Cardinale v. City of Atlanta, 290 Ga. 521

Cardinale, pro se, sued the City of Atlanta, the Council, and Municipal Clerk alleging Open Meetings Act violations.
The February 2010 City Council retreat minutes omitted names of those voting against or abstaining in a non-roll-call vote.
The Chair of the Committee on Council polled members; 7 voted to amend, 8 voted to maintain; minutes stated only a general denial of amendment.
Cardinale sought declaratory and injunctive relief and penalties under OCGA § 50-14-6.
The trial court dismissed the criminal-charge claim; the Court of Appeals affirmed; the Supreme Court granted certiorari.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether non-roll-call voting requires listing opposing or abstaining votes	Cardinale: names must be recorded for non-roll-call votes	City: no mandatory listing; presumption of unanimity unless listed	Yes, minutes must list names of those voting against or abstaining in non-roll-call votes
Whether the criminal penalties claim was properly dismissed	Cardinale seeks misdemeanors and fines under OCGA § 50-14-6	Private citizen lacks standing to prosecute; criminal claim properly dismissed	Dismissed the criminal liability portion; declaratory/injunctive claims remain

Chase v. State, 285 Ga. 693 (Ga. 2009) (plain-language interpretation when unambiguous)
EarthResources, LLC v. Morgan County, 281 Ga. 396 (Ga. 2006) (remedial public-records construction favored)
Red & Black Pub. Co., Inc. v. Board of Regents, 262 Ga. 848 (Ga. 1993) (public-access aims of open-government)
Atlanta Journal v. Hill, 257 Ga. 398 (Ga. 1987) (transparency goals of the Open Records/Open Meetings acts)
Slakman v. Continental Cas. Co., 277 Ga. 189 (Ga. 2003) (avoid surplusage; plain-terms construction)
Flint River Mills v. Henry, 239 Ga. 347 (Ga. 1977) (legislative authority to create presumptions)
Stendahl v. Cobb County, 284 Ga. 525 (Ga. 2008) (standards for dismissal and construction of pleadings)