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OM 14-37 Ryan v. Warren Housing Authority – Violation Found

The Warren Housing Authority violated the OMA by communicating via correspondence concerning public business. The evidence revealed that a letter was written and signed by one of the Housing Authority members. Although it appears no discussions amongst a quorum of the Housing Authority members occurred, the letter was circulated to two (2) other Housing Authority members who read and signed the letter. Since the Housing Authority is comprised of five (5) members, three (3) members would constitute a quorum. While there was no physical "convening," the OMA specifically prohibits the use of electronic communications to circumvent the spirit or the requirements of the OMA. The fact that the letter was hand delivered to Housing Authority members, rather than sent electronically, was of no moment to our analysis.

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