Jones v. Help At Home, LLC

Appellate Court of Illinois·Decided September 3, 2026·No. 1-25-0452·Unpublished

Opinion

2026 IL App (1st) 250452-U

FOURTH DIVISION

September 3, 2026

No. 1-25-0452

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1).

IN THE

APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

DIONDRA JONES, ) Appeal from the ) Circuit Court of

Plaintiff-Appellant, ) Cook County.

)

v. ) No. 24 CH 2449 )

HELP AT HOME, LLC, ) Honorable ) David B. Atkins,

Defendant-Appellee. ) Judge Presiding.

PRESIDING JUSTICE LYLE delivered the judgment of the court.

Justices Navarro and Ocasio concurred in the judgment.

ORDER

¶1 Held: The circuit court’s judgment granting the defendant’s motion to dismiss is affirmed.

¶2 On March 24, 2024, plaintiff-appellant, Diondra Jones, filed a complaint in the circuit court against defendant-appellee, Help at Home, LLC (Help at Home), alleging three separate violations of the Biometric Information Privacy Act (BIPA) (740 ILCS 14/1, et. seq. (West 2024)). Help at Home filed a motion to dismiss pursuant to 735 ILCS 5/2-619.1 (West 2024) on June 20, 2024, and Ms. Jones filed a response to the motion to dismiss September 4, 2024. On February 11, 2025, the circuit court granted Help at Home’s motion to dismiss, finding that Help at Home was exempt

from liability as a government contractor under 740 ILCS 14/25(e) (West 2024). Ms. Jones filed a notice of appeal on March 10, 2025. On appeal, Ms. Jones argues that the circuit court erred in granting Help at Home’s motion to dismiss because Help at Home is not exempt from BIPA under the government contractor exception since Help at Home is not a government contractor for all purposes or at all times. For the reasons that follow, we affirm the judgment of the circuit court of Cook County.

¶3 BACKGROUND

¶4 On March 25, 2024, Ms. Jones filed a class action complaint individually, and on behalf of all others similarly situated, against Help at Home pursuant to 735 ILCS 5/2-801, 2-802 (West 2024), and 740 ILCS 14/15 (West 2024). In her complaint, Ms. Jones alleged that Help at Home violated 740 ILCS 14/15(a), (b), (d) by its failures to (1) make publicly available a written retention and destruction policy for biometric data, (2) obtain her informed, written release prior to collecting her purported biometric data, and (3) obtain her consent prior to disseminating her purported biometric data.

¶5 The complaint stated that Ms. Jones worked as a health care provider for Help at Home in Cook County, Illinois from approximately 2019 through June 2023. During Ms. Jones’ employment, Help at Home required its employees, during the on-boarding process, to provide their fingerprint to a device that captures their biometric information. Ms. Jones further alleged that at no time: (1) was she informed in writing “that her biometric information was being collected or stored or of the specific purpose and length of term for which [her] biometric information was being collected, stored, and used,” (2) did she execute a writing releasing or permitting Help at Home to utilize her biometric information, and (3) was she “provided with a publicly available written policy regarding a schedule or guideline for the retention and permanent destruction of her

biometric information.”

¶6 On June 20, 2024, Help at Home filed a motion to dismiss pursuant to 735 ILCS 5/2-619.1 (West 2024), arguing that that (1) Ms. Jones’ claims were precluded by the Fingerprint Vendor Exclusion (740 ILCS 14/25(d) (West 2024)), (2) Ms. Jones’ claims were precluded by the Government Contractor Exclusion (740 ILCS 14/25(e) (West 2024)), (3) Ms. Jones’ claims were precluded by the HIPAA Exclusion (740 ILCS 14/10 (West 2024)), and (4) Ms. Jones otherwise failed to plead violations of BIPA.

¶7 Section 25(e) of BIPA provides that:

“Nothing in this Act shall be construed to apply to a contractor, subcontractor, or agent of a State agency or local unit of government when working for that State agency or local unit of government.” 740 ILCS 14/25(e) (West 2024).

¶8 In its motion to dismiss, Help at Home claimed that it provided home and health care services to the elderly, ill, and disabled as a certified Community Care Program provider pursuant to a contract with the Illinois Department on Aging (DOA).

¶9 In support of its motion, Help at Home submitted an affidavit (Evans Affidavit) from its Regional Vice President, Kimberly Evans, attesting to Help at Home’s status as a contractor with the DOA since 1979 to provide in-home care services to participants in the DOA’s Community Care Program (CCP). In exchange for its services, Help at Home receives payment from the DOA. The Evans Affidavit asserted that Help at Home required prospective employees to receive fingerprint-based criminal history records checks as part of the onboarding process to ensure that the prospective employees do not have past criminal convictions that would disqualify them from registering as healthcare workers with the Illinois Department of Public Health (DOPH) or the DOA. Ms. Jones applied for employment with Help at Home around July 2019 and authorized her

fingerprints to be collected for purposes of a fingerprint-based criminal history records check on July 15, 2019.

¶ 10 Help at Home provided as Exhibit A, its service provider agreement with the DOA, which provided that “[t]he Service Provider shall comply with all federal, state, and local laws for doing business as a Service Provider Agency in Illinois, including, criminal background checks or waivers as required by the Illinois Healthcare Worker Background Check Act (225 ILCS 46)****.” Help at Home also included as Exhibit B, the DOA “Division of Home and Community Services” which provided that “[p]rovider agencies will be required to obtain [criminal background checks] **** on each employee with direct [CCP] participant contact as outlined in the Procedures below.” The form also provided that “[e]mployees refusing to submit to a background check shall not have contact with CCP participants in any capacity.”

¶ 11 Ms. Jones filed her response to Help at Home’s motion to dismiss on September 4, 2024. In her response, Ms. Jones claimed that “Help at Home markets itself to prospective employees as a means of being employed as a caregiver for a member [of] their own family” which was Ms. Jones’ goal when she began her employment with Help at Home in July 2019. Ms. Jones was solely responsible for caring for her parents during her employment with Help at Home. Additionally, during Ms. Jones’ employment with Help at Home, it never directed her to comply with any requests or regulations of the DOA or the CCP, and Ms. Jones was unaware of any affiliation between Help at Home and the DOA or the CCP.

¶ 12 In its February 11, 2025, order, the trial court addressed Help at Home’s argument that it is exempt from BIPA as a government contractor. The trial court found that:

“a private entity can qualify for exemption as a government contractor if the private entity demonstrates that it, not the individual whose biometrics were allegedly collected, was

working for that unit of government at the time it collected or disseminated biometric information. Here, Defendant asserts it was contracted with the Illinois Department of Aging to provide in-home care services to participants in the State’s Community Care Program, it was required to comply with state laws pursuant to its contract with the State, and that the Background Check Act requires a health care employer initiate a fingerprint-

based criminal history record check when an applicant is given a conditional offer of employment. The court finds Defendant is exempt from BIPA under Section 25(e), and as such, the court need not address other arguments raised by Defendant.” (Emphasis in original.)

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Jones v. Help At Home, LLC, (Ill. Ct. App. 2026).

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