Townsend v. Estates of Hyde Park

Appellate Court of Illinois·Decided August 31, 2026·No. 1-25-0096·Published·Cited by 1 cases

Opinion

2026 IL App (1st) 250096

No. 1-25-0096

Opinion filed August 31, 2026

FIFTH DIVISION

IN THE

APPELLATE COURT OF ILLINOIS FIRST DISTRICT

DEBRA D. TOWNSEND, Individually and on ) Appeal from the Circuit Court Behalf of All Others Similarly Situated, ) of Cook County.

)

Plaintiff-Appellee, )

)

v. ) No. 2019 CH 11849 )

THE ESTATES OF HYDE PARK, LLC., ) The Honorable ) Eve M. Reilly,

Defendant-Appellant. ) Judge, presiding.

JUSTICE ODEN JOHNSON delivered the judgment of the court, with opinion.

Presiding Justice Mitchell and Justice Wilson concurred in the judgment and opinion.

Justice Wilson also specially concurred, with opinion.

OPINION

¶1 On October 15, 2019, Debra Townsend, a nurse, filed a class action complaint against her former employer, defendant Estates of Hyde Park, a short-term rehabilitation and long- term care facility in Cook County. The complaint alleged numerous violations of the Biometric Information Privacy Act (Act) (740 ILCS 14/1 et seq. (West 2018)). On February 22, 2024, defendant moved for judgment on the pleadings, which the trial court denied on July 12, 2024. However, on December 19, 2024, over plaintiff’s objection, the trial court granted defendant’s

motion, pursuant to Illinois Supreme Court Rule 308 (eff. Oct. 1, 2019), which permits a party to apply to the appellate court for leave to appeal a legal question certified by the trial court.

¶2 On February 24, 2025, a different panel of the Appellate Court, First District, entered an order denying defendant’s application for leave to appeal. On May 12, 2025, our supreme court entered an order, pursuant to its supervisory authority, instructing the Appellate Court, First District, to vacate its denial order. The supreme court further directed the appellate court to allow defendant’s application and to consider the legal question certified by the trial court. On July 21, 2025, the panel that had entered the denial order entered a subsequent order vacating it. On January 2, 2026, the appeal was assigned to this panel for consideration and decision.

¶3 The question, submitted by defendant and certified by the trial court, asks:

“Is fingerprint or scan of a hand information collected by a healthcare provider from its employees through its timekeeping system for purposes of complying with Illinois and/or Federal healthcare regulations ‘information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996 [(HIPAA) (Pub. L. No. 104-191, 110 Stat. 1936 (1996))]’ 740 ILCS 14/10, such that it is carved out from the definition of ‘biometric identifier’ under the Illinois Biometric Information Privacy Act?”

At the heart of this question are payroll records resulting from a timekeeping system that collects biometric data. Defendant argues that, since it is required to later submit its payroll records to federal and state regulatory agencies, then its payroll records qualify as “health care” operations that are exempt from the Act. In denying defendant’s motion for judgment on the pleadings, the trial court found defendant’s argument unpersuasive. For the following reasons,

we are also unpersuaded and, consequently, answer the certified question in the negative: defendant’s payroll records are not exempt from the Act. We will not rule on the judgment of the pleadings, as it is beyond the scope of this appeal, which is limited to the certified question.

¶4 BACKGROUND

¶5 Since this appeal comes to us at the pleadings stage, we accept as true all the well- pleaded facts in the complaint and all reasonable inferences that may be drawn from those facts, and we construe them in a way most favorable to plaintiff. Bennett v. Chicago Title & Trust Co., 404 Ill. App. 3d 1088, 1094 (2010). No answer was filed by defendant, and no exhibits were attached to the complaint. We summarize below the facts alleged in the complaint.

¶6 Defendant Estates of Hyde Park, LLC is a short-term rehabilitation and long-term care facility in Cook County, where plaintiff Debra Townsend, a nurse, worked from April 2019 to September 2019. Handscans were used at the facility for timekeeping purposes.

¶7 When defendant hires an employee, the employee is enrolled in defendant’s employee database, using a scan of the employee’s hand. Defendant then uses its employee database to monitor the time worked by its employees. Defendant requires its employees, as a condition of employment, to have their hand scanned by a biometric timekeeping device. Employees are required to have their hands scanned “to clock-in and clock-out, recording their time worked.” Plaintiff alleges that, “[w]hile many employers use conventional methods for tracking time worked (such as ID badges or punch clocks), Defendant’s employees are required, as a condition of employment, to have their hand geometry scanned by a biometric timekeeping device.”

¶8 Plaintiff’s complaint alleges that defendant violated the Act in numerous ways, such as failing to inform employees of the length of time that their scans would be stored and failing to provide a publicly available retention schedule and guidelines for destruction. Plaintiff alleges that defendant disclosed employee hand-scan data to at least one third-party vendor. In her putative class action complaint, filed October 15, 2019, plaintiff sought to bring her action on behalf of herself and also on behalf of other similarly situated individuals who worked for defendant and who had hand scans collected.

¶9 In its motion for judgment on the pleadings, defendant argued that the act of scanning an employee’s hand for timekeeping purposes is excluded from the Act’s protections, on the ground that the Act exempted from its protections “health care *** operations under [HIPAA].” 740 ILCS 14/10 (West 2018).

¶ 10 At the May 30, 2024, hearing on defendant’s motion, defendant argued that it had to submit its “payroll-based records” to state and federal agencies, in order to qualify for federal government-funded health programs and to maintain its state license as a nursing home, and, thus, its payroll qualified as a health care operation under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) (Pub. L. No. 104-191, 110 Stat. 1936 (1996)). In response, plaintiff argued that the fact that payroll records were sent to a regulator who might then use them in an audit was too tenuous a connection for them to qualify as health care operations under HIPAA. Plaintiff noted that every Cook County judge to address the issue had held that timekeeping was not a health care operation under HIPAA.

¶ 11 On July 5, 2024, the trial court denied defendant’s motion for judgment on the pleadings. The trial court’s order noted that there was a split among trial courts regarding the application of the Act to biometric timekeeping systems used in healthcare facilities. The trial

court noted that the Illinois Supreme Court’s decision in Mosby v. Ingalls Memorial Hospital, 2023 IL 129081, was instructive but not dispositive, since Mosby involved medication dispersion rather than the timekeeping of staff. Mosby was the last decision issued by the Illinois Supreme Court regarding the Act’s reach.

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