No Rule 56(f) Notice When Issues Are Teed Up; Civil Detainee Privilege Limits Survive Under Both Sandin and Youngberg; Medical-Care Claims Require Objective Unreasonableness

Introduction

This nonprecedential Seventh Circuit disposition affirms summary judgment against a civil detainee, Logan Dyjak, housed at the McFarland Mental Health Center after an NGI (not guilty by reason of insanity) finding. Dyjak sued several McFarland employees under 42 U.S.C. § 1983, alleging Fourteenth Amendment due process violations stemming from a change in psychiatric diagnosis and restrictions on facility privileges. The opinion addresses three core themes: (1) the evidentiary and causation demands placed on plaintiffs at summary judgment in civil detention cases; (2) the applicable constitutional standards for medical-care and privileges claims brought by civil detainees; and (3) the scope of district court discretion under Rule 56 and scheduling orders, especially regarding notice under Rule 56(f) and extensions to respond to dispositive motions.

Two claims anchor Dyjak’s case. First, Dyjak alleged that staff psychiatrist Dr. Stacey Horstman and clinical director Dr. Jo‑Ann Lynn arbitrarily downgraded their diagnosis from “sustained remission” to “partial remission,” thereby violating due process through objectively unreasonable mental-health care. Second, Dyjak alleged that administrator Lana Miller failed to exercise professional judgment by restricting access to computers, education, gym/cafe, and non-secure areas—purportedly via a blanket administrative policy—without seeking a court order to expand privileges.

The district court granted summary judgment for the defendants. On appeal, the Seventh Circuit (Judges Easterbrook, St. Eve, and Maldonado) affirmed, rejecting procedural challenges to the summary judgment process and concluding that the record did not support either a medical-care or a privileges claim.

Summary of the Opinion

Affirmance on all grounds. The Seventh Circuit upheld the district court’s summary judgment for defendants Horstman, Lynn, and Miller.
Scheduling and Rule 56 rulings sustained. The district court did not abuse its discretion by denying additional extensions after granting three prior extensions and warning no more would be given. Nor was additional Rule 56(f) notice required because the defendants’ motion put Dyjak on notice of the factual issues the court resolved.
Medical-care claim fails. Applying the Fourteenth Amendment’s objective unreasonableness standard for detainees’ medical-care claims (McCann v. Ogle County), the court found no evidence that the change to “partial remission” was erroneous or that care was objectively unreasonable.
Privileges claim fails under any standard. Although the district court applied the Sandin/Thielman “atypical and significant hardship” framework, the Seventh Circuit held that even under the more protective Youngberg professional-judgment standard for civil detainees, Dyjak failed to show a constitutional violation because there was no evidence of a blanket policy or of a constitutional duty to petition the court to expand privileges.
No prejudice from any framing differences. Even if the district court’s doctrinal framing of the medical-care claim differed from how Dyjak characterized it, Dyjak offered no response to the motion or contrary evidence and thus could not show prejudice.

Analysis

Precedents Cited and Their Influence

Rakes v. Roederer, 117 F.4th 968 (7th Cir. 2024) — Establishes the summary judgment lens: courts view the evidence and draw reasonable inferences in favor of the non-movant. The panel explicitly applied this approach while emphasizing the absence of evidence tying alleged deprivations to these defendants.
McCann v. Ogle County, 909 F.3d 881 (7th Cir. 2018) — Clarifies that pretrial detainees’ medical-care claims arise under the Fourteenth Amendment’s objective unreasonableness standard (rather than the Eighth Amendment’s subjective deliberate indifference). The court analogized Dyjak’s civil-detainee medical-care claim to this standard and found no objectively unreasonable care.
THIELMAN v. LEEAN, 282 F.3d 478 (7th Cir. 2002) (citing SANDIN v. CONNER, 515 U.S. 472 (1995)) — Articulates that for confined persons, routine changes in conditions or privileges generally do not create a state‑law liberty interest absent “atypical and significant hardship.” The district court used Thielman/Sandin to assess the privileges restrictions; the Seventh Circuit noted that Dyjak would lose even under the alternative Youngberg standard.
YOUNGBERG v. ROMEO, 457 U.S. 307 (1982) — Establishes that civilly committed individuals are entitled to conditions reasonably related to professional judgment. The Seventh Circuit reasoned that, even assuming Youngberg applied, Dyjak presented no evidence that Miller adopted blanket restrictions without professional judgment, nor that Miller had a constitutional obligation to petition the court to increase privileges.
Miller v. Chicago Transit Auth., 20 F.4th 1148 (7th Cir. 2021) — Confirms the district court’s broad discretion to manage schedules and decide whether to excuse missed deadlines after considering relevant circumstances. This supported the refusal to grant Dyjak a fourth extension.
Haley v. Kolbe & Kolbe Millwork Co., 863 F.3d 600 (7th Cir. 2017) and Mulvania v. Sheriff of Rock Island County, 850 F.3d 849 (7th Cir. 2017) — Both stand for the proposition that additional Rule 56(f) notice is unnecessary when the parties have notice of the factual issues to be decided on summary judgment. These cases undercut Dyjak’s claim that the court granted summary judgment on an unannounced ground.
Tibbs v. Administrative Office of the Illinois Courts, 860 F.3d 502 (7th Cir. 2017) — Notes that concessions in an answer can be binding judicial admissions. The Seventh Circuit explained why the specific “reaffirmed” statement in the answer did not override Horstman’s subsequent, more comprehensive report reflecting “partial remission,” and why the later report could be considered.

Legal Reasoning

1) Procedural Rulings: Extensions, Rule 56(d), and Rule 56(f) Notice

Extensions and docket control. The district court granted three extensions to the pro se plaintiff and clearly warned that no further extensions would issue. When Dyjak sought additional extensions, the court declined and proceeded without a response. The Seventh Circuit found no abuse of discretion under Miller v. CTA, emphasizing the deference afforded to trial judges managing schedules, especially after multiple extensions and explicit warnings.

Rule 56(d) request for more time to gather facts. The district court denied Dyjak’s Rule 56(d) motion to defer ruling until more evidence could be gathered. On appeal, the denial was implicitly sustained; the panel noted the generous prior extensions and the lack of a response showing what material facts would emerge and how they would preclude summary judgment.

Rule 56(f) notice. Dyjak argued the district court granted summary judgment on grounds not raised by defendants and thus owed notice and an opportunity to respond. The Seventh Circuit rejected this, citing Haley and Mulvania: no additional notice is required when the parties are on notice of the factual issues to be decided. Here, the defendants’ motion squarely put the psychiatric evaluations and defendants’ declarations at issue; Dyjak could not claim surprise or prejudice—an especially difficult showing given that no response was filed to contest the record.

2) Medical-Care Claim: Objective Unreasonableness and the Diagnosis Change

The court applied the Fourteenth Amendment objective unreasonableness framework (McCann) to evaluate Dyjak’s challenge to the diagnostic change from “in sustained remission” to “in partial remission.” Two points controlled:

No evidentiary rebuttal. The record contained Horstman’s later comprehensive report reflecting partial remission. Dyjak did not submit evidence showing the diagnosis was wrong, arbitrary, or outside the range of professional judgment. Mere disagreement with a diagnosis or treatment plan, without more, does not establish objectively unreasonable care.
Judicial admission argument fails. Although a statement in the answer acknowledged that an August 16 evaluation reaffirmed remission, the Seventh Circuit reasoned that this did not preclude consideration of Horstman’s later August 21 comprehensive report reflecting partial remission. The later medical judgment did not contradict the earlier snapshot; rather, it superseded it with more detailed findings. Without contrary medical evidence, the claim could not survive summary judgment.

3) Privileges Claim: Sandin/Thielman vs. Youngberg—and Why the Claim Fails Either Way

The district court evaluated Dyjak’s claim that facility privileges (computers, education, gym/cafe access, movement to non-secure areas) were unconstitutionally restricted by asking whether the restrictions imposed an “atypical and significant hardship” under Thielman/Sandin. It concluded they did not.

On appeal, Dyjak argued that Youngberg’s professional-judgment standard, appropriate to civil detainees, should govern. The Seventh Circuit did not resolve which standard applies, because the claim fails under the more protective Youngberg standard too. Two gaps proved fatal:

No evidence of a blanket, nonprofessional policy. Dyjak alleged that Miller adopted a “blanket administrative policy” to restrict privileges, but offered no evidence supporting this claim. Absent proof that decisions were divorced from professional judgment, Youngberg is not violated.
No constitutional duty to petition for increased privileges. The panel was explicit: there is no authority establishing a constitutional obligation for an administrator to petition a court to expand a detainee’s privileges. That undermined Dyjak’s theory that Miller failed to exercise required professional judgment by not seeking a court order.

Additional causal considerations under § 1983 also loom large. The record showed that: (a) court orders were necessary for higher privilege levels; (b) Dyjak remained at the same “staff supervision” level since 2018; (c) Horstman testified the diagnosis did not affect the privilege level; and (d) reported restrictions coincided with COVID‑19 institutional measures. Taken together, these facts sever any link between defendants’ conduct and the alleged deprivations.

Impact and Forward-Looking Implications

Procedural rigor matters—especially for pro se litigants. Even sympathetic circumstances will not guarantee endless extensions. After multiple extensions and clear warnings, courts may rule without a response. Litigants should preserve objections and marshal record evidence rather than rely on procedural challenges that require showing prejudice.
Medical-care claims by civil detainees require evidence of objective unreasonableness. Disagreeing with a diagnosis or alleging arbitrariness is insufficient absent evidence—often expert or documentary—showing the diagnosis was wrong or outside the bounds of professional judgment. Later, more comprehensive evaluations can legitimately supersede earlier impressions.
Privileges claims face dual hurdles. Under Thielman/Sandin, plaintiffs must show atypical and significant hardship; under Youngberg, they must show a departure from professional judgment. This disposition underscores that many institution-wide restrictions—particularly those coinciding with public-health measures like COVID‑19—will not, without more, evidence a constitutional violation by specific officials.
Rule 56(f) notice is not a gotcha. When a summary judgment motion presents the key factual materials and theories, courts may grant judgment without separate notice of every doctrinal nuance, especially if the nonmovant did not respond and cannot show surprise or prejudice.
Judicial admissions are not talismans. An admission about a moment-in-time evaluation does not foreclose consideration of a subsequent, more thorough medical report. Plaintiffs must confront and counter the full record, not single sentences from pleadings.

Complex Concepts Simplified

Nonprecedential disposition: A decision designated nonprecedential does not bind future panels but can be persuasive and is often citable under federal rules. It reflects how the court currently applies established law to common fact patterns.
Objective unreasonableness (Fourteenth Amendment medical care): For detainees (pretrial or civil), the question is whether the care provided was objectively unreasonable in light of the risk—not whether officials had subjective knowledge and disregard of risk (the Eighth Amendment standard for convicted prisoners).
Youngberg professional judgment: Civilly committed individuals are entitled to decisions informed by professional judgment about safety, freedom of movement, and treatment. A constitutional violation generally requires proof that officials substantially departed from accepted professional standards.
Sandin/Thielman atypical and significant hardship: Changes in conditions or privileges do not create a liberty interest unless they impose a hardship atypical and significant compared to the ordinary incidents of confinement.
Rule 56(d): Allows a nonmovant to seek deferral of summary judgment to obtain essential facts by affidavit or declaration explaining what specific evidence is needed and how it will create a genuine dispute.
Rule 56(f): Requires notice before a court grants summary judgment on grounds not raised by a party—unless the parties already had notice of the critical factual issues and evidence, in which case no additional notice is needed.
Judicial admission: A deliberate, clear, and unequivocal statement in a pleading can bind the party. But it does not bar the court from considering additional, non-contradictory evidence that refines or updates the factual picture.
Personal involvement in § 1983: Each defendant must be personally responsible for the alleged deprivation. Institutional changes due to broader policies (e.g., COVID-19 measures) do not automatically establish individual liability.

Conclusion

The Seventh Circuit’s affirmance in Dyjak consolidates several settled principles in the civil detention context. Procedurally, district courts enjoy considerable discretion to enforce deadlines and may grant summary judgment without additional Rule 56(f) notice when the dispositive factual issues were clearly presented. Substantively, civil detainees’ medical-care claims hinge on objective unreasonableness, and privileges claims will fail absent proof of either an atypical and significant hardship or a departure from professional judgment. The court also clarifies that administrators are not constitutionally obligated to petition courts to expand detainee privileges and that bare allegations of “blanket policy” restrictions require evidentiary support.

For practitioners, the case is a reminder to build a record that links specific defendants to specific deprivations, deploy targeted Rule 56(d) showings when more discovery is necessary, and, for medical or privileges claims, to marshal professional standards and expert opinions that move the claim from disagreement to demonstrable unreasonableness or nonprofessionalism. While nonprecedential, the decision illustrates how the Seventh Circuit will analyze similar claims and provides a roadmap for both plaintiffs and institutional defendants in this recurrent area of litigation.