Board of Education of Springfield School District No. 186 v. Attorney General, 2017 IL 120343

Springfield School District Board negotiated a separation agreement with Superintendent Dr. Walter Milton Jr., signing versions in closed sessions (Milton dated 1/31/13; six board members signed undated on 2/4/13).
The Board posted the March 5, 2013 agenda online (four days before the meeting) with a link to the separation agreement and a resolution calling for approval of the separation agreement between Dr. Milton and the Board.
At the March 5 public meeting the Board president read the resolution aloud (identifying the agreement and the parties), discussion occurred, and the Board voted 6–1 to approve; the agreement was then dated March 5, 2013.
A reporter complained to the Attorney General alleging Open Meetings Act violations (final action in closed session; inadequate public recital at open meeting; failures to keep closed-session recordings and minutes summaries).
The Attorney General issued binding opinions finding multiple violations, including that the March 5 recital was insufficient because it did not verbally disclose key terms or the significance of the agreement.
The circuit court and the appellate court reversed the Attorney General on the public-recital issue; the Supreme Court affirmed, holding the open-meeting recital was sufficient and that section 2(e) does not require an explanation of significance or detailed terms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether section 2(e) of the Open Meetings Act requires a verbal explanation of the significance or terms of an action at the open meeting	AG: recital must state the nature and "other information" sufficient to ensure attendees understand the significance/terms (reasonable-person/key-terms standard)	Board: statute requires stating the nature; requiring explanation/key-terms is impractical and not in text	Held: section 2(e) requires a public recital at the open meeting of the nature/identity of the matter and enough detail to identify the transaction, but not an explanation of terms or significance; no deference to AG on this plain meaning
Whether the Board’s March 5, 2013 public recital satisfied section 2(e) so that the subsequent vote was valid	AG: recital was vague; posting the agenda earlier does not cure an inadequate in‑meeting recital	Board: president read the resolution identifying the agreement and parties; prior posting and resolution reading suffice to inform public	Held: recital was sufficient—announced nature (separation agreement) and identified parties (Dr. Milton and the Board); vote valid; no need to read contract or enumerate key terms

Grissom v. Board of Education of Buckley-Loda Community School District No. 8, 75 Ill. 2d 314 (Illinois Supreme Court) (Open Meetings Act does not prohibit preparing signed findings in closed session followed by public vote)
Jewell v. Board of Education, Du Quoin Community Unit Schools, District No. 300, 19 Ill. App. 3d 1091 (Ill. App. Ct.) (no violation where board agreed in closed session and then returned to open session and recorded votes)
AFM Messenger Service, Inc. v. Department of Employment Security, 198 Ill. 2d 380 (Illinois Supreme Court) (standards for reviewing mixed questions of fact and law; clearly erroneous review)
People v. Collins, 214 Ill. 2d 206 (Illinois Supreme Court) (statutory interpretation principles; apply plain meaning when language clear)
Hadley v. Illinois Department of Corrections, 224 Ill. 2d 365 (Illinois Supreme Court) (agency interpretations not binding when statute plain)