Brief
Kansas
City v. State of MO
94-4035
(1996)
The Desegregation Monitoring Committee (DMC) is an extension of a federal court responsible for overseeing implication of that court's orders. The DMC requires a school board to meet behind closed doors at DMC meetings to discuss matters concerning implementation of the court's orders.
The facts indicate a conflict between the rights of the federal court to efficiently carry out it's orders through the DMC and the rights of individuals to be informed about and participate in school board meetings.
The court must determine the application of the Act (Missouri Sunshine Act) to the DMC Executive Committee closed-door meetings at which the school board is required to appear.
The courts holdings were (a) In instances in which the prohibitions of the Act might be contravened, the DMC should seek a court order stating that such a closed meeting is necessary, (b) The meetings agenda should be controlled so as not to infringe on the policies regarding discussion of public business, and (c) the agenda of the DMC meetings should be limited to only those areas clearly within the mission of remedy implementation.
The court cites the Supremacy Clause of the United States Constitution as sufficient to invalidate the claim that the DMC, which is an arm of the federal court, falls within the scope of the Act. Additionally, the court argues that the closed-door meetings were DMC meetings, called and controlled by the DMC and, therefore, did not trigger the Act's provisions.
The case is remanded to the district court for action consistent with it's holdings.
The state statute establishes regulations on how a board can meet and what can be discussed in open meetings as well as closed meetings. However, the federal government is not held to specific state statutes requiring its members to operate within the state's jurisdiction.
The decision implies that the federal government will not necessarily be held to state statutes. However, embedded in the decision is the implication that specific rules should exist to limit the potential abuse of this exception by federal bodies.
Functions of state government may be greatly affected in that specific state statutes may not apply to various federal agencies. Furthermore, those federal agencies may be required to follow specific rules and procedures when dealing with future cases.