We granted leave in this case to determine whether the presidential selection procedure utilized by defendant violated the Open Meetings Act (oma), MCL 15.261 et seq.-, MSA 4.1800(11) et seq., and whether application of the OMA to committees formed by the governing boards of our public universities to assist in the selection of university presidents is constitutional. As an initial matter, while we would customarily begin our analysis with a discussion of whether the OMA was violated by the conduct of the board of trustees,1 we are bypassing that question and moving directly to the constitutional question because the OMA cannot be a restraint upon the actions of defendant in this circumstance. As explained below, we hold that the Legislature does not have power to regulate open meetings for defendant in the context of presidential searches at all, i.e., the Legislature is institutionally unable to craft an open meetings act that would not, in the context of a presidential selection committee, unconstitutionally infringe the governing board’s power to supervise the institution. We therefore reverse the Court of Appeals decision and reinstate the trial court’s order granting summary disposition for defendant.
i
John DiBiaggio resigned as president of Michigan State University during the summer of 1992. Defendant appointed Gordon Guyer interim president and thereafter formed a presidential search committee (PSC), consisting of the eight university trustees and *79nine additional members, to assist it in selecting a new president. The psc developed a statement of qualifications and proceeded to identify potential candidates to meet its charge of recommending final candidates to defendant by July 1, 1993.2 The search process, however, ground to a halt when the msu student *80newspaper, the State News, published a confidential list of over one hundred nominees under consideration for the presidency. In response, defendant reconstituted the PSC to consist of four trustees and the nine nontrustee members. The PSC then continued its search in private.
The PSC gathered and reviewed information regarding the candidates, eventually selecting fifteen to interview. After completing the interviews, the PSC recommended four candidates to defendant. Defendant released the names of these candidates to the public. One candidate eventually withdrew, and defendant publicly interviewed the others. Two candidates withdrew after their interviews. Defendant considered the remaining candidate at a July 27, 1993, meeting, but the trustees were evenly divided regarding her candidacy.
Unable to reach a decision to elect the sole remaining candidate, defendant requested that the PSC reconvene and recommend additional candidates. The PSC declined to recommend other candidates. Defendant’s chairman then contacted M. Peter McPherson, a candidate who had withdrawn his name from consideration after his interview with the PSC, and urged him to reinstate his candidacy. McPherson agreed. Defendant publicly interviewed him on August 17, 1993, and subsequently elected him president.
*81Plaintiffs commenced this action shortly after defendant reconstituted the psc, but the trial court denied their motion for a preliminary injunction.3 The parties continued discovery after the conclusion of the search and eventually filed cross-motions for summary disposition. The trial court granted defendant’s motion and denied plaintiffs’ motion, concluding that the psc was not a public body subject to the OMA, that application of the oma to the presidential search is unconstitutional, and that defendant did not unlawfully delegate its constitutional authority. The Court of Appeals reversed.4
The Court of Appeals reasoned that, although courts have held that Michigan public universities are distinct governmental bodies, coequal with the Legislature, they are not constitutionally immune from all regulation by the Legislature. The Court then concluded that the policy of promoting openness in government that underlies the oma supported application of the act to state universities:
The longstanding public policy of this state to open the acts of governmental officials to public scrutiny supports the conclusion that the oma can be constitutionally applied to universities. The oma is not aimed at any activities peculiar to the university and does not attempt to change or disturb its educational activities. In fact, the effect of the oma with respect to public universities is minimal. Although it requires that much of the process of selecting a university president be done in public, it does not tell the board what *82the criteria should be for that selection, how to select a candidate, or whom to select as president. It merely requires that, when interviewing candidates and when making a detailed review of applications of candidates who do not request confidentiality, the university function in public meetings. It does not divest the board of its authority to select a president. [221 Mich App 103, 112; 561 NW2d 433 (1997).]
The Court of Appeals also determined that the psc violated the OMA during its search process. The Court reasoned that the PSC was a “public body” for purposes of the OMA because defendant empowered it by resolution to exercise portions of defendant’s governmental authority in selecting a president. The Court determined that the psc violated the oma “when it took steps to reduce the number of candidates in private session, when it reviewed applications of persons not requesting confidentiality, and when it interviewed applicants in private.” Id. at 119. Finally, the Court rejected plaintiffs’ argument that defendant unlawfully delegated its constitutional authority to select a president because defendant, while giving the psc more than ministerial duties, retained its ultimate authority. 5
This Court granted defendant’s application for leave to appeal.6
n
We address today the constitutional question left open by Booth Newspapers, Inc v Univ of Michigan Bd of Regents, 444 Mich 211, 235-236; 507 NW2d 422 *83(1993),7 and conclude that application of the oma to committees formed by governing boards of public universities to assist in the selection of university presidents is unconstitutional.
A
The Michigan Constitution is a limitation on the Legislature’s power, not a grant of power to it. Advisory Opinion on Constitutionality of 1976 PA 240, 400 Mich 311, 317-318; 254 NW2d 544 (1977). As this Court explained in In re Brewster Street Housing Site, 291 Mich 313, 332-333; 289 NW 493 (1939):
By the Declaration of Independence, all political connection between the colonies and the State of Great Britain was declared to be dissolved and the colonies asserted to be free and independent States. The several States, when organized, succeeded to all of the legislative powers within their respective territorial jurisdictions possessed by the Parliament of England, and as such free and independent States they still possess those powers, except insofar as they have been delegated by the States to the Federal government by the Constitution of the United States or voluntarily restrained by the people through the Constitution of the State.
Thus, absent a constitutional limitation, the Legislature has the power to legislate within a particular field. See Advisory Opinion 1976 PA 240, supra at 318; Oakland Co Taxpayers’ League v Oakland Co Supervisors, 355 Mich 305, 323; 94 NW2d 875 (1959); Brewster Street, supra at 333. In this case, we revisit *84the question of the scope of the Legislature’s power to regulate public universities.
B
The Michigan Constitution confers a unique constitutional status on our public universities and their governing boards.8 Const 1963, art 8, §§ 5, 6. Const 1963, art 8, § 5 grants defendant broad authority over Michigan State University, including the power to elect the president of the university:
[T]he trustees of Michigan State University and their successors in office shall constitute a body corporate known as the Board of Trustees of Michigan State University .... Each board shall have general supervision of its institution and the control and direction of all expenditures from the institution’s funds. Each board shall, as often as necessary, elect a president of the institution under its supervision. He shall be the principal executive officer of the institution, be ex-officio a member of the board without the right to vote and preside at meetings of the board.
Const 1963, art 8, § 4, however, restricts the board’s power to dictate its procedure, directing that “[fjormal sessions of governing boards of such institutions shall be open to the public.”
In construing provisions of our constitution, the primary rule is that of “common understanding.” Council of Organizations & Others for Education About Parochiaid, Inc v Governor, 455 Mich 557, 569; *85566 NW2d 208 (1997). In Traverse City School Dist v Attorney General, 384 Mich 390, 405; 185 NW2d 9 (1971), this Court embraced Justice Cooley’s explanation of this principle in his treatise, 1 Cooley, Constitutional Limitations (6th ed), p 81:
A constitution is made for the people and by the people. The interpretation that should be given it is that which reasonable minds, the great mass of the people themselves, would give it. “For as the Constitution does not derive its force from the convention which framed, but from the people who ratified it, the intent to be arrived at is that of the people, and it is not to be supposed that they have looked for any dark or abstruse meaning in the words employed, but rather that they have accepted them in the sense most obvious to the common understanding, and ratified the instrument in the belief that that was the sense designed to be conveyed.” (Emphasis added.)
To clarify meaning, we often consider the circumstances surrounding the adoption of the provision and the purpose it is designed to accomplish. Bolt v City of Lansing, 459 Mich 152, 160; 587 NW2d 264 (1998). Thus, we turn to the historical origins of Const 1963, art 8, §§ 4, 5 to discern the limits they place on the Legislature’s power to regulate our public universities.
c
Long ago, the Legislature controlled and managed our first public university, the University of Michigan. Const 1835, art 10, § 5; see Regents of the Univ of Michigan v Michigan, 395 Mich 52, 63; 235 NW2d 1 (1975). This experiment failed, prompting extensive debate regarding the future of the university at the Constitutional Convention of 1850. Sterling v Regents of Univ of Michigan, 110 Mich 369, 374-378; 68 NW *86253 (1896). Const 1850, art 13, § 8 emerged from these debates, divesting the Legislature of its power to regulate the university and placing control in an elected board. Id. at 377-380. The provision granted the board “the general supervision of the university, and the direction and control of all expenditures . . . .” The Constitution of 1850 also granted the board the power to elect a president of the university. Id.
The University of Michigan thrived under the leadership of its board of regents. Sterling, supra at 377. Recognizing the importance of an independent governing board in managing state colleges and universities, Const 1908, art 11, §§ 7, 8 vested control of the then-named Michigan Agricultural College in the State Board of Agriculture.9 State Bd of Agriculture v Auditor General, 226 Mich 417, 424; 197 NW 160 (1924); State Bd of Agriculture v Auditor General, 180 Mich 349, 359; 147 NW 529 (1914); Bauer v State Bd of Agriculture, 164 Mich 415; 129 NW 713 (1911). Const 1963, art 8, § 5 combined the separate provisions of the Constitution of 1908 into one provision, granting the respective governing bodies control over the University of Michigan, Michigan State University, and Wayne State University.10 The current provision draws its language from Const 1850, art 13, § 8.
This Court has long recognized that Const 1963, art 8, § 5 and the analogous provisions of our previous *87constitutions limit the Legislature’s power.11 “[T]he Legislature may not interfere with the management and control of” universities. Regents, supra at 395 Mich 65. The constitution grants the governing boards authority over “the absolute management of the University, and the exclusive control of all funds received for its use.” Bd of Agriculture, supra at 226 Mich 424. This Court has “jealously guarded” these powers from legislative interference. Bd of Control of Eastern Michigan Univ v Labor Mediation Bd, 384 Mich 561, 565; 184 NW2d 921 (1971).
This Court has not, however, held that universities are exempt from all regulation. In Regents of the Univ of Michigan v Employment Relations Comm, 389 Mich 96, 108; 204 NW2d 218 (1973), we quoted Branum v Bd of Regents of the Univ of Michigan, 5 Mich App 134, 138-139; 145 NW2d 860 (1966):
It is the opinion of this Court that the legislature can validly exercise its police power for the welfare of the people of this State, and a constitutional corporation such as the board of regents of the University of Michigan can lawfully be affected thereby. The University of Michigan is an independent branch of the government of the State of Michigan, but it is not an island. Within the confínes of the operation and the allocation of funds of the University, it is supreme. Without those confines, however, there is no reason to allow the regents to use their independence to thwart the clearly established public policy of the people of Michigan.
Legislative regulation that clearly infringes on the university’s educational or financial autonomy must, therefore, yield to the university’s constitutional power. Thus, although a university is subject to the *88public employees relations act, MCL 423.201 et seq.) MSA 17.455(1) et seq., the regulation cannot extend into the university’s sphere of educational authority:
Because of the unique nature of the University of Michigan . . . the scope of bargaining by [an association of interns, residents, and post-doctoral fellows] may be limited if the subject matter falls clearly within the educational sphere. Some conditions of employment may not be subject to collective bargaining because those particular facets of employment would interfere with the autonomy of the Regents. [Regents, supra at 389 Mich 109.]
See also Central Michigan Univ Faculty Ass’n v Central Michigan Univ, 404 Mich 268, 281-283; 273 NW2d 21 (1978). Similarly, although the Legislature may attach conditions to an appropriation, the conditions cannot invade university autonomy. Bd of Agriculture, supra at 226 Mich 425.
D
In this case, we do not consider a generally applicable law that implicates university financial autonomy. Rather, we consider a law that dictates the manner in which the university operates on a day-to-day basis. The authority of the governing board is derived from Const 1963, art 8, § 5, which states in pertinent part:
Each board shall have general supervision of its institution .... Each board shall, as often as necessary, elect a president of the institution under its supervision.
We hold that the application of the OMA to the internal operations of the university in selecting a president infringes on defendant’s constitutional power to supervise the institution. Const 1963, art 8, § 5.
*89Although a university is not a separate branch of government, our decision in In re 1976 PA 267, 400 Mich 660; 255 NW2d 635 (1977), is instructive. In that case, this Court held in a rare advisory opinion that the proposed OMA provision applying the act to this Court during its exercise of rulemaking authority and deliberations regarding administrative orders was unconstitutional:
The judicial powers derived from the Constitution include rulemaking, supervisory and other administrative powers as well as traditional adjudicative ones. They have been exclusively entrusted to the judiciary by the Constitution and may not be diminished, exercised by, nor interfered with by the other branches of government without constitutional authorization. See Attorney General ex rel Cook v O’Neill, 280 Mich 649; 247 NW 445 (1937). It is our opinion that 1976 PA 267 is an impermissible intrusion into the most basic day-to-day exercise of the constitutionally derived judicial powers. [Id. at 663.]
Given the constitutional authority to supervise the institution generally, application of the oma to the governing boards of our public universities is likewise beyond the realm of legislative authority. Const 1963, art 8, § 5.
That the oma cannot constitutionally be applied to the defendant’s presidential search committee is supported by the language of Const 1963, art 8, § 4.12 The *90delegates to the Constitutional Convention of 1961 recognized that the decision whether to open meetings of university governing boards to the public lay within the boards’ sphere of authority. Const 1963, art 8, § 4 restricted the boards’ authority by requiring that “[formal sessions of governing boards of such universities shall be open to the public.” The author of the provision explained its purpose:
Meetings of governing boards of the 3 major universities have been open to the public and news media for the past V2 dozen years and that has been accomplished only after a long period of negotiations. As it stands, the public and news media are present only as a matter of sufferance. They are invited guests of the governing board, an invitation which could be, conceivably, withdrawn at any time. . . . [N]ow that we are creating by constitutional enactment 7 more such governing boards, it would be appropriate that their formal meetings should be conducted in public sessions. [1 Official Record, Constitutional Convention 1961, p 1187.]
That the provision is limited to “formal sessions,” rather than all sessions, signifies that the governing boards retain their power to decide whether to hold “informal” sessions in public. Const 1963, art 8, § 5, prohibits the Legislature from intruding in this basic day-to-day exercise of the boards’ constitutional power. Nor can application of the OMA rest on the absence of a definition of “formal sessions” in the constitution. Unlike other provisions of the constitution, the Legislature is not delegated the task of defining the phrase “formal sessions” for purposes of Const 1963, art 8, § 4.13
*91The meetings of the PSC clearly were not “formal” sessions of defendant under the common understanding of that term.14 Only four trustees were members of the psc and participated in that phase of the presidential search. Under Const 1963, art 8, § 5, the governing board of the university, not the Legislature, has the power to open the meetings of a presidential search committee such as the instant one to the public. Application of the OMA to the PSC is simply an impermissible intrusion on defendant’s constitutional authority to supervise the institution.15
*92Under Const 1963, art 8, § 4, defendant’s presidential selection process need not have been open to the public except when conducted at a formal session of the board, such as the session at which defendant elected President McPherson. Defendant complied with the constitutional provision in its selection of a university president.16 Accordingly, we reverse the Court of Appeals decision and reinstate the trial court’s order granting summary disposition for defendant.
Weaver, C.J., and Brickley, Taylor, and Young, JJ., concurred with CORRIGAN, J.See Taylor v Auditor General, 360 Mich 146, 154; 103 NW2d 769 (1960).
Defendant charged the psc as follows:
The Presidential Search Committee shall recommend to the Board of Trastees by July 1, 1993 a slate of final candidates for President of Michigan State University. The Board of Trustees will select and appoint the President.
Members of the University community (trustees, faculty, staff, alumni, and students) and other persons interested in the University must submit the name of any person they wish considered as a prospect, nominee, or applicant to the Search Committee for review. The Search Committee shall not eliminate a candidate from consideration until such time as a President has been selected. The Board may add to the list of final candidates individuals reviewed by the Search Committee and not included in the list of final candidates by the Search Committee.
In carrying out its responsibilities the Presidential Search Committee shall:
1. Solicit comments from interested parties on the needs of the University and the qualifications for the next President.
2. Hold public hearings on the needs of the University and the qualifications for the next President.
3. Develop a statement of the needs of the University and the qualifications of the next President to be used to recruit, screen, interview, and evaluate candidates. . . .
4. Actively solicit nominations and applications from a diverse group of well-qualified persons.
5. Develop rules and procedures for the Search Committee to receive nominations and applications, screen candidates, check references, evaluate candidates, interview candidates, and recommend candidates to the Board of Trustees.
6. Carry out the University’s commitment to principles and policies of pluralism and diversity.
7. Carry out the search in a manner that will enhance the stature of Michigan State University.
8. Observe the requirements of Michigan’s Open Meetings Act and Freedom of Information Act.
9. Respect the confidentiality of candidates to the extent permitted by law *8010. Inform the Board of Trustees, the University community, and the media about the progress of the search.
11. Coordinate efforts with those of the consultants of Heidrick and Struggles Inc. who have been retained by msu to assist in the search.
12. The Search Committee will be discharged by action of the Board upon completion of its responsibilities.
The Court of Appeals denied plaintiffs’ application for leave to appeal the interlocutory order and dismissed their motion for peremptory reversal. Unpublished order entered June 18, 1993 (Docket No. 165288). This Court denied plaintiffs’ subsequent application for leave to appeal. 443 Mich 869 (1993).
221 Mich App 103; 561 NW2d 433 (1997).
Judge C. A Nelson dissented, concluding that the oma could not be constitutionally applied to the selection of a state university president.
458 Mich 865 (1998).
The dissent in Booth, supra at 251, reached the constitutional question, concluding that application of the oma in this context is unconstitutional.
This Court has described the governing boards’ status as “the highest form of juristic person known to the law, a constitutional corporation of independent authority, which, within the scope of its functions, is coordinate with and equal to that of the legislature.” Bd of Regents of the Univ of Michigan v Auditor General, 167 Mich 444, 450; 132 NW 1037 (1911).
Defendant came into existence by constitutional amendment in 1959. 1959 PA JR No 2. The Legislature changed the name of defendant’s institution to Michigan State University in 1963. 1963 (2nd Ex Sess) PA 50.
The people granted constitutional status to Wayne State University in 1959. 1959 PA JR No 3. Const 1963, art 8, § 6, confers constitutional status on our other public universities, but provides for appointed, rather than elected, governing boards.
See, e.g., Regents, supra at 395 Mich 65; Bd of Agriculture, supra at 226 Mich 425; Sterling, supra at 380-384.
The concurrence does not explain how Const 1963, art 8, § 4, which applies only to the governing board, applies to a search committee that includes both members of the board and other members of the university community. Given its composition, it is wrong to characterize the meetings of the committee as meetings of the board. Our decision today rests on the board’s supervisory power under Const 1963, art 8, § 5. Const 1963, art 8, § 4 guides us in determining whether Const 1963, art 8, § 5 grants the board the authority to decide whether to open meetings of the search committee to the public.
Compare Const 1963, art 5, §§ 28, 29, establishing the state transportation and civil rights commissions. See, generally, Beech Grove Invest*91ment Co v Civil Rights Comm, 380 Mich 405, 418-419; 157 NW2d 213 (1968) (plurality opinion), and 2 Official Record, Constitutional Convention 1961, pp 2673-2674, discussing the distinction between the phrases “provided by law” and “prescribed by law” as used in the constitution. The relevant provisions of Const 1963, art 8, §§ 4, 5, are not qualified by any such language.
The Attorney General endeavored to define the phrase “formal sessions” in OAG, 1969-1970, No 4676, pp 73, 75 (August 13, 1969):
Meaning and effect can be given to the last sentence of Article Vffl, Sec. 4 by interpreting the phrase “formal sessions” as meetings or sittings of the respective governing bodies held in accordance with established rules of such bodies for the transaction of business.
Therefore, . . . whenever the governing board of an educational institution of higher learning is convened in accordance with established rules of such body for the transaction of business, it must convene in public session to which the members of the public are to be admitted. Private or executive meetings not held in accordance with established rules or where no business of the board is transacted are not formal sessions.
The Attorney General’s attempt to define the term reveals that the determination of what constitutes a “formal” or “informal” session lies within the governing boards’ sphere of authority. This Court would apply the most deferential standard when reviewing the board’s definition of “formal session,” limited to determining whether it bears any relation to the purpose of Const 1963, art 8, § 4. See, generally, Graglia, United States v Lopez: Judicial review under the Commerce Clause, 74 Tex L R 719, 725-726 (1996).
Plaintiffs’ arguments regarding the policy reasons for requiring an open presidential search, and open government in general, are irrelevant *92to our resolution of this case because the constitution settles the question by limiting the Legislature’s power to regulate universities:
[T]he Court is not called upon to give its opinion as to whether the legislation in question is good public policy and the best part of wisdom for the Legislature and the universities to follow. We are asked only whether the legislative conditions invade the constitutional jurisdiction of the universities. Therefore, our conclusions based on the Constitution and the foregoing precedents and our analysis of the lessons they teach can be seen only in that perspective. [Regents, supra at 395 Mich 76.]
In light of our disposition of the constitutional issue, we do not consider whether the psc would otherwise qualify as a “public body” for purposes of the oma.