No specific provision, but “meeting” is defined as “the convening of a quorum of a public body,” so text messaging between persons could be subject to the Open Meetings law only if the people exchanging messages constituted a quorum of the public body.
There is no statutory or case law concerning text messages, specifically, but the Attorney General has opined that sequential electronic discussions could be considered meetings under the FOIA. Ark. Op. Att’y Gen. No. 2008-055.
There are no decisions on whether text messages constitute a meeting, but the purpose of the public meetings law is broad and would prevent the use of electronic means to hold meetings. “It is further the intent of the Legislature that clandestine meetings, conferences or meetings held on private property without proper notice and ample opportunity for attendance by the public not be used to defeat the purposes of this subchapter.” 1 M.R.S.A. § 401.
Use of text messaging by a majority of the legislative body, either directly or through intermediaries, “to discuss, deliberate, or take action on any item of business that is within the subject matter jurisdiction of the legislative body” would violate the Brown Act. Cal. Gov't Code § 54952.2(b).