Supreme Court
No. 2025-6-Appeal. (PC 22-4727)
Nicole Solas :
v. :
South Kingstown School Committee. :
NOTICE: This opinion is subject to formal revision before publication in the Rhode Island Reporter. Readers are requested to notify the Opinion Analyst, Supreme Court of Rhode Island, 250 Benefit Street, Providence, Rhode Island 02903, at Telephone (401) 222-3258 or Email opinionanalyst@courts.ri.gov, of any typographical or other formal errors in order that corrections may be made before the opinion is published. Supreme Court
Present: Suttell, C.J., Goldberg, Robinson, Lynch Prata, and Long, JJ.
OPINION
Justice Lynch Prata, for the Court. The plaintiff, Nicole Solas, appeals
from a Superior Court entry of judgment in favor of the defendant, the South
Kingstown School Committee. This case comes before the Court pursuant to an
order directing the parties to appear and show cause why the issues raised in this
appeal should not be summarily decided. After considering the parties’ written and
oral submissions and reviewing the record, we conclude that cause has not been
shown and that this case may be decided without further briefing or argument. The
issue presented on appeal is whether the Black, Indigenous, People of Color
(BIPOC) Advisory Board is a “public body” subject to the Open Meetings Act
(OMA), G.L. 1956 § 42-46-3. For the reasons set forth in this opinion, we affirm
the judgment of the Superior Court.
-1- Facts and Travel
On June 23, 2020, Robin Wildman, executive director of Nonviolent Schools
Rhode Island (NSRI), gave a presentation to the South Kingstown School
Committee (the school committee) on the mission of NSRI and how the organization
could help improve the “climate and culture” of the South Kingstown school district.
On July 22, 2020, the school committee unanimously voted to create the “equity and
anti racist advisory board” which later became known as the BIPOC Advisory Board
(the Board) facilitated by Wildman and Jonathan Lewis, a training director at NSRI.
The school committee authorized Wildman and Lewis to facilitate Board meetings
in response to numerous community members expressing their concerns about the
lack of diversity in district staff members and racial inequity in the district’s student
disciplinary policies. Community members also shared that students were
experiencing acts of racism to such a degree that the school district should implement
anti-racist professional development training and provide conflict-resolution
training to promote a more equitable school district.
On October 27, 2020, the school committee unanimously voted to continue
the Board and executed an agreement with NSRI to facilitate twenty-five meetings
-2- from February through August 2021. Thereafter, the school committee allotted
$5,000 of its funds to the Board to facilitate these meetings. 1
In May 2021, plaintiff learned of the Board’s existence and asked the
superintendent of the school district, Linda Savastano, for permission to attend its
meetings. Savastano directed plaintiff to Wildman, who informed plaintiff that the
school district hired the NSRI as a private vendor and that at that time, the Board’s
meetings were not open the public.2
Subsequently, plaintiff filed an administrative complaint with the Rhode
Island Office of the Attorney General under § 42-46-8(a) against the BIPOC Board,
alleging that the Board was a public body that did not hold open meetings, in
violation of the OMA. 3 The school committee filed a response denying plaintiff’s
1 The record reveals that NSRI was paid $7,474 for the July 1, 2020, through June 30, 2021, fiscal year. This amount included $5,000 for the facilitation of twenty-five Board meetings and other services performed by NSRI unrelated to facilitation of the Board. 2 Wildman testified at her deposition that, in the preliminary stage of the Board’s formation, participation on the Board was open only to members of the community who identified as BIPOC. This effort was intended to facilitate a safe space for members to share personal stories about how the school district’s policies affected them. Wildman also testified that after the preliminary stage, membership on the Board would be open to the larger community. Wildman testified, however, that she rejected Solas’s requests to attend the meetings because of Solas’s persistent emails and social media remarks to Wildman demanding that the meetings be open to the public and requesting names of individual Board members. 3 General Laws 1956 § 42-46-8 provides a remedial cause of action for citizens or entities of the state who are aggrieved as a result of a public body operating in violation of the OMA.
-3- allegations. The school committee declared that the Board’s mission was “to
advocate for equity in the education of students who identify as [BIPOC] in South
Kingstown schools, inspiring a healthier and just community and school system for
everyone.” Additionally, the Board was to “review[] current [s]chool [c]ommittee
policies through the lens of inclusivity and equity. If the Board finds facts to lead it
to believe that the policy being reviewed does not meet these goals, they bring those
concerns to the School Committee Policy Sub-Committee.” The School Committee
Policy Sub-Committee (the policy sub-committee) would then meet to discuss and
vote on the Board’s policy proposals and submit said proposals to the school
committee for further review.
On May 10, 2022, the Attorney General notified plaintiff that the Board was
not a public body under the OMA. Consequently, plaintiff filed a complaint in
Superior Court pursuant to the OMA against the school committee. Thereafter,
plaintiff filed an amended complaint and moved for summary judgment, arguing that
the plain language of the OMA and this Court’s holding in Solas v. Emergency
Hiring Council of the State, 774 A.2d 820 (R.I. 2001), required that the Board be
subject to the OMA because, according to plaintiff, the Board possessed advisory
power over matters of significant public interest. The plaintiff sought declaratory
relief that any actions taken by the Board be deemed null and void. The school
committee responded with a cross-motion for summary judgment, arguing that the
-4- Board was not a public body under the OMA, citing to this Court’s holding in
Pontarelli v. Rhode Island Board Council on Elementary and Secondary Education,
151 A.3d 301 (R.I. 2016).
The hearing justice concluded that the school committee “did not evade its
own bylaws or state laws,” because the Board “[did] not possess any voting or veto
power to override the [s]chool [c]ommittee’s or the [p]olicy [s]ubcommittee’s
decision[s] * * *.” The hearing justice reasoned that there was a structured process
where the Board provided suggestions to the policy sub-committee for its review,
which was then subject to further review by the school committee. The hearing
justice determined that this framework “provide[d] the public two opportunities to
stay informed and voice concerns about the Board’s policy proposals * * *.”
Furthermore, the hearing justice found that, because there was a review process
where recommendations or suggestions made by the Board to the policy
sub-committee were not “blanketly adopted” by the school committee, “the Board
[wa]s analogous to the [Compensation Review Committee] in Pontarelli.” See
Pontarelli, 151 A.3d at 308. Accordingly, the hearing justice denied plaintiff’s
motion for summary judgment, and granted defendant’s cross-motion. Final
judgment in favor of defendant entered on October 23, 2024. The plaintiff filed a
timely notice of appeal.
-5- Standard of Review
“This Court reviews a decision granting a party’s motion for summary
judgment de novo.” Citizens Bank, N.A. v. Palermo, 247 A.3d 131, 133 (R.I. 2021)
(quoting Boudreau v. Automatic Temperature Controls, Inc., 212 A.3d 594, 598
(R.I. 2019)). “We assess the matter ‘from the vantage point of the trial justice,
viewing the evidence in the light most favorable to the nonmoving party, and if we
conclude that there are no genuine issues of material fact and that the moving party
is entitled to judgment as a matter of law, we will affirm.’” Felkner v. Rhode Island
College, 291 A.3d 1001, 1008 (R.I. 2023) (brackets and deletions omitted) (quoting
Citizens Bank, N.A., 247 A.3d at 133).
Additionally, “[a] Superior Court decision granting or denying declaratory
relief is reviewed with great deference by this Court.” LMG Rhode Island Holdings,
Inc. v. Office of McKee, 335 A.3d 444, 448 (R.I. 2025) (quoting Estrella v. Janney
Montgomery Scott LLC, 296 A.3d 97, 106 (R.I. 2023)). “When deciding an action
for declaratory judgment, a Superior Court justice makes all findings of fact without
a jury.” Id. (quoting Estrella, 296 A.3d at 106). “Such factual findings are afforded
great weight by this Court, and will not be disturbed absent a showing that the trial
justice overlooked or misconceived material evidence or was otherwise clearly
wrong.” Id. (quoting Estrella, 296 A.3d at 106). Nevertheless, “a trial justice’s
findings on ‘questions of law and statutory interpretation are reviewed de novo by
-6- this Court.’” Id. (quoting Westconnaug Recovery Company, LLC v. U.S. Bank
National Association as Trustee for ARMT 2007-2, 290 A.3d 364, 366 (R.I. 2023)).
Discussion
On appeal, plaintiff maintains that the Board is a public body, and thus its
meetings are mandated to be open to the public. The plaintiff argues that Solas is
controlling law because, according to plaintiff, the Board “meets all the criteria this
Court has set to determine whether an entity is a ‘public body’ under the OMA.”
The plaintiff contends that the Board is comparable to the Emergency Hiring Council
(EHC) in Solas. See Solas, 774 A.2d at 825. The plaintiff alleges that the Board was
created by the South Kingstown School Committee specifically to exercise
“advisory power,” which included making policy decisions on matters of significant
public interest. The plaintiff cites to this Court’s holding in Solas to assert that an
entity’s exercise of advisory power is sufficient to invoke the OMA and subject the
entity to its regulations.
In response, defendant argues that the Board is not a public body subject to
the OMA. The defendant contends that this Court’s holding in Pontarelli controls
because the Board operates as an “informal ad hoc working group,” distinguishable
from the EHC in Solas. The defendant avers that the Board is more akin to the
Compensation Review Committee (CRC) in Pontarelli. See Pontarelli, 151 A.3d at
301. The defendant asserts that, under the OMA, a public body must convene to
-7- discuss a matter over which the body has advisory power; defendant alleges that the
Board does not have such power. The defendant points to the hearing justice’s
finding that although the Board submitted proposals to the policy sub-committee,
the Board “did not possess veto or voting power to override” any of the policy sub-
committee or the school committee’s decisions. Likewise, that “any
recommendation or suggestion made by the Board to the Policy Subcommittee [was]
never blanketly adopted by the School Committee.”
The defendant further argues that for the Board to be properly subjected to the
regulations of the OMA, the Board must be a public body and its meetings must have
a quorum. Thus, according to defendant, the irregularity of the Board’s meetings
and membership combined with the ad hoc nature of the Board’s existence fail to
establish that the OMA is properly invoked.
Accordingly, the issue presented to this Court is whether the Board is a public
body within the meaning of the OMA, such that its meetings must be open to the
public pursuant to § 42-46-3. We answer this question in the negative.
This Court has stated that “[w]hen a municipality’s actions are challenged as
being violative of the Open Meetings Act, we are presented with ‘a mixed question
of law and fact.’” Anolik v. Zoning Board of Review of City of Newport, 64 A.3d
1171, 1174 (R.I. 2013) (quoting Tanner v. Town Council of Town of East Greenwich,
880 A.2d 784, 791 (R.I. 2005)). Accordingly, our examination of whether the
-8- Board’s meetings “violated the Open Meetings Act will be carried out in a de novo
manner with respect to the ‘application of the law to the facts.’” Id. at 1174 (quoting
Tanner, 880 A.2d at 791).
Additionally, “[i]n matters of statutory interpretation our ultimate goal is to
give effect to the purpose of the act as intended by the Legislature.” LMG Rhode
Island Holdings, Inc., 335 A.3d at 449 (quoting Sosa v. City of Woonsocket, 297
A.3d 120, 124 (R.I. 2023)). Therefore, “when the language of a statute is clear and
unambiguous, this Court must interpret the statute literally and must give the words
of the statute their plain and ordinary meanings.” Id. (quoting Sosa, 297 A.3d at 124).
Accordingly, “[w]hen interpreting a statute, this Court’s task is to ‘determine and
effectuate the General Assembly’s intent and attribute to the enactment the meaning
most consistent with its policies or obvious purposes.’” Cullen v. Lincoln Town
Council, 960 A.2d 246, 249 (R.I. 2008) (brackets omitted) (quoting Tanner, 880
A.2d at 796); see In re J.T., 252 A.3d 1276, 1280 (R.I. 2021).
The General Assembly enacted the Open Meetings Act “to ensure that ‘public
business be performed in an open and public manner and that the citizens be advised
of and aware of the performance of public officials and the deliberations and
decisions that go into the making of public policy.’” Cullen, 960 A.2d at 249
(quoting § 42-46-1). To effectuate its purpose, the act requires that “[e]very meeting
of all public bodies shall be open to the public unless closed pursuant to §§ 42-46-4
-9- and 42-46-5.” Section 42-46-3. Under the OMA, a public body is defined as “any
department, agency, commission, committee, board, council, bureau, or authority,
or any subdivision thereof, of state or municipal government * * * that funded at
least twenty-five percent (25%) of its operational budget in the prior budget year
with public funds * * *.” Section 42-46-2(5). Further, a meeting is “the convening
of a public body to discuss and/or act upon a matter over which the public body has
supervision, control, jurisdiction, or advisory power.” Section 42-46-2(1) (emphasis
added).
Indeed, this Court has established that “[a] literal reading of the act
demonstrates that all meetings to discuss or act upon matters over which the council
has supervision, control, or advisory power, are required to be open to the public.”
Solas, 774 A.2d at 825. Likewise, in Solas, this Court stated that “[w]hether
supervisory or advisory, both functions are regulated by the act. As the plain
language of the statute provides, a council’s exercise of advisory power is enough to
bring it under the act’s umbrella.” Id.
In Solas, the plaintiff requested to attend a meeting held by the EHC to
“consider the hiring of a hearing officer for the State Building Commission * * *.”4
Solas, 774 A.2d at 821. The EHC informed the plaintiff that he could not attend
4 We note that the plaintiff in Solas is not the same plaintiff in this case. See Solas v. Emergency Hiring Council of the State, 774 A.2d 820, 821 (R.I. 2001).
- 10 - because the meeting was closed to the public. Id. Subsequently, the plaintiff filed a
complaint in Superior Court seeking a declaration that the EHC was subject to and
governed by the OMA. Id. at 821-22. In rendering our decision, this Court
contemplated four primary considerations: (1) the EHC’s creation; (2) the
consistency of the EHC’s meetings; (3) the composition and selection of EHC
members; and (4) the EHC’s “advisory capacity with veto power over a subject of
significant public interest.” Id. at 823-24.
First, the Court noted that the EHC was created by executive order “to manage
and control the state’s hiring practices and its fiscal resources.” Solas, 774 A.2d at
823. Under the Governor’s instruction, “no new positions, vacant positions, or
promotions could be created or filled without authorization from the EHC.” Id.
Second, we considered that members of the EHC were “required to meet at least
biweekly[,]” demonstrating consistent and regularly scheduled meetings. Id. at 824.
Third, we noted that the EHC was “composed of a group of high level state
officials[5] that convene[d] to discuss and/or act upon matters of great interest to the
citizens of this state” (i.e., hiring state employees). Id. at 825. The EHC’s
membership of high-level public officials who received their positions by
5 Members of the EHC included “the director of the Department of Administration or a designee, a department director appointed by the Governor * * *, the governor’s executive counsel or a designee, the governor’s cabinet secretary, and the special assistant to the chief of staff for boards and commissions.” Solas, 774 A.2d at 824.
- 11 - appointment reinforced that the EHC was a public body. See id. Lastly, the Court
concluded that, because the EHC “possesse[d] significant supervisory and executive
veto power over creating or filling state employment positions[,] * * * [a]t the very
least the [EHC] function[ed] in an advisory capacity in state hirings.” Id.
By contrast, in Pontarelli, a plaintiff, employed as a hearing officer for the
Rhode Island Department of Elementary and Secondary Education (RIDE), alleged
that the RIDE and the Rhode Island Board Council on Elementary and Secondary
Education (the council) violated the OMA when they failed to provide the public
with adequate notice of CRC meetings, as required by the act. Pontarelli, 151 A.3d
at 302. This Court held that the CRC was not a “‘public body’ and, consequently,
[was] not subject to (nor was it in violation of) the OMA.” Id. at 308.
In analyzing many of the same factors contemplated in Solas, this Court
reasoned that, “[u]nlike the EHC in Solas, the CRC in this case d[id] not meet on a
regular basis, nor was the CRC created by an executive order.” Pontarelli, 151 A.3d
at 308; see Solas, 774 A.2d at 824. Rather, the CRC was created by the council “to
review requested and proposed salary adjustments for RIDE employees.” Pontarelli,
151 A.3d at 302-03. Likewise, “the CRC d[id] not have regular meetings; rather, it
schedule[d] meetings when a CRC member request[ed] one.” Id. at 303.
- 12 - Additionally, although this Court recognized that “the CRC was composed of
a group of high-level state officials[6] and operated under a charter,” we ultimately
determined that “these two factors alone [were] insufficient to place [the CRC] into
the ‘public body’ umbrella.” Pontarelli, 151 A.3d at 308. There, this Court noted
that CRC membership was not established by appointment, “instead, serving on the
CRC [was] just an additional task for people that [were] on the leadership team.” Id.
at 303 (internal quotation marks omitted). Although the CRC operated under a
charter, this Court determined that this factor was not sufficient to invoke the OMA.
Pontarelli, 151 A.3d at 308. Likewise, the CRC neither took nor kept written
meeting minutes. Id. at 303.
Notably, in Pontarelli, this Court pointed out that in Solas “the EHC’s
advisory power over the matter to be discussed at a meeting alone required that the
meeting be open to the public.” Pontarelli, 151 A.3d at 308. Conversely, we
determined that the CRC did not have such advisory power. Id. The CRC received
salary compensation recommendations from RIDE division chiefs, which the CRC
then submitted to the commissioner of RIDE. Id. at 303. It was then in the
commissioner’s discretion to present any of the CRC’s recommendations to the
6 “The CRC [wa]s composed of six RIDE employees: three division chiefs, the chief of staff, the human resources coordinator, and the deputy commissioner.” Pontarelli v. Rhode Island Board Council on Elementary and Secondary Education, 151 A.3d 301, 303 (R.I. 2016).
- 13 - council. Id. at 308. The Court reasoned that, because any recommendations made
by the CRC were subject to a review process, “the public would have [had] an
opportunity to be informed of and object to such proposal[s].” Id.
In the instant case, we conclude that the Board is an amorphous, ad hoc group
that is more akin to the CRC in Pontarelli; it is not a “public body” subject to the
OMA. See Pontarelli, 151 A.3d at 308; see also § 42-46-3. The Board was not a
subdivision of local government, but a sporadic group of volunteers created by the
South Kingstown School Committee. See Pontarelli, 151 A.3d at 302 (stating that
the CRC was created by the council); see also Solas, 774 A.2d at 823 (noting that
the EHC was created by the governor through an executive order). The school
committee contracted with NSRI to permit Wildman and Lewis to facilitate meetings
for members of the BIPOC community to discuss their personal experiences with
and concerns about inequity in the school district. It is evident that any rules
pertaining to the Board were created by the NSRI under its contract with the school
committee. Similarly, the Board did not operate under a charter or bylaws; the NSRI
and Board members made meeting agendas informally.
Additionally, the relaxed nature of the Board’s membership and meetings
evidence that it served as more of an advocacy or affinity group than a board with
“advisory capacity.” Contra Solas, 774 A.2d at 825. Board members were merely
volunteers from the community. They did not receive compensation, medical, or
- 14 - any other benefits, for their service on the Board. As the hearing justice iterated, the
school committee allocated funds to pay NSRI for its facilitation of Board meetings;
the funds were not used to compensate members for their participation. Moreover,
in her deposition, Wildman testified that she gathered people to attend the meetings
by “word of mouth.” Unlike the EHC in Solas, Board members were not appointed
by a subdivision of state or municipal government or elected by the public. See id.
at 824 (noting the “senior executive branch staff members” on the EHC). The record
shows that, in essence, initially anyone who identified as a member of the BIPOC
community and, later, the broader community, was welcome to attend the meetings
to participate on the Board.
It is clear from the record that the nature of the Board’s membership was
voluntary and that the Board did not have consistent membership. The record also
reveals that meetings occurred weekly for a period but that over time membership
reduced and was informal. Wildman attested that the Board’s membership started
with about fifteen members and that “[d]ue to the personal nature of the stories that
were shared, over time, the members began to call each other family.” After which,
the group’s attendance declined to seven or eight regular members. Similarly, an
active member of the Board, Mwangi Gitahi, testified that the Board “didn’t really
have a membership, like, the same number of people who would attend each
meeting. It just kind of depended on who was available and who could make it.”
- 15 - Indeed, the inconsistency of the Board’s membership leads us to conclude that the
Board could not meet a quorum requirement if its membership was indeterminable.
See § 42-46-2(6).
The plaintiff alleges that the Board possessed advisory power over matters of
significant public interest to the citizens of this state. We disagree. The school
committee specifically charged Wildman and Lewis with facilitating meetings for
members of the BIPOC community to “inspir[e] a healthier and just community and
school system for everyone.” Naturally, this directive permitted the Board to review
specific school policies and provide feedback to the policy sub-committee on how
those policies could be amended to influence a more progressive and inclusive
school district, but the Board itself had no ability to implement changes to school
policies.
Here, the proposal review system, like the CRC’s in Pontarelli, was a
dual-step procedure. See Pontarelli, 151 A.3d at 308. The Board would submit
policy suggestions, notably on anti-racist, anti-discrimination, and anti-harassment
policies to the policy sub-committee, to address issues that Board members and the
relevant community were facing in the school district. The policy sub-committee
would then either send the suggestions back to the Board for reconsideration or offer
the ideas to the school committee for further review. See Pontarelli, 151 A.3d at 308
(“[T]he CRC’s sole function [was] to advise the commissioner of RIDE, who in turn
- 16 - has to make a recommendation to the council.”). The policy sub-committee was not
obligated to accept the Board’s suggestions in whole or in part. The policy
sub-committee’s decision whether to forward the Board’s suggestions to the school
committee was entirely discretionary. Furthermore, both the policy sub-committee
and the school committee were public bodies subject to the OMA, and held open
meetings. See § 42-46-3. Accordingly, interested district members had an
opportunity to stay informed about the district’s policy determinations at both stages
of the process. See Pontarelli, 151 A.3d at 308 (“[I]f the commissioner decided to
present any proposal to the council for the council’s required approval, the public
would have an opportunity to be informed of and object to such proposal.”).
The plaintiff contends that the Board possessed “advisory power” because,
according to plaintiff, the school committee appointed at least two members of the
Board to the policy sub-committee, which did have voting and veto power. See
§ 42-46-2. Based on the record, that assertion is inaccurate. Indeed, the policy
sub-committee had voting power on proposals to school policies; however, the
school committee did not appoint any members of the Board to the policy
sub-committee. The record indicates that, after the Board’s creation, the school
committee reserved one seat on the policy sub-committee for a Board member. The
seat was designated so that a Board member could be present at policy
sub-committee meetings to discuss the proposed suggestions. After a successful
- 17 - petition by the Board, this number was increased to two. Nonetheless, the seats were
not established for a particular member of the Board; they were for any Board
member who was available and willing to attend the policy sub-committee meeting.
Contra Solas, 774 A.2d at 824 (noting that the EHC was composed of members
appointed by the Governor). Consequently, anyone who volunteered to be a
representative occupied the reserved seat. Moreover, no Board members were
members of the school committee. Accordingly, the fact that the school committee
reserved two spots for Board representation on the policy sub-committee does not
advance plaintiff’s argument because members of the public had access to the policy
sub-committee and the school committee meetings, both of which were open to the
public. See Pontarelli, 151 A.3d at 308 (stating that council meetings were open to
the public when it deliberated salary adjustments proposed by the CRC). Therefore,
we discern no error in the hearing justice’s determination.
Finally, plaintiff avers that the hearing justice’s decision circumvents the
policy behind the OMA, which mandates transparency for matters of significant
public interest, and permits the school committee to use third-party vendors to evade
the statute. The plaintiff contends that Solas requires a broad interpretation of §
42-46-1, in favor of meetings being public, and that the hearing justice’s
interpretation improperly narrows its reach. Section 42-46-1; see Solas, 774 A.2d at
- 18 - 825. Indeed, this Court has stated that the statute requires a broad interpretation,7
however, the Board does not convene on matters over which it has veto power or
advisory capacity. See Solas, 774 A.2d at 824. The Board was not comprised of
public officials who formally convened to make deliberations and decisions on
public policy, such that adherence to the statute was required. Contra id. (“The EHC
combines senior executive branch staff members with employees for assistance with
the functions and objectives set forth in both executive orders * * *. It is clear that
the council has been granted significant influence and veto power over creating
positions in state government * * *.”).
It is clear that that the Board was a sporadic, ad hoc group of community
members who volunteered to meet to share their experiences and make suggestions
about how to create a more inclusive school community. Upon receipt of Board
suggestions, the policy sub-committee would deliberate and advise the school
committee on what, if any, changes might be implemented. Certainly, Solas had the
opportunity to attend policy sub-committee and school committee meetings to learn
of or object to such changes. Accordingly, the hearing justice was correct in his
7 “[J]urisdictions have enacted open meeting or ‘sunshine’ laws for the public interest to protect the public from ‘closed door’ politics; and, as such, these enactments should be broadly construed and interpreted in the light most favorable to public access to achieve their remedial and protective purpose.” Solas, 774 A.2d at 824.
- 19 - determination that the Board is not a public body subject to the open meetings
requirement of the OMA.
Conclusion
For the reasons stated herein, the Superior Court judgment is affirmed. The
papers may be remanded thereto.
Justice Goldberg participated in the decision but retired prior to its
publication.
- 20 - STATE OF RHODE ISLAND SUPREME COURT – CLERK’S OFFICE Licht Judicial Complex 250 Benefit Street Providence, RI 02903
OPINION COVER SHEET
Title of Case Nicole Solas v. South Kingstown School Committee.
No. 2025-6-Appeal. Case Number (PC 22-4727)
Date Opinion Filed May 29, 2026
Suttell, C.J., Goldberg, Robinson, Lynch Prata, and Justices Long, JJ.
Written By Associate Justice Erin Lynch Prata
Source of Appeal Providence County Superior Court
Judicial Officer from Lower Court Associate Justice Christopher K. Smith
For Plaintiff:
Jonathan Riches, Esq. Attorney(s) on Appeal For Defendant:
Deidre E. Carreno, Esq.
SU-CMS-02A (revised November 2022)