Hitt v. Mabry

CADENA, Chief Justice,

dissenting.

The injunction is too broad, even as modified by the majority opinion, and goes beyond the relief prayed for by plaintiffs.

Insofar as the Open Meetings Act is concerned, the petition alleges that two defendants, Elizondo, President of the Board of Trustees, Cisneros, Secretary of the Board, and Board members Ward and Lopez “have engaged in a continuous and repetitive pattern of illegal informal telephone polls ... to conduct” School District Business. The petition further alleges that such informal telephone polls “discuss public issues and result in meetings that had not been properly noticed with date, time, place and subject matter,” and that the continued use of such polls is a “conspiracy to circumvent the provisions of the Act by meeting in numbers less than a quorum for the purpose of secret deliberations.”

In the prayer plaintiff sought to permanently enjoin Elizondo and Cisneros and “their agents, employees, servants or attorneys from using telephone surveys or polls to conduct any business ...” of the School District. This is the only prayer for injunc-tive relief which can be said to have even a remote connection with the provisions of the Open Meetings Act.

The majority opinion correctly points out that one seeking injunctive relief must be specific in pleading the relief sought, and that a trial court has no authority to grant relief beyond that so specified. It is true, of course, that injunctions, to give effective relief should be broad enough to prevent a repetition of the evil sought to be corrected.

Even the most liberal interpretation of the pleadings reveals that the specific relief sought was an injunction preventing Eli-zondo and Cisneros, as well as their agents, employees, servants or attorneys “from using telephone surveys or polls to conduct school district business.”

The injunction, as modified by this court, does not expressly grant the only relief sought, since it does not mention telephone polls or surveys. It can be conceded that the injunction which this court would issue, by requiring the giving of proper notices, requiring that all meetings be open to the public and requiring the announcement at an open meeting of the topics to be discussed in executive session, effectively prevents the use of informal telephone surveys or polls. But it is clear that the issuance of such an injunction goes far beyond the prayer for injunctive relief in *798that it is not restricted to the use of telephone surveys and polls.

There is another difficulty with the injunction as modified. Plaintiffs alleged that the use of telephone polls was a conspiracy to circumvent the provisions of the Open Meeting Act, but it is not a violation of § 2, which requires that every meeting of a government body shall, with some exceptions not here relevant, be open to the public. According to § 1(a), the word “meeting” means “and deliberation between a quorum of members of a governmental body at which any public business or public policy over which the governmental body has supervision or control is discussed or considered, or at which any formal action is taken.” As applicable to this case, the “governmental body” which is required to meet publicly is the Board of Trustees, and the requirement that meetings of that body be public applies only when a quorum is present, since in the absence of a quorum there is no “meeting.” Notice of deliberations is required only where the deliberation involves a quorum. Plaintiffs’ pleadings do not allege that “meeting” as defined in § 1, were held without being open to the public following proper notice.

The injunction also restrains members of the Board who are not accused of violations of the Open Meetings Act in plaintiffs’ pleadings and who are not named as defendants. The only members of the Board who are named as defendants are Elizondo and Cisneros. The trial court, in its judgment, speaks only of violations by “defendants.” Yet the injunction is made applicable to all members of the Board, including even the Board member who is plaintiff in the case.

The petition names the superintendent and superintendent-elect, “the San Antonio Independent School District its Agents, Employees, Servants and Attorneys” as defendants, in addition to Elizondo and Cisne-ros. The injunction also purports to bind such other defendants who are not members of the Board of Trustees.

It is patent that the Open Meetings Act does not apply to the superintendent, superintendent-elect or other members of the staff of the school district, nor does it apply to the school district itself. The prohibition against secret meeting applies only to meetings of the “governmental body,” that is, the Board of Trustees. Neither the superintendent, the superintendent-elect or other members of the staff can, under any circumstances, hold a meeting involving “a quorum of members” of the governmental body. Staff meetings are beyond the reach of the statute. The provisions for injunction and mandamus found in § 3 are expressly designed to prevent “violations or threatened violations of this Act by members of a governing body.” The penalties provided in § 4(a) apply only to

any member of a governing body who willfully calls or aids in calling or organizing a special or called meeting or session which is closed to the public, or who willfully closes or aids in closing a regular, special or called meeting or session which is closed to the public where a closed meeting is not permitted by the provisions of this Act, shall be guilty of a misdemeanor ...

Similarly, § 4(b), which makes it a misdemeanor to conspire to circumvent the provisions of the statute by meeting in numbers less than a quorum is applicable only to “any member of group of members of a governing body.” The Legislature, at least, recognized that the statute imposed duties only on governing bodies and their members, that only governing bodies or their members could violate the statute, and that actions by persons who are not members of the governing or governmental body cannot violate the provisions of the statute. It is idle to attempt to enjoin violations of a statute by persons who, no matter what actions they take or fail to take, cannot be guilty of violating the statute.

Rule 683, which provides that an injunction shall be binding on the “parties ... their officers, agents, employees and attorneys” is completely irrelevant here. It cannot be seriously argued that the Rule *799broadens the statutory prohibitions or imposes duties not imposed by the statute. In the ordinary case, if the injunction is to protect the aggrieved person effectively, it may be necessary to make the injunction binding on the agents, etc. of the parties, since the acts of the representatives of the parties may violate the rights of the complainant as effectively as the acts of their principals or superiors who are parties to the injunction case. Further, in such cases the act of the subordinate is viewed as the act of his principal. In the case before us, the act of, say, the superintendent is not the act of the governmental body nor of any member of that body. No matter how earnestly the representative of the school district attempt to do that which the statute prohibits, their actions cannot result in a violation of the statute.

It should also be pointed out that, as alleged in plaintiffs pleadings, the persons sought to be enjoined, other than Elizondo and Cisneros, are employees, etc., of the school district. They are not employees of the Board of Trustees or of any member of that Board.

The point finds illustration, for example, in that portion of the injunction, as modified by the majority opinion, which enjoins the agents, etc., of the “defendants” from “Failing to announce at an open meeting of the SAISD Board the topic(s) to be discussed at a closed or executive session, as required in § 2(a).” The relevant provision of § 2(a) prohibits closed meetings “unless the governmental body has first been convened in open meeting ... for which notice has been given ... and during which open meeting or session the presiding officer has publicly announced that a closed or executive session.” It is, of course, impossible for even the superintendent to comply with the requirements of § 2(a). Since the duty is imposed only on the presiding officer, no representative of the District other than the presiding officer of the governmental body can make the required announcement, and the absence of the required announcement is not a failure of, say, the superintendent to make any announcement which he is required to make.

I know of no considerations which can justify the action of a court in requiring, under threat of contempt proceedings, a person to do that which no rule of law requires him to do, or to refrain from doing that which he is not forbidden to do by any known rule of law.