Illinois Supreme Court
Criminal Court
Attorney-Client Privilege
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.)