From the Wisconsin State Journal newspaper:

Many Madison City Council members send and receive emails and texts during meetings, and the city requires all of it to be kept as a public record. Some want to explore new rules because such communications can create the possibility of open meetings violations and, if not illegal, still allow a channel of communications unseen by the public in real time.

Full article.

See resources at right for 1) sample California local policies addressing this issue, 2) staff analysis of issues and practices relating to electronic agendas, and 3) an Institute whitepaper and Powerpoint exploring the intersections between technology and public agency meetings.