Rhea v. School Bd. of Alachua County
1994 WL 190008, 636 So. 2d 1383, 1994 Fla. App. LEXIS 4698 (1994)
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Rule of Law:
Under Florida's Government in the Sunshine Law, a government body must hold its meetings at a location that provides the constituency it serves with a reasonable opportunity to attend. Holding a meeting at a distant, out-of-jurisdiction location merely for the convenience of the board's members violates this requirement.
Facts:
- The Alachua County School Board decided to conduct a workshop for its members in Orlando, Florida.
- The location was chosen because all Board members were already scheduled to be in Orlando to attend a convention for the Florida School Boards Association.
- Orlando is located outside the geographical boundaries of Alachua County and is more than 100 miles from Gainesville, the Board's headquarters.
- The Board advertised the Orlando workshop in the Gainesville Sun newspaper as 'a public workshop to which all persons are invited.'
- Darnell Rhea, a resident of Alachua County, stated that he would have attended the workshop but for the fact that it was held over 100 miles away from his home.
Procedural Posture:
- Darnell Rhea filed a complaint for injunctive and declaratory relief against the School Board of Alachua County in the trial court.
- Both parties moved for summary judgment.
- The trial court granted summary judgment in favor of the School Board, finding no violation of the Sunshine Law.
- Rhea, as the appellant, appealed the trial court's decision to the District Court of Appeal of Florida, First District.
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Issue:
Does a county school board violate Florida's Government in the Sunshine Law, which requires meetings to be 'open to the public,' by holding a workshop over 100 miles outside its geographical jurisdiction for the convenience of its members, thereby impeding access for its constituents?
Opinions:
Majority - Judge Lawrence
Yes. A county school board violates the Sunshine Law by holding a public workshop at a distant, out-of-county location without a substantial justification, as doing so denies the local public a reasonable opportunity to attend. The court reasoned that the term 'public' in the Sunshine Law refers to the specific constituency affected by the board's actions—in this case, the citizens of Alachua County. For a meeting to be truly 'open to the public,' these citizens must have a 'reasonable opportunity' to attend. The court established a balancing test, weighing the public's interest in access against the board's need for the alternate location. Here, the Board's justification—the convenience of its members—was deemed 'insignificant' and was heavily outweighed by the burdens of time and expense placed upon the public. The location in Orlando had no specific relevance to the subject matter of the workshop, further weakening the Board's position.
Analysis:
This decision clarifies that the 'open to the public' requirement of Florida's Sunshine Law has a geographical component, meaning accessibility is not just about an unlocked door but about practical, physical access for the relevant community. By establishing a balancing test instead of a rigid, bright-line rule, the court created a flexible standard for future cases. This precedent requires government bodies to provide a substantial justification for holding meetings outside their jurisdictions, strengthening public oversight by preventing agencies from effectively excluding constituents by choosing remote or inconvenient locations.
