People v. Radojcic

Illinois Appellate Court
Criminal Court
Attorney-Client Privilege
Citation
Case Number: 
2012 IL App (1st) 102698
Decision Date: 
Wednesday, May 2, 2012
District: 
1st Dist.
Division/County: 
Cook Co., 3rd Div.
Holding: 
Reversed and remanded.
Justice: 
NEVILLE
Before court excludes testimony from attorney because of attorney-client privilege, court must consider whether party seeking to use it has made sufficient showing to give court reason to question witnesses in camera, to determine whether privilege applies. State presented testimony giving reasonable cause to suspect that client used communications with his attorney to advance his attempts to commit crimes or fraud, and thus attorney-client privilege does not preclude testimony from attorney. (STEELE and SALONE, concurring.)