{
 "topic": "OMA section 2.06(d)",
 "statute": "5 ILCS 120/2.06(d)",
 "family": "Minutes and verbatim recordings",
 "page": "https://illinoisfoia.org/issues/oma-2-06-d/",
 "note": "Determination letters are non-binding. Verify against the source PDF before citing.",
 "counts": {
  "violation_found": 1,
  "no_violation": 2,
  "no_determination": 2,
  "other": 0
 },
 "challenge_notes": {
  "generated_by": "AI summary of the decisions listed on this page; not legal advice; verify each decision against its PDF",
  "when_a_challenge_is_strong": [
   {
    "text": "The public body completely failed to conduct any semi-annual review of closed session minutes and did not report in open session.",
    "why": "Section 2.06(d) of the Open Meetings Act requires at least a semi-annual review of all closed session minutes and an open-session report on continued confidentiality; total failure is a violation.",
    "decisions": [
     {
      "title": "A committee's failure to review closed session minutes",
      "url": "https://illinoisfoia.org/opinions/letter-52812/#issue-1"
     }
    ]
   }
  ],
  "when_the_body_usually_wins": [
   {
    "text": "The public body conducted a review, even if the manner was informal or the time spent was brief.",
    "why": "The Act does not prescribe a specific procedure or amount of time for the review; it only mandates that a review occur.",
    "decisions": [
     {
      "title": "A village council's review of closed-session minutes",
      "url": "https://illinoisfoia.org/opinions/letter-80205/#issue-1"
     },
     {
      "title": "A county board's review of closed session minutes and recordings",
      "url": "https://illinoisfoia.org/opinions/letter-69534/#issue-1"
     }
    ]
   },
   {
    "text": "The public body acknowledges a past failure but has already scheduled or initiated the required review.",
    "why": "Once the body takes steps to perform the semi-annual review, the issue is considered resolved and no further violation is found.",
    "decisions": [
     {
      "title": "A board's meeting minutes and vote documentation",
      "url": "https://illinoisfoia.org/opinions/letter-87758/#issue-1"
     },
     {
      "title": "A committee's failure to review closed session minutes",
      "url": "https://illinoisfoia.org/opinions/letter-52812/#issue-2"
     }
    ]
   }
  ],
  "points_to_put_in_the_letter": [
   {
    "text": "State that the Open Meetings Act requires the public body to review all closed session minutes at least every six months and to report in open session whether confidentiality is still needed.",
    "why": "",
    "decisions": [
     {
      "title": "A committee's failure to review closed session minutes",
      "url": "https://illinoisfoia.org/opinions/letter-52812/#issue-1"
     }
    ]
   },
   {
    "text": "If the body claims it already conducted a review, ask it to produce the minutes of the open meeting where the review was reported.",
    "why": "",
    "decisions": [
     {
      "title": "A committee's failure to review closed session minutes",
      "url": "https://illinoisfoia.org/opinions/letter-52812/#issue-1"
     }
    ]
   }
  ],
  "facts_to_gather": [
   "Whether the public body’s meeting minutes or agendas from the past six months show any report on the review of closed session minutes."
  ],
  "common_mistakes": [
   {
    "text": "Arguing that the public body’s review was not thorough or took too little time.",
    "why": "",
    "decisions": [
     {
      "title": "A village council's review of closed-session minutes",
      "url": "https://illinoisfoia.org/opinions/letter-80205/#issue-1"
     },
     {
      "title": "A county board's review of closed session minutes and recordings",
      "url": "https://illinoisfoia.org/opinions/letter-69534/#issue-1"
     }
    ]
   },
   {
    "text": "Believing that the Open Meetings Act prescribes a specific manner or procedure for the semi-annual review.",
    "why": "",
    "decisions": [
     {
      "title": "A village council's review of closed-session minutes",
      "url": "https://illinoisfoia.org/opinions/letter-80205/#issue-1"
     },
     {
      "title": "A county board's review of closed session minutes and recordings",
      "url": "https://illinoisfoia.org/opinions/letter-69534/#issue-1"
     }
    ]
   }
  ],
  "caution": "Determination letters are non-binding; outcomes depend on the specific facts, and you should always verify the full text of the decision."
 },
 "issues": [
  {
   "issue": "Failure to conduct semi-annual review of closed session minutes",
   "outcome": "no_determination",
   "rule": "Public bodies must periodically review closed session minutes every six months; the Board acknowledged failure but has since scheduled the review, resolving the issue.",
   "decision": {
    "title": "A board's meeting minutes and vote documentation",
    "date": "2025-12-12",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-87758/"
   },
   "authorities": []
  },
  {
   "issue": "Closed session minutes review procedure under OMA",
   "outcome": "no_violation",
   "rule": "OMA requires periodic review of closed session minutes but does not prescribe the manner of review or require a specific amount of time for review.",
   "decision": {
    "title": "A village council's review of closed-session minutes",
    "date": "2024-03-05",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-80205/"
   },
   "authorities": []
  },
  {
   "issue": "Sufficiency of Board's closed session minutes review",
   "outcome": "no_violation",
   "rule": "OMA gives public bodies discretion to determine confidentiality of closed session minutes and does not specify procedures for conducting the semiannual review.",
   "decision": {
    "title": "A county board's review of closed session minutes and recordings",
    "date": "2022-02-09",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-69534/"
   },
   "authorities": [
    {
     "text": "Ill. Att'y Gen. PAC Req. Rev. Ltr. S-0184",
     "url": null
    }
   ]
  },
  {
   "issue": "Failure to conduct semi-annual review of closed session minutes",
   "outcome": "violation_found",
   "rule": "A public body must review all closed session minutes at least semi-annually and report in open session whether confidentiality is still needed.",
   "decision": {
    "title": "A committee's failure to review closed session minutes",
    "date": "2018-08-28",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-52812/"
   },
   "authorities": []
  },
  {
   "issue": "No further remedial action required due to recent and planned reviews",
   "outcome": "no_determination",
   "rule": "Because the body recently reviewed some minutes and plans to review the rest, no further action is required beyond continuing semi-annual reviews.",
   "decision": {
    "title": "A committee's failure to review closed session minutes",
    "date": "2018-08-28",
    "binding": false,
    "url": "https://illinoisfoia.org/opinions/letter-52812/"
   },
   "authorities": []
  }
 ]
}