OMA section 2.06(d)
OMAPeriodic review of closed minutes
5 ILCS 120/2.06(d). Periodic review of closed minutes
5 issues across 4 determination letters:1 violation found · 2 no violation · 2 no determination / resolved.
Counts are per issue, not per letter, and come from automated extraction checked against sampled letters. Determination letters are not binding precedent.
How to challenge a denial on this issue
AI-generated summary of the decisions listed on this page, with each point linked to the letters it comes from. Determination letters are not binding precedent and this is not legal advice. Open the letter and check the PDF before relying on any point.
When a challenge is strong
- The public body completely failed to conduct any semi-annual review of closed session minutes and did not report in open session. 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.Based on: 2018 · A committee's failure to review closed session …
When the public body usually wins
- The public body conducted a review, even if the manner was informal or the time spent was brief. The Act does not prescribe a specific procedure or amount of time for the review; it only mandates that a review occur.Based on: 2024 · A village council's review of closed-session mi… · 2022 · A county board's review of closed session minut…
- The public body acknowledges a past failure but has already scheduled or initiated the required review. Once the body takes steps to perform the semi-annual review, the issue is considered resolved and no further violation is found.Based on: 2025 · A board's meeting minutes and vote documentation · 2018 · A committee's failure to review closed session …
Points to put in your letter
- 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.Based on: 2018 · A committee's failure to review closed session …
- If the body claims it already conducted a review, ask it to produce the minutes of the open meeting where the review was reported.Based on: 2018 · A committee's failure to review closed session …
Common mistakes
- Arguing that the public body’s review was not thorough or took too little time.Based on: 2024 · A village council's review of closed-session mi… · 2022 · A county board's review of closed session minut…
- Believing that the Open Meetings Act prescribes a specific manner or procedure for the semi-annual review.Based on: 2024 · A village council's review of closed-session mi… · 2022 · A county board's review of closed session minut…
Facts to gather first
- Whether the public body’s meeting minutes or agendas from the past six months show any report on the review of closed session minutes.
Determination letters are non-binding; outcomes depend on the specific facts, and you should always verify the full text of the decision.
Drafting brief for an AI assistant
Copy this into your assistant to help draft a request, appeal, or challenge to a denial that turns on this issue. It carries the rules and decisions, not your facts: add those yourself. Machine-readable version: oma-2-06-d.json.
Violation found (1)
Failure to conduct semi-annual review of closed session minutes
Rule: A public body must review all closed session minutes at least semi-annually and report in open session whether confidentiality is still needed.
Violation found A committee's failure to review closed session minutes · August 28, 2018
No violation (2)
Closed session minutes review procedure under OMA
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.
No violation A village council's review of closed-session minutes · March 5, 2024
Sufficiency of Board's closed session minutes review
Rule: OMA gives public bodies discretion to determine confidentiality of closed session minutes and does not specify procedures for conducting the semiannual review.
No violation A county board's review of closed session minutes and recordings · February 9, 2022
No determination / resolved (2)
Failure to conduct semi-annual review of closed session minutes
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.
No determination / resolved A board's meeting minutes and vote documentation · December 12, 2025
No further remedial action required due to recent and planned reviews
Rule: Because the body recently reviewed some minutes and plans to review the rest, no further action is required beyond continuing semi-annual reviews.
No determination / resolved A committee's failure to review closed session minutes · August 28, 2018