Not all court litigation and legislative activity since 1974 has favored open meetings at the state level, but there seems to be a trend toward increasing the public access allowed by state courts and legislatures. This paper reviews state supreme court decisions, lower court rulings, and state legislative activities that have affected the interpretation of state "sunshine laws." The paper concludes that, in spite of increased legislative and judicial activity concerning open meetings, many frustrating situations still confront reporters attempting to cover meetings of public bodies. (RL)