(dissenting). Because I find the application of the Open Meetings Act1 and the Freedom of Information Act2 to governing boards of public universities during the selection of university presidents violates the autonomy vested in the boards by the Michigan Constitution and warrants review by this Court, I respectfully dissent.
i
The majority refuses to examine the clear constitutional issue presented in the instant case because defendant did not raise the issue until appeal. The majority correctly notes that "[i]ssues raised for the first time on appeal are not ordinarily subject to review.” Ante at 234. Nevertheless, the instant case presents a significant issue, which is necessary to the correct resolution of the case and may be resolved without further action. Hence, this Court has the discretion to review the constitutional issue. See, e.g., Dation v Ford Motor Co, 314 Mich 152, 161; 22 NW2d 252 (1946); Perin v Peuler, 373 Mich 531, 534-535; 130 NW2d 4 (1964); Felcoskie v Lakey Foundry Corp, 382 Mich 438, . 442; 170 NW2d 129 (1969).3 The Court is not obliged to stand idle when a controversy before it *252involves vital issues regarding the very structure of state government. Indeed, this Court did not hesitate to declare, without a case or controversy and sua sponte, that the oma would be unconstitutional if applied to this Court. In re 1976 PA 267, 400 Mich 660; 255 NW2d 635 (1977).4
ii
The Michigan Constitution confers an independent governmental status on its public universities and their boards of education, and grants the boards the exclusive power to elect their presidents:
The regents of the University of Michigan and their successors in office shall constitute a body corporate known as the Eegents of the University of Michigan .... 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. [Const 1963, art 8, § 5.][5]
This Court has long held that "[t]he object of construction, as applied to a written constitution, is to give effect to the intent of the people adopting it.” 1 Cooley, Constitutional Limitations (8th ed), p *253124. The primary source for ascertaining the original understanding of the constitution is its plain meaning as understood by its ratifiers at the time of its adoption. Committee for Constitutional Reform v Secretary of State, 425 Mich 336, 342; 389 NW2d 430 (1986).6 This is so because the fundamental charter " 'is made for the people and by the people,’ ” Traverse City School Dist v Attorney General, 384 Mich 390, 405; 185 NW2d 9 (1971), and " 'does not derive its force from the convention which framed, but from the people who ratified it . . . .’” Id., quoting Cooley, supra (6th ed), p 81.
Often, however, "[w]e cannot understand these provisions unless we understand their history . . . .” Cooley, supra, p 132. If so, "to clarify meaning, the circumstances surrounding the adoption of a constitutional provision and the purpose sought to be accomplished may be considered.” Traverse City School Dist, supra at 405.7 Thus, we should expound the constitution "according to its own tenor, in the light of such previous historical facts as may legitimately aid to elucidate it.” People ex rel Twitchell v Blodgett, 13 Mich 127, 142 (1865) (Campbell, J.). Therefore, we may " 'endeavour to place ourselves in the position of the framers of the Constitution, and ascertain what was meant at the time ....’” Committee for Constitutional Reform, supra at 342, quoting Pfeiffer v Detroit Bd of Ed, 118 Mich 560, 564; 77 NW 250 (1898). See also People v Thompson, 424
*254Mich 118, 125-126; 379 NW2d 49 (1985).8 Furthermore, due deference to contemporaneous or longstanding interpretations of the constitution by this Court is warranted.9
These traditional rules of constitutional construction are essential: "The literal construction of the words, without regard to their obvious purpose of protection, is to make the constitutional safeguard no more than a shabby hoax, a barrier of words, easily destroyed by other words. ... A constitutional limitation must be construed to effectuate, not to abolish, the protection sought by it to be afforded.” Lockwood v Comm’r of Revenue, 357 Mich 517, 556-557; 98 NW2d 753 (1959). Thus, a thorough examination of the historical origins of the constitutional provision in question is indispensable to the proper disposition of the instant case and the integrity of the constitution.
hi
The supreme law of the State of Michigan has long conferred a unique constitutional status upon *255its public universities. In 1837, the Legislature established the state’s first public institution of higher learning, the University of Michigan, in Ann Arbor.10 Upon its founding, the university was managed by the Legislature, and this arrangement was incorporated into the state’s first constitution. Const 1835, art 10, § 5. Legislative regulation of the university was generally understood as disastrous, however, and a major focus of the Constitutional Convention of 1850 was the elimination of such supervision over the institution:
Under the Constitution of 1835, the legislature had the entire control and management of the University and the University fund. They could appoint regents and professors, and establish departments. The University was not a success under this supervision by the legislature .... Such was the condition of affairs when [the Constitutional Convention of 1850] met. It is apparent to any reader of the debates in this convention in regard to the constitutional provision for the University that they had in mind the idea of permanency of location, to place it beyond mere political influence, and to intrust it to those who should be directly responsible and amenable to the people. [Sterling v Univ of Michigan Regents, 110 Mich 369, 374; 68 NW 253 (1896).[11]
*256Thus, the Constitutional Convention of 1850 divested the Legislature of its picayune and unsuccessful regulation of education, and placed control of public universities in an independent body of government directly responsible to the people:
The public men of those times were greatly interested in the University. . . . The general consensus of opinion was that it should be under the control and management of a permanent board, who should be responsible for its management.
Obviously, it was not the intention of the framers of the Constitution to take away from the people the government of this institution. On the *257contrary, they designed to, and did, provide for its management and control by a body of eight men elected . . . for long terms, and whose sole official duty it should be to look after its interests, and who should have the opportunity to investigate its needs, and carefully deliberate and determine what things would best promote its usefulness for the benefit of the people. [Id. at 375-379J[12]
Hence, the Constitution of 1850 and its progeny13 specifically granted the board of regents of the University of Michigan independent constitutional status. This Court, therefore, has long recognized that the Legislature and boards of education are distinct and coequal governmental bodies vested with separate powers:
The board of regents and the legislature derive their power from the same supreme authority, namely, the Constitution. In so far as the powers of each are defined by that instrument, limitations are imposed, and a direct power conferred upon one necessarily excludes its existence in the other, in the absence of language showing the contrary intent. . . . They are separate and distinct constitutional bodies, with the powers of the regents defined. By no rule of construction can it be held that either can encroach upon or exercise the powers conferred upon the other. [Id. at 382.]
In other words, "the board of regents is made *258the highest form of juristic person known to the law, a constitutional corporation of independent authority, which, within the scope of its functions, is co-ordinate with and equal to that of the legislature.” Bd of Regents of Univ of Michigan v Auditor General, 167 Mich 444, 450; 132 NW 1037 (1911).14
Hence, "the Legislature may not interfere with the management and control of ” universities, Regents of Univ of Michigan v Michigan, 395 Mich 52, 65; 235 NW2d 1 (1975), nor may it "control the action of the Regents.” Weinberg v Regents of Univ of Michigan, 97 Mich 246, 254; 56 NW 605 (1893). Justice Williams distilled from our constitution and precedent that "[t]he Legislature cannot interfere in the management of the university. [Nor may it] prohibit [or] require the universities to take any particular action.” 395 Mich 92. In fact, "[t]he powers and prerogatives of Michigan universities have been jealously guarded not only by the boards of those universities but by this Court in a series of opinions running as far back as 1856.” Eastern Michigan Univ Bd of Control v Labor Mediation Bd, 384 Mich 561, 565; 184 NW2d 921 (1971).15
*259Nevertheless, this Court has noted that its historically strong protection of regental autonomy is not without exceptions. The Court has acknowledged that legislative regulation of the universities is not improper if legislation focuses upon the general welfare and does not interfere with the university’s operations, finances, or mission:
"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 confines of the operation and the allocation of funds of the University, it is supreme. Without these 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.” [Univ of Michigan Regents v Employment Relations Comm, 389 Mich 96, 108; 204 NW2d 218 (1973), quoting Branum v Bd of Regents of Univ of Michigan, 5 Mich App 134, 138-139; 145 NW2d 860 (1966).][16]
*260This reading of the constitution is in accord with its language as well as the original intentions of the ratifiers and framers of the constitution when granting autonomous regental power. The thrust of the adoption of the constitutional provisions was to ensure university autonomy with regard to management and supervision of the educational process and related matters, but not with the general welfare of the community. The provision, for instance, clearly was not intended to permit a board of regents to decriminalize drugs for recreational use or violate child labor laws, nor was it intended to permit the regents to refuse compliance with other general welfare laws unless they interfered with their constitutionally conferred duties.17
On the other hand, the constitution clearly prohibits infringement of constitutionally enumerated regental power by the Legislature. Hence, this Court has held that although defendant was subject to the public employees relations act,18 such regulation could not extend into the regents’ constitutionally granted powers:
Because of the unique nature of the University of Michigan . . . the scope of bargaining by [an *261association of medical interns, residents, and postdoctoral 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. [389 Mich 109.]
Similarly, in Bd of Agriculture v Auditor General, 226 Mich 417, 425; 197 NW 160 (1924), the Court ruled that although the Legislature may attach conditions to funding, not only may the regents reject such appropriations, but those conditions that infringed upon the regents’ management and control of the institution were unconstitutional:
Clearly, in saying that the legislature can attach to an appropriation any condition which it may deem expedient and wise, the court had in mind only such a condition as the legislature had power to make. It did not mean that a condition could be imposed that would be an invasion of the constitutional rights and powers of the governing board of the college. It did not mean to say that, in order to avail itself of the money appropriated, the State board of agriculture must turn over to the legislature management and control of the college, or of any of its activities.[19]
Moreover, those cases permitting legislative interference with the regental power pitted one constitutional provision against another, and resolved the disputes by holding that the more specific power granted to the other branches of gov*262ernment overrode the general power of university autonomy.20
The Legislature, therefore, may not impose conditions on a board of regents that interfere with the supervision, management, or control of a university or that are related to its finances, property, or educational mission, and may only regulate university-related activities that have bearing on the general welfare and that arise from a constitutionally granted power.
IV
In the instant case, the plain meaning of the constitution, combined with the historical circumstances surrounding its adoption, reveal that the intentions of its ratifiers and framers were to grant autonomous regental power over the selection of the university president. The constitution endows the regents with the exclusive power to "elect a president of the institution under its supervision,”21 and confers upon the regents "general supervision of its institution and the control and direction of all expenditures . . . .” Const 1963, art 8, § 5. That the ratifiers and framers of the constitution intended to prohibit legislative intervention in the fundamental operations of public universities may not be doubted. The historical circumstances that bore the constitutional provi*263sion evidence that regental autonomy in core educational functions, such as selecting a president, was the paramount concern of the ratifiers and framers of the section. Indeed, acknowledging that the selection of the president of a university is perhaps the most important function of the board of regents, the constitution explicitly granted the power to the regents,22 who historically were unencumbered in their presidential selection process by the Legislature.23 In short, legislative oversight of the presidential selection process strikes at the core of regental autonomy.
This is so because the procedures followed by defendant to select a president are a vital aspect of the "management and control of” the university. 395 Mich 65. As this Court is well aware, procedure often determines result. The oma and the foia certainly attempt to "control the action of the Regents” by dramatically altering the method by which the board must fulfill its constitutionally vested duty. Weinberg, supra at 254.24 Indeed, our well-established precedent manifests that most legislative efforts to control the university unconstitutionally have occurred when the "legislature attempted to impose its will upon the internal operations of a university.” 384 Mich 565. The acts at issue are such attempts._
*264In In re 1976 PA 267, 400 Mich 660, 663; 255 NW2d 635 (1977), the Court recognized that the separation of powers doctrine prohibits the application of the oma to the internal operations of the judiciary:
The judicial powers derived from the Constitution . . . 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. . . . 1976 PA 267 is an impermissible intrusion into the most basic day-today exercise of the constitutionally derived judicial powers.[25]
Similarly, the oma and the foia strongly infringe upon the internal workings of a university by demanding the regents entirely rework their presidential selection procedures to meet their requirements. The regents vigorously argue that an open selection process will reduce both the quantity and the quality of available candidates. The record reveals that other regents from major Michigan universities concur. Not unlike this Court, the application of the oma and the foia to the regents is simply beyond the realm of legislative authority.
Moreover, the constitution rejects legislative attempts to open the presidential selection process because it fails to include the informal presidential search process in its mandatory disclosure provision. Const 1963, art 8, § 4. Ratified concurrently with art 8, § 5, art 8, § 4 mandates limited public oversight over the universities: "Formal sessions of governing boards of such institutions shall be open to the public.”_
*265At the Constitutional Convention, the author of the provision explained its history and purpose:
Meetings of governing boards of the 3 major universities have been open to the public and news media for the past Vi 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. [Delegate White, 1 Official Record, Constitutional Convention 1961, p 1187.]
Similarly, the Address to the People stated that this provision was enacted to "insure[ ] that formal sessions of the governing boards of such institutions will be open to the public.” 2 Official Record, Constitutional Convention 1961, p 3396.
Unmistakenly, the purpose of the provision was to bring within the constitution the then-recent practice of permitting public access to formal meetings. No evidence, however, suggests that the provision was intended or understood to mandate the exposure of the entire presidential selection process to public view, or to empower the Legislature to do so.26 Indeed, the exclusionary language of "formal” reveals the decision whether informal meetings shall be held publicly is vested in the regents. As noted at the Constitutional Convention of 1961, before the adoption of art 8, § 4, regental power permitted the exclusion of the public from *266all of its meetings; after the ratification of that provision, the same power rested with the regents except with relation to formal meetings. Indeed, that the convention considered a constitutional amendment necessary to ensure that the recent practice of open formal meetings continued strongly suggests that the framers understood that the regents possessed plenary power with regard to the issue. The presidential selection process, therefore, need not be disclosed except when conducted in a formal meeting, such as the election of the officer,27
*267The plain understanding of the constitution, enlightened by the circumstances from which it arose, protects regental power from the Legislature’s oversight in the instant case. The Legislature, therefore, possesses no power to force defendant to comply with the oma and the foia28 during the presidential selection process.29
*268Griffin, J., concurred with Riley, J.MCL 15.261 et seq.; MSA 4.1800(11) et seq.
MCL 15.231 et seq.; MSA 4.1801(1) et seq.
Furthermore, in my view, the exercise of the Court’s discretion is compelled in this case because the Court is presented with "a significant constitutional question . . . .” People v Blunt, 189 Mich App 643, 646; 473 NW2d 792 (1991). See also Dation, supra (examining a claim that the workers’ compensation act violated due process for first *252time on appeal); People v DeGraffenreid, 19 Mich App 702, 715; 173 NW2d 317 (1969) (holding that in some cases a court is "obliged to” grant a criminal defendant relief if a constitutional error occurred at trial even if the defendant did not assert such a right at trial); People v Davis, 181 Mich App 354, 355; 448 NW2d 842 (1989) (examining an ex-post-facto claim for the first time on appeal).
Furthermore, because as found by both the majority and Justice Boyle, the regents undoubtedly violated the oma and the foia in some fashion, the doctrine that the Court should not reach constitutional issues that are unnecessary to the resolution of a case is not invoked.
See also Const 1963, art 8, § 6.
In other words, " '[t]he interpretation that should be given it is that which reasonable minds, the great mass of the people themselves, would give it.’ ” Committee for Constitutional Reform, supra at 342, quoting Traverse City School Dist v Attorney General, 384 Mich 390, 405; 185 NW2d 9 (1971).
See also People v Harding, 53 Mich 481, 485; 19 NW 155 (1884); Kearney v Bd of State Auditors, 189 Mich 666, 673; 155 NW 510 (1915); Committee for Constitutional Reform, supra at 405.
That the Court, with some hesitation, may examine "the proceedings of the constitutional convention [to] endeavor to discover the probable intention of the framers of the constitution as we now find it, is well settled . . . .” Blodgett, supra at 165 (Cooley, J.). Strong reliance on such records, however, is appropriate only in the absence of clear constitutional language or "when we find in the debates a recurring thread of explanation binding together the whole of a constitutional concept.” Regents of Univ of Michigan v Michigan, 395 Mich 52, 60; 235 NW2d 1 (1975). See also Committee for Constitutional Reform, supra at 341.
"Indeed, where a particular construction has been generally accepted as correct, and especially when this has occurred contemporaneously with the adoption of the constitution, and by those who had opportunity to understand the intention of the instrument, it is not to be denied that a strong presumption exists that the construction rightly interprets the intention.” [McPherson v Secretary of State, 92 Mich 377, 383; 52 NW 469 (1892), quoting Cooley, supra, p 67, aff’d 146 US 1; 13 S Ct 3; 36 L Ed 869 (1892).]
The University of Michigan was founded under an act of Congress making an appropriation of lands for the support of a university in this State, approved May 20, 1826. [Sterling v Univ of Michigan Regents, 110 Mich 369, 373; 68 NW 253 (1896).]
A select committee was appointed by the legislature in 1840 to inquire into the condition of the University. . . . [This] report[ ] and discussion[ ] undoubtedly [was] known to the members of the convention, and their action should be construed in the light of such knowledge. [Id. at 375-377.]
The committee reported the dismal failure of the state-run public universities and the advantages of autonomous boards of education:
*256"No State institution in America has prospered as well as independent colleges with equal, and often with less, means. Why they have not may be ascribed, in part, to the following causes: They have not been guided by that oneness of purpose and singleness of aim (essential to their prosperity) that others have whose trustees are a permanent body, — men chosen for their supposed fitness for that very office, and who, having become acquainted with their duties, can and are disposed to pursue a steady course, which inspires confidence and insures success .... State institutions, on the contrary, have fallen into the hands of the several legislatures, fluctuating bodies of men, chosen with reference to their supposed qualifications for other duties than cherishing literary institutions. When legislatures have legislated directly for colleges, their measures have been as fluctuating as the changing materials of which the legislatures were composed.
"The argument by which legislatures have hitherto convinced themselves that it was their duty to legislate universities to death is this: 'It is a State institution, and we are the direct representatives of the people, and therefore it is expected of us; it is our right. The people have an interest in this thing, and we must attend to it.’ As if, because a university belongs to the people, that were reason why it should be dosed to death for fear it would be sick, if left to be nursed, like other institutions, by its immediate guardians. Thus has State after State, in this American Union, endowed universities, and then, by repeated contradictory and over legislation, torn them to pieces with the same facility as they do the statute book, and for the same reason, because they have the right.” [Sterling, supra at 375-377, quoting 2 House Documents 1840, p 470.]
So clear was the convention’s intent, this Court has confidently reported that there was not "a single utterance by any member of that convention from which it could be inferred that the members believed or supposed that they were leaving the control of that institution to the legislature.” Sterling, supra at 377. As one conventioneer stated, " 'the convention will observe that the concerns of this University are to be placed in the hands of the regents.’ ” Delegate Whipple, quoted id. at 375.
Const 1850, art 13, reads in essence the same as the 1908 provision and subsequently the 1963 provision. [395 Mich 64, n 8 supra.]
See also People ex rel Drake v Regents of Univ of Michigan, 4 Mich 98, 104 (1856); Weinberg v Regents of Univ of Michigan, 97 Mich 246, 254-255; 56 NW 605 (1893); Bd of Agriculture v Auditor General, 226 Mich 417, 423; 197 NW 160 (1924).
See, e.g., People ex rel Drake, n 14 supra; People v Regents of the Univ, 18 Mich 469 (1869) (the Legislature may not mandate at least one professor of homeopathy in the department of education of defendant); Weinberg, supra at 254-255 (the public bonding statute does not apply to universities); Sterling, supra (the public act directing regents to establish a homeopathic medical college is unconstitutional); Bauer v State Bd of Agriculture, 164 Mich 415, 418-419; 129 NW 7Í3 (1911) (universities possess exclusive control of appropriated funds, and may construct a building on college grounds to be leased as a post office); Regents v Auditor General, 167 Mich 450-451 (regents are not bound by the general accounting laws of the state unless they so consent); Bd of Agriculture v Auditor General, 180 Mich 349, 359; 147 NW 529 (1914) ("the legislature exceeded its *259powers in attempting to deprive the relator of its constitutional control of agricultural college funds derived from the Federal government”); Bd of Agriculture, n 14 supra, 226 Mich 426-427 (conditions attached to appropriations were an unconstitutional infringement of regental autonomy); Bd of Regents of Univ of Michigan v Michigan, 166 Mich App 314; 419 NW2d 773 (1988) (the statute mandating divestment from corporations operating in South Africa by public educational institutions unconstitutionally infringed upon the defendant’s grant of exclusive control and direction of expenditures to the university); Michigan United Conservation Clubs v Bd of Trustees of Michigan State Univ, 172 Mich App 189; 431 NW2d 217 (1988) (a university ordinance designating all lands and water under its control as a wildlife, fish, and bird sanctuary was within the constitutional and statutory authority of the board of trustees to control and manage university property); Dynamic Heating & Pumping Co v Ins Co of North America, 912 F2d 123 (CA 6, 1990) (the defendant was exempt from the Bonding Act requirements as a constitutionally created entity).
Plaintiffs suggest that because the foia states that "[i]t is the *260public policy of this state that all persons are entitled to full and complete information regarding the affairs of government and the official acts of those who represent them as public officials and public employees,” MCL 15.231(2); MSA 4.1801(1)(2), the foia may apply in the instant case. However, the Legislature may not violate the constitution in pursuit of its own designated "public policy.”
Glass v Dudley Paper Co, 365 Mich 227; 112 NW2d 489 (1961) (holding that the specific constitutional authority of the Legislature to create courts and define their jurisdiction was sufficient to fix the jurisdiction of the Court of Claims and include Michigan State University within its exclusive jurisdiction); Peters v Michigan State College, 320 Mich 243; 30 NW2d 854 (1948) (upholding, by an equally divided vote, the Court of Appeals ruling that the Michigan State College was not exempt from the workers’ compensation act),
MCL 423.201 et seq.; MSA 17.455(1) et seq.
Hence, the Legislature may not invade a university’s management and control over its property, Weinberg, supra at 254-255; Dynamic Heating & Pumping Co, n Í5 supra, or curriculum. Sterling, supra at 375, or finances. 226 Mich 426-427.
In Univ of Michigan Regents v Employment Relations Comm, supra, the Court noted that the resolution of public employee disputes was a matter of public policy as provided in art 4, § 48. In Glass, n 17 supra, the general autonomy of the university was pitted against the other branches’ constitutional powers to establish and operate courts as conferred by art 7, § 1. Similarly, in Peters, n 17 supra, the dispute involved the provision of Const Í908, art 5, § 29, permitting the Legislature to create laws relating to employment versus the college’s general constitutional autonomy.
Regents may not delegate this power. See Sittler v Bd of Control, 333 Mich 681, 686; 53 NW2d 681 (1952).
Indeed, the Address to the People unambiguously declared that "[e]ach of the boards is permitted to choose the president of its university as presently provided.” 2 Official Record, Constitutional Convention 1961, p 3396.
Nearly all regental meetings were closed to the public except at the leisure of the board. See, e.g., Delegate White, 1 Official Record, Constitutional Convention 1961, p 1187.
Moreover, defendant credibly maintains that it perceives that presidential searches would be hampered by compliance with the oma. Whether this assertion is true is irrelevant, because defendant’s determination in this policymaking arena may not be questioned by this Court. At issue is the clash between two lawmakers; I only resolve that defendant is entitled to autonomy in this area. See also n 28.
So clear was the unconstitutionality of the application of the oma to the judiciary, that this Court was compelled to issue an extremely rare advisory opinion informing the Legislature of the unconstitutionality of proposed oma provisions.
Plaintiffs do not suggest that the then-existing practice was to allow the press to accompany regents on interviews for possible presidential candidates, nor do they suggest that such practice was even considered at the adoption of the constitution.
Unlike other provisions of the constitution, "formal sessions” are undefined and are not delegated to the Legislature to define. Hence, the constitution may leave the definition, if not patently unreasonable, to the boards. Cf. Bd of Regents of Univ of Michigan v Auditor General, supra at 449 (holding that regents could determine if their expenditures were "for lawful purposes”).
In any event, the plain meaning of the constitutional provision prohibits the application of the oma and the foia in the instant case. Unlike the oma, the constitution only mandates that "[formal sessions” be open to the public. Sources contemporary with the adoption of the amendment reveal that "formal” is defined as "belonging to or being the essential constitution or structure . . . following or according with established form, custom, or rule . . . based on conventional forms and rules,” while "session” is defined as "a meeting or series of meetings of a body (as a court or legislature) for the transaction of business . . . .” Webster’s Seventh New Collegiate Dictionary (1969), p 328; id. at 793. See also 37 CJS, formal, p 115 ("[o]f or pertaining to form, characterized by due form or order”).
This definition comports with one drafted by the Attorney General:
"[F]ormal sessions” [is defined] as meetings or sittings of the respective governing bodies held in accordance with established rules of such bodies for the transaction of business. . . .
[W]henever 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 .... [OAG, 1969-1970, No 4676, pp 73, 75 (August 13, 1969).]
Cf. Severson v Sueppel, 260 Iowa 1169, 1173-1174; 152 NW2d 281 (1967).
Meetings at which the regents follow established rules in order to formally transact business, therefore, must be open to the public. OAG, No 4676, supra. On the other hand, informal meetings need not *267be. The meetings at issue, therefore, were informal and need not have been open to the public.
The Michigan Constitution also mandates that the financial records of public entities be open to public scrutiny:
All financial records, accountings, audit reports and other reports of public moneys shall be public records and open to inspection. [Const 1963, art 9, § 23.]
"The manifest purpose of article 9, §23 is to allow the public to keep their finger on the pulse of government spending.” Grayson v Bd of Accountancy, 27 Mich App 26, 34; 183 NW2d 424 (1970). In the instant case, there is no doubt that the records of the expenditures by defendant must be open to public scrutiny in some manner. Hence, defendant must disclose that it purchased airline tickets, the price of the tickets, and other pertinent financial information. Defendant must release at least "summaries, balance sheets, and other such compilations which map out and correlate a myriad of financial transactions into a meaningful account.” Id. On the other hand, whether a constitutional mandate exists which compels defendant to disclose the location of its travels is open to question. Cf. id. at 34-35 ("[i]t strains one’s credulity to think that the framers of the Constitution meant to allow the public to inspect every receipt . . . and every writing evidencing a receipt or expenditure”).
In any event, where the board, while exercising its exclusive authority to select a president, reasonably determines that such disclosure significantly hinders its ability to fulfill its constitutional duty, then the longstanding constitutional protection of regental autonomy should outweigh the minimal interest of financial record disclosure of the destination of such trips. Hence, in the conflict between these two constitutional provisions regental autonomy triumphs.
Both sides vigorously contest the efficacy of a closed versus an open presidential selection process. These arguments, however, are irrelevant to the resolution of the instant case because the constitution has settled the issue:
[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 *268invade 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. [395 Mich 76.]