Paul Dubé

The Ombudsman of Ontario investigated a complaint regarding closed meetings held by the council for the Municipality of Calvin on August 12, November 25, and December 16, 2025.

The Ombudsman found that the council contravened section 239(4) of the Municipal Act, 2001 by failing to include a description of the general nature of the matters to be discussed in its resolutions to proceed into closed session.

Furthermore, the council contravened its own procedure by-law by failing to report back to the public the general nature of the matters discussed upon returning to open session.

The Ombudsman recommended that the council ensure future resolutions and reports back include sufficient descriptions of the items discussed.

The Ombudsman investigated complaints regarding five closed meetings held by the Township of Douro-Dummer.

The Ombudsman found that the Township provided adequate public notice for an emergency meeting and properly discussed a matter under the solicitor-client privilege exception.

However, the Township contravened the Municipal Act, 2001 by failing to state by resolution the general nature of the matters to be considered in camera at four meetings.

The Ombudsman recommended that the Township ensure resolutions provide a general description of issues to be discussed and encouraged the keeping of comprehensive minutes and audio/video recordings of closed sessions.

The Ombudsman investigated complaints regarding closed meetings held by the Region of Waterloo's council and committees.

The Ombudsman found that a closed session discussion on December 13, 2023 regarding the potential acquisition of land fit within the open meeting exception for the acquisition or disposition of land, as it involved an actual proposed transaction and financial arrangements that could affect the municipality's bargaining position.

However, the Ombudsman determined that two resolutions to move into closed session contravened section 239(4)(a) of the Municipal Act, 2001 because they only cited the exception for solicitor-client privilege and failed to provide a description of the general nature of the matters to be discussed.

The Ombudsman investigated a complaint regarding an emergency meeting held by the Township of Coleman council on July 15, 2025.

The Ombudsman found that the meeting did not qualify as an emergency under the Township's procedure by-law, meaning public notice should have been provided.

Furthermore, the Township's procedure by-law failed to provide for public notice of special meetings, contravening the Municipal Act, 2001.

Regarding the closed session, the Ombudsman determined that the discussion did not fit the cited exception for advice subject to solicitor-client privilege, as no legal advice was received or discussed.

However, the discussion did fit the exception for personal matters about an identifiable individual, as council scrutinized the performance of specific lawyers.

The Ombudsman investigated a complaint regarding three meetings held by the council for the Township of Sables-Spanish Rivers.

The Ombudsman found that a closed session discussion on February 28, 2024, regarding a private dispute between residents, fit within the open meeting exception for personal matters.

An informal gathering of four council members prior to a January 8, 2025 meeting was found not to constitute a 'meeting' under the Municipal Act, 2001.

Finally, a closed session discussion on February 26, 2025, concerning a dispute between two council members, fit within the personal matters exception, but the council contravened section 239(4) of the Act by failing to include this topic in its resolution to proceed into closed session.

The Ombudsman investigated a complaint regarding closed meetings held by the City of Elliot Lake council on May 1 and May 15, 2023, and December 2, 2024.

The Ombudsman found that the May 2023 meetings, closed under the education or training exception to discuss the City's strategic plan, contravened the Municipal Act, 2001 because the discussions materially advanced council business.

Council also failed to state the general subject matter in its resolutions and failed to keep complete minutes for those meetings.

However, the December 2024 closed meeting did not contravene the Act, as the discussions fit within the exceptions for education or training, personal matters about an identifiable individual, and advice subject to solicitor-client privilege.

The Ombudsman investigated a complaint regarding a closed meeting held by the council for the Town of Hawkesbury to receive a presentation from consultants on the Town's new strategic plan.

The council relied on the education or training exception under section 239(3.1) of the Municipal Act, 2001.

The Ombudsman found that the exception did not apply because the council discussed particular issues affecting the municipality in a way that materially advanced its business or decision-making.

The Ombudsman concluded that the council contravened the Act and made recommendations to improve compliance.

The Ombudsman investigated a complaint regarding closed meetings held by the Town of Cobalt's 2025 Budget Advisory Group.

The investigation determined that the advisory group met the definition of a committee under the Municipal Act, 2001, as at least 50% of its members were council members.

Consequently, the group was required to comply with open meeting rules, including providing public notice and conducting business in open session.

The Ombudsman found that the meetings held on March 6, March 27, and April 23, 2025, were improperly closed to the public and made recommendations to ensure future compliance.

The Ombudsman investigated a complaint alleging that the Township of Strong council contravened the open meeting rules in the Municipal Act, 2001 by discussing a council member's conduct in a closed session.

The Ombudsman found that portions of the discussion involved unsubstantiated allegations and were personal in nature, fitting the exception for personal matters about an identifiable individual under section 239(2)(b).

Although other portions concerned professional conduct that did not fit the exception, the Ombudsman concluded that parsing the intertwined topics would have detracted from free and uninterrupted discussion.

Therefore, the entire closed session was permitted and no contravention occurred.

The Ombudsman investigated complaints regarding meetings held by the Township of Bonfield's council and committees.

The Ombudsman found that an email and sequential one-on-one phone calls between council members prior to a meeting did not constitute an illegal closed meeting, as they did not materially advance council business.

A closed session of the Corporate Services Committee was found to be permitted under the solicitor-client privilege exception, as the committee received confidential legal advice regarding a draft by-law.

However, the Ombudsman found that the Township violated the open meeting rules by failing to provide public notice for three meetings in accordance with its procedural by-law, attributing the failure to administrative oversight.

The Ombudsman investigated a complaint regarding a closed meeting held by the London Transit Commission on February 28, 2024.

The Commission discussed receiving training from the integrity commissioner and recording future meetings, which was intertwined with discussions about the personal conduct of identifiable Commissioners.

The Ombudsman found the discussion fit within the exception for personal matters about an identifiable individual.

However, the Commission contravened the Municipal Act, 2001 by failing to include the general subject matter in its resolution to enter closed session and by failing to have a procedure by-law in place at the time of the meeting.

The Ombudsman investigated a complaint that the Township of Lake of Bays council held an improper closed meeting on September 10, 2024, to discuss a Road License Agreement program.

The Ombudsman found that a brief portion of the closed session regarding a potential Integrity Commissioner complaint and Freedom of Information requests did not fit within the exception for personal matters and should have been discussed in open session.

However, the remainder of the closed session discussion regarding the road allowance program was properly held in camera under the exceptions for advice subject to solicitor-client privilege and the acquisition or disposition of land.

The Ombudsman investigated a complaint regarding closed meetings held by the Town of Essex council on four dates in 2024.

The investigation found that the closed session discussions fit within various open meeting exceptions under the Municipal Act, 2001, including those for the acquisition or disposition of land, solicitor-client privilege, and information supplied in confidence by a third party.

However, the Ombudsman determined that the Town contravened the Act by failing to state by resolution the general nature of the subject matter to be discussed prior to entering each closed session.

Recommendations were made to improve the Town's compliance and record-keeping practices.

The Ombudsman investigated a complaint that the Committee of the Whole for the Township of Ramara held illegal closed meetings via email on October 23 and 24, 2024.

The Ombudsman found that the October 23 email, which contained information that directly resulted in the removal of a food waste program from the budget, materially advanced municipal business and constituted an illegal closed meeting.

The October 24 email, which merely requested a topic be added to a future agenda, was procedural in nature and did not constitute a meeting.

The Ombudsman investigated a complaint alleging that the council for the Township of Frontenac Islands held an illegal closed meeting via email.

The investigation found that a quorum of council participated in two email threads on August 15 and 16, 2024, discussing a delegation letter to the Minister of Health.

The Ombudsman concluded that these email exchanges materially advanced council business and decision-making, thereby constituting a meeting that contravened the open meeting requirements of the Municipal Act, 2001.

The Ombudsman investigated a complaint regarding a closed meeting held by the City of Kitchener council on August 14, 2023, to discuss a centralized model for arts and entertainment facilities.

The Ombudsman found that the closed session was permitted under the Municipal Act, 2001, as the discussion involved information supplied in confidence by a third party, labour relations, and plans for negotiations.

Although some parts of the discussion did not fit within the exceptions, they could not realistically be parsed from the protected information.

The Ombudsman concluded that the council did not contravene the open meeting rules.

The Ombudsman investigated complaints regarding several closed meetings held by the council for the Township of Russell in 2023 and 2024.

The complaints alleged that council improperly discussed matters in camera, including a costing update for a recreation complex, a verbal update on a sports dome, and land transactions, and failed to livestream the open portions of meetings following closed sessions.

The Ombudsman found that all the in camera discussions fit within the open meeting exceptions under the Municipal Act, 2001, specifically the exceptions for plans and instructions for negotiations, and the acquisition or disposition of land.

The Ombudsman also found no contravention regarding the livestreaming practice, as the meetings remained open to the public in person, though he recommended clarifying the livestreaming policy on the Township's website.

The Ombudsman investigated a complaint alleging that five council members for the City of Greater Sudbury held an illegal closed meeting when they attended a meeting of the Flour Mill Community Action Network.

The Ombudsman found that while the five members constituted a quorum of the City's Operations Committee, they did not materially advance the business or decision-making of the committee.

Therefore, the gathering did not constitute a meeting under the Municipal Act, 2001, and no violation of the open meeting rules occurred.

The Ombudsman investigated a complaint alleging that the council for the Township of The North Shore held illegal closed meetings following a regular council meeting and via group text messages.

The investigation found that while a quorum of council was present during an in-person discussion and in the group text messages, these interactions did not constitute 'meetings' under the Municipal Act, 2001.

The discussions did not materially advance the business or decision-making of council, as no concrete actions were taken and the Mayor had unilateral authority under the procedure by-law to cancel the meetings in question.

The Ombudsman concluded that the open meeting rules were not contravened.

The Ombudsman investigated a complaint regarding a strategic planning session held in a closed meeting by the City of Cornwall council.

The council cited several exceptions under the Municipal Act, 2001 to justify the closed session.

The Ombudsman found that the discussions, which involved general strategic planning, potential land acquisitions, and brief mentions of staffing, did not fall within any of the cited open meeting exceptions.

The Ombudsman concluded that the council contravened the Act and made recommendations to improve future compliance.