One Culpeper paper has this article about the resolution in favor of a Virginia county in a Freedom of Information Act case brought by another Culpeper paper, challenging the propriety of a closed meeting by the county board of supervisors.
Interestingly, a rationale for the closed meeting was the county's adversarial position in relation to the country school board over the construction of a new high school.
The article also says: "A relatively new element of FOIA states that motions to convene closed sessions must identify the subject matter to be discussed, as well as the purpose of the meeting. The provision further states that a 'general reference' to the subject matter is not sufficient." The court ruled that the identification of the subject matter requirement had not been violated, partly because there are no precedents applying this requirement. Va. Code 2.2-3712 says: "A. No closed meeting shall be held unless the public body proposing to convene such meeting has taken an affirmative recorded vote in an open meeting approving a motion that (i) identifies the subject matter, (ii) states the purpose of the meeting and (iii) makes specific reference to the applicable exemption from open meeting requirements provided in § 2.2-3707 or subsection A of § 2.2-3711."
On this point, the FOIA advisory council has explained: "The subject need not be so specific as to defeat the reason for going into closed session, but should at least provide the public with general information as to why the closed session will be held. For example, a public body might state that the subject of a closed session would be a discussion of disciplinary action against a employee, which goes a step beyond just stating that the purpose of the meeting is to consider a personnel matter." Opinion for Lucy Phillips, AO-45-01.