The consultation of as few as two individuals may create a “meeting” if two individuals create a quorum. See Thomas v. Township of Cherry, 722 A.2d 1150, 1153 (Pa. Commw. Ct. 1999) (stating “that a ‘meeting’ took place as contemplated by the Sunshine Act when the two [Board] members got together albeit without notice to the third”).
Pennsylvania's Constitution has no shield law provision. Although Pennsylvania's Constitution protects every citizen's right to "freely speak, write and print on any subject," Pa. Const. art. I, § 7, Pennsylvania courts have not held that it protects reporters from disclosing their sources. SeeIn reTaylor, 193 A.2d 181, 184 (Pa. 1963).
The scope of records covered by the Act does not “supersede or modify the public or nonpublic nature of a record or document established in Federal or State law, regulation or judicial order or decree.” Section 306. Elsewhere the Act makes the same point clear: “If the provisions of this Act regarding access to records conflict with any other federal or state law, the provisions of this Act shall not apply.” Section 3101.1. In other words, if some other Pennsylvania or federal statute, regulation or order requires or prohibits access, the Act does not change that.
There is no requirement that an agency provide individualized written notice to a person whose business with an agency will be conducted at a particular meeting. See Sheetz, Inc. v. Phoenixville Borough Council, 804 A.2d 113 (Pa. Commw. Ct. 2002).