FREEDOM OF INFORMATION COMMISSION
OF THE STATE OF CONNECTICUT
In the Matter of a Complaint by FINAL
DECISION
Richard Cicciari,
Complainant
against Docket
#FIC 87-187
Legislative Council of the Town of Hamden,
Respondent October
14, 1987
The above-captioned
matter was heard as a contested case on July 30, 1987, at which time the
complainant and the respondent appeared, stipulated to certain facts and
presented testimony, exhibits and argument on the complaint.
After consideration of
the entire record, the following facts are found:
1. The respondent is a public agency within the
meaning of §1-18a(a), G.S.
2. By letter of complaint dated and filed with
the Commission on July 1, 1987, the complainant alleged the respondent violated
the Freedom of Information Act by conducting business beyond that specified in
the notice for its June 5, 1987 special meeting.
3. Specifically, the complainant alleges the
respondent held a new election at its June 5, 1987 special meeting and
nominated, elected and confirmed Kevin Lawlor as fifth district councilperson,
when the meeting was noticed solely to confirm the election of Kevin P. Lawlor
as fifth district councilperson.
4. The complainant requests the Commission to
declare the actions taken by the respondent at its June 5, 1987 special meeting
null and void and to impose a civil penalty.
5. The respondent claims it confirmed the
election of Kevin Lawlor as fifth district councilperson at its June 5, 1987
special meeting and therefore its actions were within the scope of the notice
given for that meeting within the meaning of §1-21(a), G.S.
Docket #FIC 87-187 Page 2
6. It is found the respondent elected Kevin
Lawlor as fifth district councilperson at its April 13, 1987 emergency meeting.
7. It is noted the complainant in this case
filed a complaint with the Commission, Docket #FIC 87-113, alleging the
respondent impermissibly held an emergency meeting on April 13, 1987, to fill a
vacancy on its council and requesting the Commission to declare the election
null and void.
8. It also is noted on May 27, 1987, the
hearing officer issued a report in Docket #FIC 87-113, recommending all votes
taken at the respondent's April 13, 1987 emergency meeting be declared null and
void. The Commission, however, did not
adopt the hearing officer's report until July 8, 1987.
9. It is found the respondent held a special
meeting on June 5, 1987.
10. It also is found the respondent noticed its
June 5, 1987 special meeting for the following purpose: "to confirm the election of Kevin P.
Lawlor as councilperson from the fifth district to the Hamden Legislative
Council."
11. It further is found that at the respondent's
June 5, 1987 special meeting, one of its members moved to "nominate,
confirm, elect, ratify, affirm and instate Kevin Lawlor as the fifth district
councilman to the Legislative Council of the Town of Hamden," and the
motion passed by a majority vote.
12. It further is found the motion described in
paragraph 11, above, was made to remedy any alleged impropriety concerning the
respondent's April 13, 1987 election before the Commission rendered a final
decision in Docket #FIC 87-113.
13. It further is found the respondent held a
new election to fill the position of fifth district councilperson at its June
5, 1987 special meeting.
14. It therefore is concluded the respondent
failed to give sufficient notice to the public of what would transpire at its
June 5, 1987 special meeting in violation of §1-21(a), G.S.
15. It is found, however, at the time of the
respondent's June 5, 1987 special meeting, the Commission had not declared the
respondent's April 13, 1987 election null and void.
Docket #FIC 87-187 Page 3
16. It also is found at the time of its June 5,
1987 special meeting, the respondent held an election to fill a position for
which there was no vacancy and therefore its actions have no legal effect.
17. The Commission therefore declines to declare
the respondent's June 5, 1987 election null and void because it was meaningless
and further declines to impose a civil penalty.
The following order by
the Commission is hereby recommended on the basis of the record concerning the
above-captioned complaint:
1. The respondent shall henceforth act in
strict compliance with the requirements of §1-21(a), G.S.
Approved by order of
the Freedom of Information Commission at its regular meeting of October 14,
1987.
Catherine
H. Lynch
Acting
Clerk of the Commission