Under the Sunshine Act, the gathering of nine of City Council's 17 current members constitutes a quorum, which would require the meeting to be open to the public if official business is discussed.
Clarke described the luncheon as a chance for current and elected members to get to know each other, and insisted beforehand that no official business would be conducted.
"There is no official city business being discussed at this event, period," Clarke said. "It's the first time that the 2012 class will have an opportunity to just sit in a room and just kind of bond."
Days before the lunch, three members said there would be some discussion of official business, but after the meeting members said they chatted about the holidays and the latest happenings in Harrisburg.
Reynolds Brown said that the lunch is part of a tradition that occurs roughly every term and that members should be able to have social gatherings together.
"It's unfortunate if Council members cannot sit down and enjoy lunch together [regardless of how many members are present]," she said. "Councilman Clarke made it clear there was not going to be any formal business discussed - we're not going to discuss committee assignments; we're not going to discuss budgets."
But some watchdogs note that, since the public was excluded, only Council knows what was discussed.
"At the end of the day, we will never know if official business was discussed," said Terri Mulcher, executive director of the Pennsylvania Office of Open Records. "For someone to suggest a lunch is just a lunch when you're a public official, that's a hard sell to the public."
Melissa Melewski, media-law counsel for the Pennsylvania Newspaper Association, echoed Mulcher's sentiments.
"It certainly raises the question as to whether the Sunshine Act was followed," Melewski said. "It's very easy for officials to stray into discussions of official business. If it's purely social, that would be fine."
Ellen Kaplan, of the watchdog group the Committee of Seventy, said, however, that the meeting was not a cause for concern, and assumed that it had been simply a social gathering.