The 1991 Connecticut Supreme Court case of Elections Review Committee of the Eighth Utilities District v. Freedom of Information Commission held that the term "committee" in C.G.S. §1-200(1), refers to a group that is a "subunit" of the agency that created it. Sheila Parizo appealed to the Freedom of Information Commission alleging that the Board of Alderman of the city of Derby violated the Freedom of Information Act by failing to post notice of a subcommittee meeting and excluding the public from such meeting. The FOIC found that the community relations subcommittee of the board of aldermen is comprised of three members of the board and is a subunit of the board of alderman. The subcommittee is a "committee of" the board and, thus, a public agency. The board of aldermen held a meeting and an item on the agenda was a public hearing and discussion of a project involving a parcel of land. During the discussion, the mayor asked a board member whether he would like to convene the subcommittee to review the maps and appraisals. The agenda did not state that the community relations subcommittee would meet to review maps and appraisals pertaining to the parcel. Nevertheless, the board recessed its meeting so the subcommittee could meet. The complainant was not permitted to attend the subcommittee meeting. The subcommittee did not record minutes of their discussion or make a record of any votes. When the full board reconvened, it heard the subcommittee's recommendation to make an offer on the property. The board unanimously approved a motion to make such an offer as recommended. The FOIC found that the subcommittee discussed matters over which it had supervision, control, jurisdiction or advisory power. The discussion was a meeting of the subcommittee subject to the requirements of the FOIA. The FOIC concluded that the subcommittee violated C.G.S. §§1-225(a) and (d). The respondent board violated the FOIA by failing to require the subcommittee to comply with the open meeting requirements of C.G.S. §§1-225(a) and (d). The FOIC directed the subcommittee to file minutes of the meeting and to strictly comply, henceforth, with the violated provisions.

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