White v. King, 2014 Ohio 3896

White and King served on the Olentangy Local School District Board of Education along with Feasel, O'Brien, and Dunbar.
In March 2012, White began an independent investigation into expenditures by two athletic directors, leading to resignations and reimbursements.
On Sept. 25, 2012, the Board amended Policy 0148.1(B) to require communications through the Superintendent or Treasurer; White voted against the amendment.
On Oct. 11, 2012, a Columbus Dispatch editorial criticized similar restrictions and highlighted White's vote against the policy.
Between Oct. and Oct. 2012, King drafted a public response; the final letter (Oct. 13, published Oct. 27, 2012) was signed by King with the other four members’ consent, but White was not consulted.
On Apr. 25, 2013, White filed a R.C. 121.22 Open Meetings claim; the Board ratified the response at a board meeting the same day; the trial court later granted judgment on the pleadings for the Board.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly granted judgment on the pleadings regarding the Open Meetings claim.	White argues the court should liberally construe the Open Meetings Statute to the facts.	King/Board contends no pre-arranged meeting or majority deliberation occurred under the statute.	No error; statute not violated under the given facts.

Moraine v. Montgomery County Bd. of Commissioners, 67 Ohio St.2d 139 (Ohio St. 2d 1981) (Sunshine Law requires deliberations in public; pre-arranged meeting standard)
Haverkos v. Northwest Local Sch. Dist. Bd. of Edn., 995 N.E.2d 862 (1st Dist. Hamilton No. C-040578, C-040589 (2005)) (emails/limited discussions not per se meetings; pre-arranged discussion not shown)