North Dakota Supreme Court
Haskell v. Grand Forks Public Schools
February 12, 20262026 ND 40
Summary
The court affirmed that the School Board did not waive the attorney-consultation exemption, properly invoked the exemption, and did not violate Haskell's due process rights by withholding the executive-session transcript during in camera review. It nevertheless held that the district court abused its discretion by granting summary judgment without independently reviewing the 27-minute recording to determine whether the executive session exceeded the exemption's scope. The judgment and costs award were reversed in part, and the case was remanded for in camera review and further proceedings.