C. Court mandated opening, closing.

The court's powers with regard to open meetings are powers of enforcement under the OML. N.Y. Pub. Off. Law § 107(1) (McKinney 1988) ("any aggrieved person shall have standing to enforce the provisions of this article against a public body by the commencement of a proceeding pursuant to article seventy-eight of the civil practice law and rules, and/or an action for declaratory judgment and injunctive relief").

Under the language of the OML, the court, in its discretion and upon good cause shown, may declare void any action taken in violation of the statute. N.Y. Pub. Off. Law § 107(1) (McKinney 1988). The court also may order future meetings open to the public, enjoin a public body from proceeding contrary to the provisions of the OML, and use its contempt powers for persistent violations of the law. See, e.g., Goetschius v. Bd. of Educ. of Greenburgh Eleven Union Free Sch. Dist., 281 A.D.2d 416, 721 N.Y.S.2d 386 (2d Dep't 2001) (The intermediate appellate court interpreted the Open Meetings Law liberally in accordance with the statute's purposes and concluded that a school district's Board of Education had engaged in a persistent pattern of deliberately violating its letter and spirit by improperly convening executive sessions and conducting official business in a manner inaudible to the public audience. Accordingly, the appellate court affirmed the trial court's annulment of the Board's determinations made in violation of the Open Meetings Law and also upheld an award of attorneys' fees to petitioners.); Orange County Publications v. County of Orange, 120 A.D.2d 596, 502 N.Y.S.2d 71 (2d Dep't 1986), appeal dismissed, 68 N.Y.2d 807, 498 N.E.2d 437, 506 N.Y.S.2d 1037 (1986) ("inasmuch as the respondents have been directed to comply with the OML by court orders, we find the respondents, in their persistent dereliction of the mandates of the statute, to be in contempt of court"); Orange County Publications v. County of Orange, No. 5686/78 (Sup. Ct., Orange County, Dec. 26, 1978) (enjoining the Orange County legislature from convening any executive session without first complying with the OML and further enjoining the legislature from excluding the public and press from meetings except legitimately convened executive sessions).