Moon v. Terrell County

Smith, Presiding Judge,

concurring specially.

I fully concur with all that is said in the majority opinion. I write separately to note an issue that may arise from a strict or literal construction of OCGA § 50-14-3 (6). Under that subsection, a meeting is exempted from the provisions of the Open Meetings Act if discussions or deliberations occur concerning disciplinary action of a public officer or employee. If evidence is received, however, the meeting is not exempted.

Here, the board of commissioners acted on the basis of the letter from the Georgia Department of Corrections, County Facilities Division (DOC), which was considered during the closed portion of the meeting. Clearly, the letter was evidence, and strictly construing the Open Meetings Act, as we are required to do, we must conclude that an open meeting was necessary under OCGA § 50-14-3 (6). But a different result may have been warranted if the board members had simply discussed reasons for Moon’s dismissal. Those reasons might have included, for example, a conversation between one of the board members and a DOC representative, without use of or reference to the letter from the DOC. Under a literal interpretation of the statute, a closed meeting in those circumstances may have been authorized. I question whether such a meeting, where simple hearsay may have served as a basis for dismissal, would have afforded Moon or any aggrieved member of the public the safeguards afforded by the Open Meetings Act.