Preven

*928 This appeal concerns the statutory interpretation of one of the public comment requirements of California's open meeting law, the Ralph M. Brown Act, Government Code section 54950 et seq. 1 Appellant Eric Preven exercised his opportunity to address a meeting of the Los Angeles City Council's Planning and Land Use Management Committee (PLUM). He was then denied the opportunity to address the full city council when it held a special meeting the next day to discuss, among other things, the recommendation arrived at by the PLUM committee.

*929 Asserting the City of Los Angeles's (City) refusal to let him address the special city council meeting was part of a larger pattern of Brown Act violations, Preven sent a cease and desist demand letter to the City. When the City failed to respond to that letter, he filed a petition for a writ of mandate and complaint for declaratory relief to enforce the Brown Act. He further brought a second claim based on the California Public Records Act. ( (CPRA); § 6250 et seq.)

In response to the petition, the City argued the Brown Act requires only the opportunity to address a special meeting of a legislative body before it takes action. Since…