Rizzo v. County of Los Angeles CA2/1
The Ralph M. Brown Act (Gov. Code, § 54950 et seq.; Brown Act) requires that most meetings of a public agency’s legislative body be open to the public. The Brown Act provides that any interested person may commence an action to obtain a judicial determination that a public action taken in violation of the act is null and void.
John Rizzo and The Marina Tenants Association (collectively Rizzo) sought declaratory and injunctive relief against the Los Angeles County Board of Supervisors (the Board) on the ground that it violated the Brown Act by approving a real property transaction in a closed session. Rizzo appeals from the judgment entered after the trial court granted defendants’ motion for summary judgment. He contends the judgment should be reversed because defendants admitted they violated the Brown Act by permitting board staff to negotiate the property transaction away from public view. We disagree and thus affirm.



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