People v. Radojcic

Illinois Supreme Court
Criminal Court
Citation
Case Number: 
2013 IL 114197
Decision Date: 
November 21, 2013
District: 
1st Dist.
Division/County: 
Cook Co.
Justice: 
THEIS
Holding: 
Appellate court affirmed.
Crime-fraud exception to attorney-client privilege applies to allow attorney to testify as to communications with his former client at that former client's criminal trial. Grand jury testimony satisfied State's burden to provide reasonable basis to suspect that client's communications with attorney, to extent related to real estate transactions in indictment, were in furtherance of mortgage fraud scheme. In camera review is not required in every case where crime-fraud exception is at issue. (GARMAN, FREEMAN, THOMAS, KILBRIDE, KARMEIER, and BURKE, concurring.)