VIA EMAIL ONLY

October 15, 2026

Ms. Nicole Solas

Celina M. Andrade, Esquire

Legal Counsel, Rhode Island Department of Labor and Training

Dear Ms. Solas and Attorney Andrade:

We have completed an investigation into the Open Meetings Act (“OMA”) complaint filed by Ms. Nicole Solas (“Complainant”) against the State Apprenticeship Council (“Council”). For the reasons set forth herein, we find that the Council violated the OMA in connection with its failure to timely post meeting minutes and for including two improperly vague agenda items in its January 27, 2026 supplemental notice. We decline to find a violation in connection with the remaining allegedly insufficient agenda items.

This Complaint concerns the Council’s October 28, 2025 and January 27, 2026 meetings. As to the Council’s supplemental notice for both convenings, the Complainant alleges that each notice contained impermissibly vague items. With regard to the October 28, 2025 meeting notice, she argues that agenda items “4,” “7,” “8,” and “9” “are all too vague to provide fair notice to the public as to the nature of the business to be discussed.” She similarly contends that portions of the January 27, 2026 Council agenda are impermissibly vague (specifically items “3-5 and 7-9”).[1] Finally, she notes that “[n]o meeting minutes for the January 26 [2026] meeting were posted,” also in violation of the OMA.

Legal Counsel to the Rhode Island Department of Labor and Training (hereinafter, the “DLT”) responded to the Complaint on behalf of the Council.[2] She argues that the content of the supplemental notices at issue comply with the OMA’s notice requirements. Beginning with the October 28, 2025 agenda, she argues that item “4” is sufficient, in part, because it contains more information than what was depicted in the Complaint itself and therefore attained a “level of detail” that “fairly informed the public” as to the nature of the substantive business to be addressed by the Council. Similarly, agenda item “7” contained an additional line that was not included in the Complaint-in-chief. The Council contends that, “[u]nder the totality of circumstances,” this added information effectuated compliance with the statute. No business transpired at the subject meeting relative to items “8” and “9” such that the Council argues that “a violation of the OMA did not occur.”

Similarly, with respect to the January 27, 2026 meeting notice, the Council argues that all relevant agenda topics (with the exception of items “7” and “9,” see infra) conform to the strictures of the statute. Agenda item “3” (related to the approval of meeting minutes), the Council avers, “plainly describes exactly which meeting minutes would be discussed and voted upon for approval.” The Council additionally submits that agenda items “4, 5 and 8,” (like challenged agenda items “8” and “9” of the October 28, 2025 agenda), reflect matters that the Council ultimately did not take up at the meeting. Therefore, “nothing was discussed or voted upon at the Council meeting relevant to these categories.”

The Council concedes that agenda items “7” and “9” of the January 27, 2026 meeting notice “require increased specificity.” Still, the Council contends that it “did not have significant discussion or take any voting action related to agenda items 7 and 9.”

Finally, the Council acknowledges that there was a “delay” in the posting of its January 27, 2026 meeting minutes and explains that this was due to the fact that “the Council’s February 24, 2026 meeting was cancelled, rendering the Council members unable to vote on and approve the January meeting minutes until its March 24th meeting.”

We decline to find a violation as to a majority of the challenged agenda items because no substantive business took place in connection with those topics. It is undisputed that as to items “8” and “9” (of the October 28, 2025 agenda) and items “4,” “5,” and “8” (of the January 27, 2026 agenda), no action was taken.[3]

This lack of action is reflected in the corresponding meeting minutes. Under challenged October 28, 2025 agenda topics “8” and “9,” (“Unfinished Business: (discussion and vote)” and “New Business: (discussion and vote),” respectively) the October 28, 2025 meeting minutes clearly state “[n]one” as to each item. The same is true regarding challenged-topics “4,” “5,” and “8” of the January 27, 2026 meeting, as the respective entries in the meeting minutes again state: “[n]one.” Because the Council did not engage in action or discussion in connection with these agenda items, it did not violate the OMA.[4]

We additionally find no violation as to items “4” and “7” on the October 28, 2025 meeting agenda and item “3” in the January 27, 2026 meeting agenda. To begin with, topic “3” of the January 27, 2026 agenda was entirely sufficient for notice purposes. The challenged agenda item states: “3. Approval of Minutes of State Apprenticeship Council Meeting of November: (discussion and vote),” and that is precisely what took place. Indeed, the relevant meeting minutes mirror exactly what was contemplated by the agenda.[5] See Derita v. Providence City Council, OM 26-05 (finding no notice violation where the agenda set forth “precisely what happened at the meeting.”).

Similarly, items “4” and “7” of the October 28, 2025 meeting agenda conformed to the statute. As to both agenda items, it is important to note that these items as constituted differ from the manner in which they were characterized in the Complaint. The Complaint frames these items as being limited in substance to only their larger umbrella topics, i.e., solely "review request for assistance from apprentices, sponsors, and others (discuss and vote)" (item “4”) and "report of the apprenticeship council" (item “7”). This depiction of the challenged agenda items fails to consider their accompanying subsections, which, importantly, provide additional notice information to round out each item.

More specifically, in addition to noticing "review request for assistance from apprentices, sponsors, and others (discuss and vote)," item “4” adds additional provisions stating:

“a. Ace Electric and Domenic Brooks, apprentice: Requesting another testing card” [and] “b. Environmental Systems, Inc. and Dylan Landry, apprentice: Requesting another testing card.”

This is true as to item “7” as well. The agenda phrasing referenced in the Complaint, "report of the apprenticeship council," is bolstered by an additional provision stating “a.  Minimum Wage Compliance: Update.”

When these agenda items are read in this full context and in conjunction with the relevant subparts, they provide the public with ample relevant information and comply with the statute’s notice requirements, particularly given the fact that these subparts directly relate to the larger umbrella topics and complement the same. In other words, the subparts of item “4” reference specific apprentices and the “assistance” they need, while the item “7” subpart specifies precisely what the Council would be “report[ing]” on (“Minimum Wage Compliance”). Thus, these agenda topics were adequate. See Mascaro v. Quonset Development Corporation, OM 26-12 (finding executive session notice to be sufficient, in part, because the Complainant’s depictions of the challenged notices were “incomplete” in that “[r]ead in their entirety … [they] provided more information than asserted”).

• Agenda Items 7 & 9 of the 1.27.26 Agenda

We do find an OMA violation with respect to agenda items “7” and “9” of the Council’s January 27, 2026 agenda. The Council itself concedes that these items “require increased specificity.”[6] See Murray v. Woonsocket City Council, OM 19-12 (finding an OMA violation where the public body conceded that “the notice could have been more specific”).

Nevertheless, injunctive relief is unneeded as to these items. The business of the Council under each topic was cabined only to “discussion” in a manner that makes injunctive relief unnecessary. See Morgan v. Central Coventry Fire District, OM 24-06 (“we do not find a need for injunctive relief … given … the fact that no action was taken at that meeting”).[7]

There is also no evidence that the conduct described above was willful or knowing. We are unaware of any recent, similar violations by the Council, and the Complainant brings no such violations to our attention. See Langseth v. Buttonwoods Fire District, OM 26-11 (declining to find a willful or knowing violation of the OMA where there was “a lack of any recent, similar violations by the public body.”).

• Meeting Minutes

The OMA requires that all public bodies keep written minutes of all meetings, which shall include, but are not limited to: “(1) The date, time, and place of the meeting; (2) The members of the public body recorded as either present or absent; (3) A record by individual members of any vote taken; and (4) Any other information relevant to the business of the public body that any member of the public body requests be included or reflected in the minutes.” R.I. Gen. Laws § 42-46-7(a). These minutes “shall be public records and unofficial minutes shall be available to the public at the office of the public body within thirty-five (35) days of the meeting or at the next regularly scheduled meeting, whichever is earlier….” R.I. Gen. Laws § 42-46-7(b)(1). A copy of official or approved minutes shall be filed “with the secretary of state for inspection by the public within thirty-five (35) days of the meeting.” See R.I. Gen. Laws § 42-46-7(d).

The Council concedes that it “posted the [January 27, 2026] meeting minutes on March 25, 2026.” As such, we conclude that the Council violated the OMA by failing to timely post its meeting minutes. See Solas v. South Kingstown Planning Board, OM 26-07 (finding an OMA violation where the public body “concede[d] that the subject minutes were posted ‘a few days behind schedule.’”).