The so-called "litigation" exception, Mo.Rev.Stat. § 610.021(1), encompasses more than litigation. The following information is considered closed:
· records relating to legal actions, causes of action, or litigation involving a public governmental body; and
· confidential or privileged communications between a public governmental body or its representatives and its attorneys; and
· legal work product. See Librach v. Cooper, 778 S.W.2d 351, 353-354 (Mo.Ct.App. 1989) (held settlement agreement between board of education and superintendent of school district was not a confidential or privileged communication between a public governmental body and its attorneys).
Mere reference to litigation is not sufficient to trigger this exception. See Tipton v. Barton, 747 S.W.2d 325, 330 (Mo.Ct.App. 1988) (litigation exception applies to analytical work product, but not to general descriptions of legal services rendered appearing on city attorney's itemized monthly billing statements). After final disposition of a litigation matter, any vote relating to that litigation involving a public governmental body must be made public. Mo.Rev.Stat. § 610.021(1).
Upon final disposition of litigation involving a public governmental body, the body must make public its minutes of closed meetings and its votes. Other confidential or privileged communications and legal work product may remain closed. Mo.Rev.Stat. § 610.021(l).
When a public governmental body is undertaking to exercise the power of eminent domain, the vote must be made public immediately following the action on the motion to authorize institution of a condemnation action. Id.