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(Government Code § 54957; Ricasa v. Office of Administrative Hearings (2019) 31 Cal.App.5th
262; Kolter v. Commission of Professional Competence of Los Angeles Unified School District
(2009) 170 Cal.App.4th 1346; Moreno v. City of King (2005) 127 Cal.App.4th 17; Morrison v.
Housing Authority of Los Angeles (2003) 107 Cal.App.4th 860; Duval v. Board of Trustees of
Coalinga-Huron Unified School District (2001) 93 Cal.App.4th 902; Bell v. Vista Unified School
District (2000) 82 Cal.App.4th 672; Bollinger v. San Diego Civil Service Commission (1999) 71
Cal.App.4th 568; Furtado v. Sierra Community College (1998) 68 Cal.App.4th 876.)

D. THERE ARE REQUIREMENTS TO REPORT OUT ACTION TAKEN IN
CLOSED SESSION

1. The Legislative Body Must Report Out in Open Session Actions Taken and the
Vote.

The legislative body must report in open session certain actions taken in closed
session and the vote, including:

• Approval of an agreement concluding real estate negotiations.

• Approval for legal counsel to defend, initiate, or settle litigation.

• Disposition of claims.

• Action to appoint, employ, dismiss, non-renew, accept resignation of, or affect
the status of any employee. The title of the position and any change in
compensation must be reported. A decision to retain an employee need not be
reported out.

• Approval of labor negotiation agreements.

Reports may be oral or written. Copies of final agreements must be made
available to the public.

Non-action items, such as obtaining direction from the legislative body, regardless
of whether a vote is taken on that direction, need not be reported out.

A checklist on reporting out requirements is contained in Appendix 5.

(Government Code § 54957.1; Gillespie v. San Francisco Public Library Commission (1998) 67
Cal.App.4th 1165; 89 Ops.Cal.Atty.Gen. 110 (2006).)

2. The Timing of Reporting Out May in Some Circumstances Be Deferred to a
Subsequent Meeting or Upon Inquiry.

Most reporting out is done at the same meeting in which the action is taken. In
some circumstances, however, reporting out is deferred to a subsequent meeting or is only

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