Definition of ''Meeting'' - Texas Open Meetings Act
The Texas Supreme Court demands "exact and literal compliance with the terms of" the Texas Open Meetings Act. Acker v. Texas Water Com'n, 790 S.W.2d 299, 300 (Tex. 1990).
Those terms dictate that "every regular, special or called meeting of a governmental body shall be open to the public, except as provided by Title 5, Chapter 551, Subtitle A, of the Government Code."
Furthermore, the word "meeting" has been legislatively defined as:
a deliberation between a quorum of a governmental body, or between a quorum of a governmental body and another person, during which public business or public policy over which the governmental body has supervision or control is discussed or considered or during which the governmental body takes formal action. TEX. GOV. CODE ANN. 551.001(4).
Next, the word "deliberation" has been defined as "a verbal exchange during a meeting . . . concerning an issue within the jurisdiction of the governmental body or any public business." Id. at 551.001(2).
In other words, whether a meeting occurred is dependent upon the existence of a verbal exchange between a quorum of the governmental body regarding public business or matter within its jurisdiction. Dallas Morning News Co. v. Board of Trustees, 861 S.W.2d 532, 537 (Tex. App.--Dallas 1993, writ denied).
And, while the legislature failed to define the phrase "verbal exchange", the term has nonetheless received judicial construction.
For instance, the panel in Dallas Morning News interpreted the phrase as a "reciprocal giving and receiving of spoken words." Id. at 537.
So, under the pre-1999 Act, a meeting occurred when there was a "giving and receiving of spoken words" about a matter of public business or within the body's jurisdiction.