Colab

The Ralph M. Brown Act (Gov. Code, § 54950 et seq.; the Brown Act) is designed to encourage public participation in government. To fulfill this purpose, it requires that public agencies conduct business and deliberate openly. Here we hold that the Brown Act does not require a county board of supervisors to allow members of the public to address it concerning whether an item should be placed on the agenda.

We also determine that the trial court did not abuse its discretion in denying plaintiffs’ motion to compel discovery. We affirm.

FACTS

The Coalition of Labor, Agriculture & Business and the Center for Environmental Equality (collectively COLAB) are nonprofit corporations. COLAB filed a complaint against the Board of Supervisors of the County of Santa Barbara (the Board) and Supervisors Gail Marshall, Susan Rose and Naomi Schwartz, alleging violations of the Brown Act. The allegations concern the timing of a recall election against Supervisor Marshall.

The Complaint

The complaint alleged: Supervisors Marshall, Rose and Schwartz opposed the recall. They believed that Marshall would have a better chance of success if the recall election was held during the general…