Bitterman v. Bolf

Defendant, Cheryl Bolf, is the duly elected clerk of the village of Oakley in Saginaw County. Defendant’s duties as clerk are set forth by statute in the General Law Village Act at MCL 64.5 to MCL 64.8a. One such duty is to keep minutes of village council proceedings. MCL 64.5(3). The Open Meetings Act (OMA), MCL 15.261 et seq., also requires a public body holding an open meeting under the OMA to keep minutes of the proceedings. MCL 15.269(1). This provision does not task a particular person with minutes-keeping. However, when a closed meeting is held under the OMA, the clerk of the public…