State Ex Rel. Krueger v. Appleton Area School District Board of Education, 2017 WI 70

Appleton Area School District Board adopted Rule 361 and an ACI Handbook delegating selection/review of educational materials to the ACI Department and prescribing a review-committee process.
The Handbook contemplates six-year cyclical curriculum reviews by review committees with defined membership and duties to identify materials and make formal recommendations to the Board.
Parent John Krueger requested an alternative Communications Arts 1 course; district officials formed the Communication Arts 1 Materials Review Committee (CAMRC) using a modified Handbook review process focused on the course book list.
CAMRC consisted of 17 members, met multiple times, identified and vetted books, solicited public input, voted on a recommended book list, and presented recommendations to the Board, which approved them.
Krueger was denied access to CAMRC meetings and sued under Wisconsin's open meetings law, alleging CAMRC violated the law; lower courts granted summary judgment to the District and CAMRC, and the court of appeals affirmed.
The Wisconsin Supreme Court reversed, holding CAMRC was a "governmental body" created by rule (Rule 361 + Handbook) and therefore subject to the open meetings law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CAMRC was a "governmental body" under Wis. Stat. § 19.82(1) (i.e., a committee "created by constitution, statute, ordinance, rule or order")	Krueger: CAMRC was formed pursuant to Board Rule 361 and the Board‑approved Handbook; those rules authorized and conferred collective authority on review committees, so CAMRC was a committee "created by ... rule" and thus subject to open meetings law.	Board/CAMRC: CAMRC was an ad hoc group formed by ACI officials in response to a parent request, not created by the Board by rule or order; Rule 361/Handbook did not specifically create CAMRC, so the open meetings law does not apply.	The Court held CAMRC was a committee with defined membership and collective authority formed pursuant to the Board's Rule 361 and Handbook; therefore it was a "governmental body" created by rule and subject to the open meetings law.

State ex rel. Newspapers, Inc. v. Showers, 135 Wis. 2d 77, 398 N.W.2d 154 (Wis. 1987) (ad hoc gatherings not covered absent creation/collective power)
State ex rel. Lynch v. Conta, 71 Wis. 2d 662, 239 N.W.2d 313 (Wis. 1976) (collective power conferral is necessary to constitute a governmental body)
State ex rel. Kalal v. Circuit Court for Dane County, 271 Wis. 2d 633, 681 N.W.2d 110 (Wis. 2004) (statutory interpretation principles)
Journal Times v. City of Racine Bd. of Police & Fire Comm'rs, 362 Wis. 2d 577, 866 N.W.2d 563 (Wis. 2015) (standards for open meetings claims and review)