Probably not. The OPMA’s open public meeting requirements apply to governing body meetings involving action. RCW 42.30.020(3) broadly defines “action” as transacting official agency business, and it includes things like governing body “considerations,” “discussions,” and “reviews.” Required OPMA training is within the agency’s official business, and it arguably involves governing body members considering, discussing and reviewing the training information and materials they receive.
The Citizens Alliance (2015) case holds that governing bodies do not violate the OPMA by passively receiving information. But members of a governing body are perhaps unlikely to stay completely silent during required OPMA training with no questions, discussions, etc. (and in any event doing so may further defeat the training’s purpose). RCW 42.30.110 also sets forth permitted executive session bases which do not include receiving general legal training.
Based on the above, OPMA training sessions attended by a governing body quorum or more should be held in public session. Alternatively, agencies can give non-public training sessions to the governing body members in sub-quorum groups or individually. RCW 42.30.205(3) allows for remote and internet-based training that might make it easier to facilitate separate training sessions.
