Woodruff v. IDHS

── Woodruff v. IDHS ── Court: Appellate Court of Illinois Date: May 11, 2026 Category: General 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