Beck v. Shelton

In this appeal, we consider several issues relating to The Virginia Freedom of Information Act (“FOIA” or the “Act”), Code §§ 2.2-3700 to -3714, including: 1) whether “members-elect” are “members” of a public body for the purpose of application of FOIA; 2) whether the use of electronic mail (“e-mail”) for communication between three or more members of a public body constitutes a “meeting” for the purposes of FOIA; and, 3) whether a particular gathering of citizens attended by three members of the Fredericksburg City Council constituted a “meeting” under the Act.

Facts and Proceedings Below

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