Shapiro v. Board of Directors

In Shapiro v. Board of Directors (2005) 134 Cal.App.4th 170, the Court observed (via one of the parties' arguments) that though the Brown Act expressly permits closed sessions between the legislative body and its counsel regarding litigation, "there is no similar express authorization to meet in closed session where the legislative body delegates to another entity as its agent its powers to negotiate for the acquisition of real property." (Shapiro, at pp. 182-183, italics omitted.)