ruling has significant implications for public bodies in Ohio. It reinforces the necessity for transparency and adherence to the Open Meetings Act. Public officials must ensure that they clearly state the purposes of executive sessions in their minutes and maintain accurate records of their meetings. Failure to do so can lead to legal challenges and potential invalidation of actions taken during those meetings.
Looking ahead, the court remanded the case back to the trial court for further proceedings. This means that the case is not over, and the trial court will need to address the issues raised by the appeals court. The outcome of this case could set a precedent for how public bodies in Ohio manage their meetings and comply with transparency laws.
Ames' case serves as a reminder to public officials about the importance of following the law and being accountable to the public they serve. The court's ruling underscores the need for clear communication and documentation in public meetings, ensuring that citizens can trust their government operates openly and transparently.