McKay v. Board of County Commissioners

746 P.2d 124, 103 Nev. 490, 1987 Nev. LEXIS 1866
CourtNevada Supreme Court
DecidedNovember 30, 1987
DocketNo. 17617
StatusPublished
Cited by31 cases

This text of 746 P.2d 124 (McKay v. Board of County Commissioners) is published on Counsel Stack Legal Research, covering Nevada Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McKay v. Board of County Commissioners, 746 P.2d 124, 103 Nev. 490, 1987 Nev. LEXIS 1866 (Neb. 1987).

Opinion

[491]*491OPINION

By the Court,

Springer, J.:

Nevada’s Open Meeting Law1 requires all meetings of public bodies to be public meetings “except as otherwise specifically provided by statute.” On December 6, 1984, the Douglas County Board of County Commissioners, a public body, conducted a closed meeting with its attorney. Since there is no statute which provides a specific exception permitting public bodies to hold closed meetings simply because their attorneys are present, the meeting was in violation of the open meeting law.

The closed meeting arose out of the following set of circumstances. During the afternoon session of a regularly scheduled public meeting, the board’s legal counsel brought up the subject of a proposed settlement offer by the liability insurance carrier which was defending a professional liability claim involving the county and an architecture firm. Two members of the board had expressed dissatisfaction with the insurance carrier’s settlement offer, and the board had directed that the district attorney there and then discuss the matter further with the insurance carrier. After meeting with representatives of the insurance carrier in a nearby room the district attorney returned to the public meeting and requested that the board reconvene in a closed, executive session in order to discuss the settlement matters. A representative of the news media objected to the proposed closed meeting; whereupon the board nonetheless passed unanimously a motion to convene for a closed “executive meeting” with the district attorney and certain state and county employees. The closed session lasted approximately twenty-five minutes, after which the board reconvened the regular public meeting and voted to accept the original settlement proposal.

The law is clear: Absent a statute that “specifically provided” an exception for attorneys, the meeting had to be “open and public.” There is no statutory exception specifically providing public bodies with the privilege to meet in private just because they have their attorneys present; hence, such meetings are prohibited. The idea that a public body can legally hold a closed [492]*492meeting with its lawyer in the face of the statutory prohibition can be advanced only by accepting one or the other of the following propositions: (1) authority to conduct a closed meeting with legal counsel is an implied and unstated provision of the open meeting law which the legislature must have intended but for some unknown reason failed to enact, or, (2) there is some kind of unspoken, constitutional, statutory, common law or public policy consideration that supercedes and overcomes the language of the open meeting law and permits public bodies to hold closed meetings if they include their attorneys.

Initially it is important to note with respect to the first proposition, the implied exception argument, that it is not the business of this court to fill in alleged legislative omissions based on conjecture as to what the legislature would or should have done. This is especially true when the legislature has already stated in as unambiguous terms as can be imagined that if there are to be any exceptions to the rule of publicity, they must be “specifically provided by statute.” To imply an exception in the face of this straightforward language would be in direct opposition to the expressed legislative intent.

When it has been deemed suitable to do so, the legislature has from time to time “specifically provided” certain exceptions to the open meeting requirement. Exceptions provided which permit closed meetings, for example, include questions of personal character, misconduct, competence and health (NRS 241.030(1)). In addition to these exceptions, the legislature, in other NRS chapters, has enacted a series of specific exceptions to the general rule of publicity. {See NRS 281.511(9), 286.150(2), 288.220, 630.336, 392.467(3)). When the legislature intends to make exceptions to the rule of publicity, it does so specifically by statute. In view of the method which the legislature has followed with regard to the rule of publicity, it is otiose to argue that the legislature really meant to include an “attorney-client” exception in the open meeting law but did not get around to it.2 Even if we were to believe that the legislature had intended to enact such an exception, the wording of the open meeting law requiring excep[493]*493tions to be expressly enacted and “specifically provided” forecloses the court from reading in or implying exceptions to the rule of publicity. As clearly as it possibly could, the legislature has expressed its will: Meetings of public bodies shall be “open and public,” unless the legislature subsequently enacts a statute specifically providing an exception to the rule of publicity.3

This court’s position is squarely supported by Laman v. McCord, 432 S.W.2d 753 (Ark. 1968), in which the Supreme Court of Arkansas rejected a city’s argument that an attorney-client privilege should be judicially imposed so that the public body could prepare its case without having to disclose its strategy and possible weaknesses to adversaries. Essentially the same contention is advanced by the public body in the case before us. The Arkansas court based its decision upholding the open meeting law upon a literal interpretation of the statutory language, “[ejxcept as otherwise specifically provided by law, all meetings ... of the governing bodies of all municipalities . . . shall be public meetings.” (Emphasis in original.) Reasoning that “specifically” meant “explicitly,” “definitely,” and “in so many words,” the Arkansas Supreme Court rightly concluded that since the legislature did not provide a specific exception for meetings of the city council and the city attorney, no exception existed. See Neu v. Miami Herald Publishing Company, 462 So.2d 821 (Fla. 1985).

Since no attorney-client privilege can be implied from the wording of Nevada’s open meeting law, we turn to the second possible argument, namely, that we should recognize some independent, immutable right of private consultation between public boards and their attorneys which supercedes the legislative power and which allows public bodies to hold private meetings with their attorneys, without regard to the open-meeting legislation. This second argument deals not with an “implied” exception, which is to say an exception inferred from the nature and content of the statute itself; rather the issue now becomes whether some independent, constitutional, statutory, common law or public policy consideration supercedes and overcomes the language of the statute and permits private meetings between public bodies and lawyers notwithstanding the mandate of openness contained in the open meeting statute.

[494]*494If such a superceding right to hold closed meetings were to be recognized, it would have to be derived from either of two possible sources: the privilege of a client that an attorney not be compelled to testify concerning confidential attorney-client communications, or, the ethical imperative that an attorney not reveal a client’s secrets.

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Bluebook (online)
746 P.2d 124, 103 Nev. 490, 1987 Nev. LEXIS 1866, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mckay-v-board-of-county-commissioners-nev-1987.