JUSTICE APPLETON delivered the opinion of the court:

In these two cases consolidated in the trial court,plaintiff, Dr. Deloris Henry, sued seven members of the board ofeducation of Champaign Community Unit School District No. 4. Shealleged that on October 29 and 30, 2002, they violated section 2aof the Open Meetings Act (Act) (5 ILCS 120/2a (West 2002)) byholding closed meetings without first citing any statutoryexception to the requirement of open meetings. The parties filedcross-motions for summary judgment, and the trial court granteddefendants' motion in both cases. Plaintiff appeals, arguingthat as a matter of law, defendants violated section 2a.

We find no violation in the meeting of October 29. Inthe meeting of October 30, however, defendants announced theywere closing the meeting to the public to discuss potentiallitigation. They never found, however, that the litigation wasprobable or imminent. Nor did they state a basis for any suchfinding. These omissions violated sections 2a and 2(c)(11) ofthe Act (5 ILCS 120/2a, 2(c)(11) (West 2002)). Therefore, weaffirm the trial court's judgment in part, reverse it in part,and remand this case for consideration of remedies.

I. BACKGROUND

In a meeting on October 29, 2002, the school boardvoted to go into closed session "to discuss an employee matter,specifically the reclassification of employment." The employeewas plaintiff.

On October 30, 2002, plaintiff filed a complaint incase No. 02-CH-287, alleging that on October 29, defendants hadviolated section 2a of the Act. Section 2a provides:

"The vote of each member on the question ofholding a meeting closed to the public and acitation to the specific exception containedin [s]ection 2 of this Act which authorizesthe closing of the meeting to the publicshall be publicly disclosed at the time ofthe vote and shall be recorded and enteredinto the minutes of the meeting." (Emphasisadded.) 5 ILCS 120/2a (West 2002).

According to plaintiff, the reference to "an employee matter" orthe "reclassification of employment" was not "a citation to [any]specific exception" in section 2(c) of the Act (5 ILCS 120/2(c)(West 2002)).

On October 30, 2002, the school board convened again,and its president, Scott Anderson, stated:

"PRESIDENT ANDERSON: The motion to approve the agenda, which includes employmentmatters regarding classification of employee,potential litigation, as well as negotiationsdiscussion, all in executive session. I needa motion.

BOARD MEMBER KLAUS: So move.

PRESIDENT ANDERSON: So moved by Mr. Klaus.

BOARD MEMBER VAN NESS: Second.

RESIDENT ANDERSON: Second by Mr. VanNess. All in favor?

(Those in favor so indicated in the affirmative.)

PRESIDENT ANDERSON: Opposed?

(No response.)

* * *

PRESIDING OFFICER ANDERSON: I need amotion to go into executive session for anemployment matter regarding a reclassification of employee.

BOARD MEMBER WAMPLER: So move.

BOARD MEMBER STORCH: Second.

PRESIDING OFFICER ANDERSON: As well asa contested litigation matter as well asnegotiations discussions.

BOARD MEMBER WAMPLER: So move.

BOARD MEMBER STORCH: Second." (Emphases added.)

Again, the employee was plaintiff.

On November 12, 2002, plaintiff filed a complaint incase No. 02-CH-300, alleging that defendants had violated section2a in the October 30 meeting by "failing and refusing to cite toa specific exception and by combining into a singular closedsession unrelated matters."

In the hearing on the cross-motions for summary judgment, the trial court reasoned that if the legislature hadintended to require a "statutory citation," it would have usedthose words. Instead, it required "a citation to the specificexception." 5 ILCS 120/2a (West 2002). In the court's view, thewords "employee matter" and "reclassification of employment" werea clear citation to the "employment" exception in section 2(c)(1)of the Act (5 ILCS 120/2(c)(1) (West 2002)). Although an additional citation to the statute itself might have been judiciallyhelpful, to hold it was essential to a valid citation would have"exalt[ed] form over substance." Because defendants had disclosed the substance of the applicable exception, the courtgranted their motion for summary judgment.

This appeal followed.

II. ANALYSIS

A. Meeting of October 29, 2002

Section 2(a) sets down two conditions for holding aclosed meeting. The first condition is substantive: the meetingmust fall into one of the 23 exceptions listed in section 2(c) (5ILCS 120/2(c) (West 2002)). 5 ILCS 120/2(a) (West 2002). Theseexceptions "shall be strictly construed against closed meetings." 5 ILCS 120/1(2) (West 2002). The second condition is procedural: the public body must close the meeting "in accordance with[section 2a]" (5 ILCS 120/2a (West 2002)). 5 ILCS 120/2(a) (West2002). Section 2a requires the public body to vote on whether toclose the meeting to the public (the meeting need not be closed,even if it falls into one of the exceptions in section 2(c)). 5ILCS 120/2a (West 2002). Section 2a further requires the publicbody, at the time of the vote, to "cit[e] to the specific exception[,] contained in section 2 of this Act[,] which authorizesthe closing of the meeting to the public" and to record thatcitation in the minutes of the meeting. 5 ILCS 120/2a (West2002).

Plaintiff argues "there was no citation to the[s]tatute[,] as required by [s]ection 2a[,] prior to a declaration being made that the [b]oard was going into closed session." (Emphasis added.) As the trial court correctly observed, however, section 2a does not require a citation to the statute; itrequires "a citation to the specific exception contained in" thestatute (5 ILCS 120/2a (West 2002)). To "cite" an exceptionmeans to quote it or call attention to it. See Merriam-Webster'sCollegiate Dictionary 208 (10th ed. 2000). One of the exceptionsin section 2(c) is "[t]he *** employment *** of specific employees of the public body, including hearing testimony on a complaint lodged against an employee to determine its validity." 5ILCS 120/2(c)(1) (West 2002). By referring to an "employeematter" and "reclassification of employment," defendants adequately identified the exception in section 2(c)(1). An additional citation to the statutory subsection might have beenhelpful but was not required. Citing the exception was sufficient.

"It is also notable," plaintiff argues, "that theexception set forth in [section 2(c)(1)] relating to the employment or dismissal of specific employees of the public bodypermit[s] hearing testimony only on a disciplinary complaint."(Emphasis added.) That is not what section 2(c)(1) says. Rather, it says: "A public body may hold closed meetings toconsider *** [t]he *** employment *** of specific employees ofthe public body, including hearing testimony on a complaintlodged against an employee to determine its validity." (Emphasisadded.) 5 ILCS 120/2(c)(1) (West 2002). "Including" is anonrestrictive word. In any event, if plaintiff means to implythat defendants never provided her with a disciplinary complaint,she fails to cite any evidentiary materials in support of thatimplication. See Official Reports Advance Sheet No. 21 (October17, 2001), R. 341(e)(6), eff. October 1, 2001 ("appropriatereference to the pages of the record on appeal"); Carruthers v.B.C. Christopher & Co., 57 Ill. 2d 376, 380, 313 N.E.2d 457, 459(1974) ("if such issues are not further supported by evidentiaryfacts through affidavits or such, summary judgment is thenappropriate").

In our de novo review (see Harrison v. Hardin CountyCommunity Unit School District No. 1, 197 Ill. 2d 466, 470-71,758 N.E.2d 848, 851 (2001)), we find no violation of the Act inthe meeting of October 29, 2002. We affirm the summary judgmentin defendants' favor and the denial of plaintiff's motion forsummary judgment as to the October 29 meeting in case No. 02-CH-287.

B. Meeting of October 30, 2002

The same reasoning applies to the meeting of October30, 2002: by referring to "an employment matter regarding areclassification of an employee," defendants clearly invoked theexception in section 2(c)(1).

In the October 30 meeting, however, defendants violatedthe Act by invoking an additional exception to the requirement ofopen meetings without following through with the conditionsattached to that exception. By using the word "litigation," theyclearly evinced their intention to invoke the "litigation"exception in section 2(c)(11). (One must understand "negotiations" to mean "negotiations regarding the litigation.") Section2(c)(11) reads as follows:

"Litigation, when an action against,affecting[,] or on behalf of the particularpublic body has been filed and is pendingbefore a court or administrative tribunal, orwhen the public body finds that an action isprobable or imminent, in which case the basisfor the finding shall be recorded and enteredinto the minutes of the closed meeting." 5ILCS 120/2(c)(11) (West 2002).

Thus, the "litigation" exception is a forked path. Ifthe litigation has been filed and is pending, the public bodyneed only announce that in the proposed closed meeting, it willdiscuss litigation that has been filed and is pending. If thelitigation has not yet been filed, the public body must (1) findthat the litigation is probable or imminent and (2) record andenter into the minutes the basis for that finding. Evidently,the legislature intended to prevent public bodies from using thedistant possibility of litigation as a pretext for closing theirmeetings to the public.

When announcing the agenda of the October 30 meeting,Anderson, the president of the school board, characterized thelitigation as merely "potential." Shortly afterward at the timeof the vote on whether to close the meeting to the public, hedescribed the litigation as a "contested litigation matter." Tojudge from the transcript of the October 30 meeting, which isattached to the complaint in case No. 02-CH-300, defendants neverexplicitly found that litigation was probable or imminent, andnever expressed any basis for such a finding, before going intoclosed session. Arguably, litigation must be filed and pendingto be "contested." But in the phrase "contested litigationmatter," it is unclear whether "contested" modifies "litigation"or "matter." Anderson never disavowed his earlier statementabout the potentiality of the litigation.

Keeping in mind that the exceptions to the requirementof open meetings are to be strictly construed (see 5 ILCS120/1(2) (West 2002)), we hold that defendants failed to dispelthe initial impression that litigation was, as of yet, potentialrather than filed and pending. Strict construction leaves noroom for ambiguity in the announcement of exceptions. Becausethe school board, through its president, announced to the publicthat "potential litigation" would be one of the topics of discussion in the closed meeting, the board violated the Act by failingto state, on the record, (1) a finding that litigation wasprobable or imminent and (2) a basis for such a finding. See 5ILCS 120/2(c)(11) (West 2002).

The school board could have closed the October 30meeting solely in reliance on the "employment" exception insection 2(c)(1) (5 ILCS 120/2(c)(1) (West 2002)). But the boardalso cited the exception for potential litigation. See 5 ILCS120/2(c)(11) (West 2002). It is unclear from the record whatthis potential litigation was or whether the board even discussedit in the closed meeting. Case No. 02-CH-287, which plaintifffiled on October 30, 2002, was the only litigation pending as ofthat date. As that lawsuit concerned only the board's allegedviolation of the Act, it was in no way germane to the question ofplaintiff's employment. As the board failed to announce whatlitigation was to have been discussed, pending or potential, weare unable to assume that the litigation under discussion by theboard was case No. 02-CH-287. Regardless of whether defendantsactually discussed "litigation" in the closed meeting of October30, 2002, they violated the procedural requirement of section 2aby announcing their intention to discuss an impermissible topicin the closed meeting (i.e., potential litigation concerningwhich they had not made the requisite findings).

We hold that the trial court erred in entering summaryjudgment in defendants' favor on the complaint in case No. 02-CH-300. Rather, the court should have entered summary judgment inplaintiff's favor in that case. See Arangold Corp. v. Zehnder,187 Ill. 2d 341, 358, 718 N.E.2d 191, 201 (1999) (if the partiesfiled opposing motions for summary judgment on the same claimsand issues and the trial court denied one motion and granted theother, the appellate court may review the denial).

For the foregoing reasons, we affirm the trial court'sjudgment in part (No. 02-CH-0287), reverse it in part (No. 02-CH-0300), and remand this case for consideration of remedies (No.02-CH-0300).

Affirmed in part and reversed in part; case remanded.

TURNER and STEIGMANN, JJ., concur.