Woodruff v. IDHS

CourtAppellate Court of Illinois
DecidedMay 11, 2026
Docket1-25-0443
StatusUnpublished

This text of Woodruff v. IDHS (Woodruff v. IDHS) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Woodruff v. IDHS, (Ill. Ct. App. 2026).

Opinion

2026 IL App (1st) 250443-U

FIRST DIVISION May 11, 2026

No. 1-25-0443

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 ______________________________________________________________________________

JACQUELINE WOODRUFF, ) Appeal from the Circuit Court of ) Cook County. Plaintiff-Appellant, ) ) v. ) ) No. 24 CH 03899 ILLINOIS DEPARTMENT OF HUMAN ) SERVICES, ) ) Honorable Allen P. Walker, Defendant-Appellee. ) Judge Presiding. ______________________________________________________________________________

JUSTICE HOWSE delivered the judgment of the court. Presiding Justice Fitzgerald Smith and Justice Cobbs concurred in the judgment.

ORDER

¶1 Held: We affirm the trial court’s order and confirm the administrative decision rendered by the Illinois Department of Human Services. Plaintiff has failed to demonstrate that the administrative agency clearly erred when it determined that her failure to cooperate with its rules justified a termination of services.

¶2 Plaintiff filed this case for administrative review following an adverse administrative

decision by the Illinois Department of Human Services. The Department concluded that

plaintiff’s refusal to execute a particular form constituted a failure to cooperate in complying

with its service plans and other administrative rules that justified a termination of the services it

was providing to plaintiff. Plaintiff appealed the administrative decision to the circuit court. On 1-25-0443

administrative review, the circuit court affirmed the Department’s decision. Plaintiff now appeals

to this court, and we confirm the Department’s decision and affirm the judgment of the circuit

court.

¶3 BACKGROUND

¶4 Plaintiff Jacqueline Woodruff is disabled and she receives various services from

defendant, the Illinois Department of Human Services. Plaintiff applied for an environmental

modification to her home through services provided by the Department under the Rehabilitation

of Persons with Disabilities Act (20 ILCS 2405/0.01 et seq. (West 2024)). The Department

granted her request. Plaintiff was approved to receive a stair chairlift and a walk-in bathtub at her

residence.

¶5 The Rehabilitation of Persons with Disabilities Act (id.) is designed to “provide for

rehabilitation, habilitation and other services to persons with one or more disabilities, their

families and the community.” To carry out the purposes of the Act, the Department runs a Home

Services Program which includes services such as adult day care, home delivered meals, and the

service at issue in this case, environmental modification. 20 ILCS 2405/3(f) (West 2024).

¶6 For the environmental modification program, the Department provides “[s]ervices to

physically modify the customer’s home to accommodate the customer’s loss of function in the

completion of his/her Activities of Daily Living.” 89 Ill. Adm. Code § 686.600. The Department

bears some or all of the cost of the environmental modifications, depending on the recipient’s

ability to pay. 20 ILCS 2405/3(f) (West 2024). However, there is a $25,000 limit on the

modifications for a five-year period. 89 Ill. Adm. Code § 686.605(c). The Department requires

all providers of construction services to carry $500,000 in liability insurance, maintain

-2- 1-25-0443

appropriate contractor licenses, and obtain all necessary building permits, among other

requirements. 89 Ill. Adm. Code § 686.608.

¶7 In March 2022, a company named Lifeway Mobility was approved to perform work on

plaintiff’s home. After the work was done, a representative of the Department inspected the

home and determined the contractor had not adequately completed the work, with the

Department recognizing that the work was “substandard.” The Department solicited bids from

new contractors to perform the remedial work. A new contractor, Access Elevator, was selected.

The Department approved a one-time exception to the $25,000 cap on the cost of services to

cover the cost of completing the work which would raise the price of the modifications to

$36,622.

¶8 The Department informed plaintiff that it would require her to execute a form called an

Environmental Modification Statement of Responsibility before the remediation work could

begin. The form explains the responsibilities of the various parties including the Department, the

selected contractor, and the recipient of the services. The form states that it constitutes an

agreement between the contractor and the recipient of the services and, as a result, any dispute

that arises between the contractor and the recipient shall be resolved between them, without the

Department’s involvement. The form concludes by stating that “[f]ailure to agree to the

Statement shall render the Environmental Modification null and void.”

¶9 Over the course of a ten-month period, plaintiff and Department employees had several

meetings and exchanged many emails and phone calls to persuade plaintiff to execute the

Statement of Responsibility. But plaintiff refused to execute the document. The communications

included the director of the Home Services Program, advocates from the long-term care

ombudsman, plaintiff’s rehabilitation counselor, and employees from Access Elevator. The

-3- 1-25-0443

Department offered to modify the Statement of Responsibility to indicate that the Department

would remain involved in the project “in extraordinary circumstances as those presented here.”

¶ 10 During the period of trying to convince plaintiff that signing the Statement of

Responsibility was in her best interest, plaintiff raised concerns to the Department about whether

the subcontractors Access Elevator would be using would have the proper licenses. The

Department reminded plaintiff that it had requirements that the providers were properly licensed

and that the representative from Access Elevator had assured all parties that all contractors would

be properly licensed. Access Elevator also sent plaintiff copies of its contractor’s licenses such as

its plumbing and elevator licenses from state and local entities and its general contractor’s

license from the City of Chicago. Plaintiff was unpersuaded. Plaintiff pointed out that the

administrative regulation requires all contractors to “meet the approval of the customer” and the

Department (citing 89 Ill. Adm. Code § 686.608(a)) and there was nothing in applicable

administrative regulations that required her to sign a Statement of Responsibility before the work

began.

¶ 11 Plaintiff provided the Department with the names of contractors she wanted to perform

the work. The Department explained that, if plaintiff rejected Access Elevator, it would be

required to re-open the bidding for the project. The Department informed plaintiff that the

contractors she had suggested for the project could bid for the work so long as they met the

requirements to qualify as set forth in the administrative regulation. The Department, however,

also informed plaintiff that regardless of who was selected to perform the work, it would require

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