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North St. Paul city attorney briefs parks commissioners on open-meeting and data-practices rules
Summary
City Attorney Jack Brooksbank told the Parks and Recreation Commission that a quorum of four constitutes a meeting, serial emails and social-media comment threads can trigger Open Meeting Law issues, and that most government records are treated as public under the Data Practices Act.
City Attorney Jack Brooksbank reviewed Minnesota open-meeting requirements, data-practices rules and ethics considerations at a Parks and Recreation Commission meeting, emphasizing practical steps commissioners can take to avoid inadvertent violations.
Brooksbank told commissioners that a quorum — four of the seven members — constitutes a meeting under the state's Open Meeting Law and that meetings are defined broadly. "If there's four people like in the comments on one thread, that also... counts as a meeting," he said, warning that serial email exchanges or multiple private messages can create a meeting even when no single message includes everyone.
He urged commissioners to use official city email addresses for park business, to post potential gatherings likely to draw four or more commissioners, and to avoid discussing commission business in overlapping private threads. "It is my job to get up here and tell you that you're not allowed to have any fun," Brooksbank said, drawing laughter while stressing the need for careful compliance.
Brooksbank also explained the Data Practices Act: most government-created or -received data are presumptively public and may be requested by members of the public; keeping park-related communications on official channels reduces the burden of fulfilling data requests. He described the de minimis gift threshold (items under $5) and noted recusal procedures for conflicts of interest, including that a recused commissioner does not count toward the quorum for that item.
Commissioners asked specific questions about event promotion via social media, whether they can post event notices and whether multiple commissioners may comment. Brooksbank said posting an event is permissible but multiple commissioners responding in a thread can create reportable government data and potential meeting issues, so staff review and a conservative approach are recommended. He offered to provide guidance and to be available to staff for follow-up.
The attorney's presentation was framed as a proactive primer to help commissioners avoid inadvertent violations rather than a response to a specific complaint or pending enforcement action.
Next step: Brooksbank said staff can provide practical posting guidance; commissioners requested occasional refreshers and the opportunity to raise new questions as membership changes.
