Objective-Reasonableness Review for Civil Detainee Diet Claims and Qualified Immunity Where Kosher-Diet Sincerity Is Unclear

1. Introduction

In Logan Dyjak v. Melanie Kluzek, et al. (7th Cir. Sept. 3, 2026) (nonprecedential), the Seventh Circuit affirmed summary judgment for McFarland Mental Health Center officials and staff on a civil detainee’s claims under 42 U.S.C. § 1983.

The plaintiff, Logan Dyjak, a civil detainee, alleged (1) unconstitutional conditions of confinement under the Fourteenth Amendment based on an inadequate diet, and (2) a First Amendment free-exercise violation based on the refusal to provide a nutritious kosher diet. The defendants were: dietician Melanie Kluzek; hospital administrators Dana Wilkerson and Lana Miller; and dietary manager Dana Carlson.

The case arose from evolving diet plans (vegan/vegetarian high-calorie high-protein), food availability problems—especially after COVID-related cafeteria closure—and enforcement of a contraband policy that led to confiscation of some outside-purchased items due to aluminum/foil packaging.

2. Summary of the Opinion

  • Fourteenth Amendment (conditions/diet): The court applied the objective-reasonableness framework for civil detainees and held that no reasonable jury could find Kluzek’s response objectively unreasonable; and that Wilkerson, Carlson, and Miller lacked the necessary personal involvement for § 1983 liability.
  • First Amendment (free exercise/kosher): The court held that qualified immunity protected Kluzek because the record did not show that “every reasonable official” would have understood her actions as substantially burdening a sincerely held religious belief; and the remaining defendants were not personally responsible for denying a kosher diet.
  • Discovery sanctions: No reversible error in denying sanctions where Dyjak did not identify compensable “expenses incurred” as a pro se litigant or other appropriate sanctions.
  • Costs: The district court did not abuse discretion awarding $292.05 in costs; a prior settlement did not bar the State agency from seeking litigation costs in future cases.

3. Analysis

3.1. Precedents Cited

A. Fourteenth Amendment protections for detainees and the objective-reasonableness lens

  • Hardeman v. Curran, 933 F.3d 816 (7th Cir. 2019): Anchors detainees’ entitlement to “basic human needs” and supplies the two-part structure (objective seriousness and the officer’s response) while distinguishing detainee due-process claims from Eighth Amendment prisoner claims.
  • DeShaney v. Winnebago Cnty. Dep't of Soc. Servs., 489 U.S. 189 (1989): Quoted via Hardeman for the baseline proposition that those in state custody are owed provision of basic needs (including food).
  • Echols v. Johnson, 105 F.4th 973 (7th Cir. 2024): Confirms civil detainees’ protected liberty interest in reasonably safe conditions and aligns civil-detainee conditions claims with pretrial detainee standards.
  • Pittman v. Madison Cnty., 108 F.4th 561 (7th Cir. 2024), cert. denied, 145 S. Ct. 1154 (2025): Applies Kingsley’s objective approach to conditions claims, reinforcing that subjective intent to punish is not required for detainee due-process analysis.
  • Kingsley v. Hendrickson, 576 U.S. 389 (2015): Provides the core test—conduct is objectively unreasonable if not rationally related to a legitimate, nonpunitive purpose or if excessive relative to that purpose.
  • Lee v. Milwaukee Cnty., 175 F.4th 877 (7th Cir. 2026): Used both for summary-judgment inference rules and for framing objective unreasonableness as an inadequate response to a serious risk “from the perspective of a reasonable officer.”
  • Kemp v. Fulton Cnty., 27 F.4th 491 (7th Cir. 2022): Adds an important limitation to objective reasonableness: the official must intend the course of action; negligence alone is insufficient.
  • Williams v. Ortiz, 937 F.3d 936 (7th Cir. 2019): Supports the conclusion that repeatedly adjusting a treatment plan in response to complaints is not objectively unreasonable even if every request is not met.

B. Personal involvement and supervisory/nonmedical reliance under § 1983

  • Zemlick v. Burkhart, 164 F.4th 1004 (7th Cir. 2026): Supplies the governing rule that § 1983 liability requires personal responsibility, and elaborates supervisory liability (“facilitate,” “approve,” “condone,” or “turn a blind eye”). It also supports the proposition that nonmedical officials may rely on medical expertise.

C. Free exercise, substantial burden, sincerity screening, and qualified immunity

  • Thompson v. Holm, 809 F.3d 376 (7th Cir. 2016): Establishes that forcing a person to choose between nutrition and religious practice is a substantial burden—an important baseline rule Dyjak invoked.
  • Vinning-El v. Evans, 657 F.3d 591 (7th Cir. 2011): Central to the defense. It holds that only sincerely held religious beliefs must be accommodated, that officials may test sincerity (distinguishing religion from taste/ethics/mischief), and that officials who reasonably believe a request is insincere are entitled to qualified immunity.
  • District of Columbia v. Wesby, 583 U.S. 48 (2018): Supplies the modern “clearly established” standard: the unlawfulness must be so clear that “every reasonable official” would understand the conduct is unlawful.
  • Vinning-El v. Evans (also): Cited again to reject liability for officials not shown to have “made or ratified” diet decisions—paralleling the court’s insistence on personal responsibility.

D. Costs, appealability, and procedural precedent

  • Lange v. City of Oconto, 28 F.4th 825 (7th Cir. 2022): Sets abuse-of-discretion review for cost awards.
  • Grunt Style LLC v. TWD, LLC, 140 F.4th 839 (7th Cir. 2025) and Ammons v. Gerlinger, 547 F.3d 724 (7th Cir. 2008): Explain that a post-judgment cost award is independently appealable and may require a separate notice of appeal (and fee) when the initial notice is untimely as to costs.

3.2. Legal Reasoning

A. Fourteenth Amendment diet/conditions claim: objective reasonableness applied to intended conduct

The panel treated the case as turning on the defendants’ conduct rather than litigating in depth whether Dyjak’s diet deficiencies met the objective-seriousness threshold, noting that defendants did not address conditions and thus the court focused on the response.

As to Kluzek, the court emphasized record evidence of ongoing clinical engagement and adaptation: (i) selecting a high-calorie/high-protein plan to prevent recurrence of weight loss and nutrient deficiencies, (ii) modifying the plan when Dyjak sought more options (vegan to vegetarian), (iii) warning about self-imposed restrictions (soy avoidance and other refusals), and (iv) recommending Ensure supplementation when restrictions continued. Under Williams v. Ortiz, these repeated modifications and risk-mitigation steps rendered her conduct not objectively unreasonable.

As to Wilkerson, Carlson, and Miller, the court applied § 1983’s personal-responsibility requirement via Zemlick v. Burkhart. Even though Carlson ordered food and planned menus, Dyjak lacked evidence tying Carlson to the early-2020 supply failures. For Wilkerson and Miller, the court found no evidence of knowing facilitation/condonation, and additionally relied on Zemlick to hold that nonmedical administrators may rely on dieticians’ adherence to federal dietary guidelines rather than independently re-auditing nutrition.

B. Free exercise claim: substantial burden requires both sincerity and personal responsibility; qualified immunity protects reasonable skepticism

The court accepted the doctrinal premise from Thompson v. Holm that forcing a choice between adequate daily nutrition and religious observance can be a substantial burden. But it treated the critical question as whether officials clearly should have understood Dyjak’s kosher request to reflect a sincerely held religious belief.

Using Vinning-El v. Evans, the panel stressed that officials may evaluate sincerity to distinguish religion from preference or other motivations. The record included: Kluzek’s notation that the request “doesn't appear to be [due to] religious preference,” evidence of restrictive eating habits, and Dyjak’s agreement that a vegan/vegetarian plan best accommodated their assorted preferences (including kosher concerns). On these facts, the court held that it was not “clearly established” under District of Columbia v. Wesby that Kluzek’s actions substantially burdened a sincere belief—thus she received qualified immunity.

For Wilkerson, Carlson, and Miller, the claim failed again for lack of personal involvement. The court rejected liability based on Miller’s grievance response, reasoning that answering a grievance—without evidence of deciding or directing enforcement—does not show personal responsibility for confiscations.

C. Discovery sanctions and costs

On sanctions, the court read FED. R. CIV. P. 37(a)(5)(A) and 37(b)(2)(C) in light of Dyjak’s failure to identify compensable “expenses incurred” beyond pro se time, and found no abuse of discretion in declining sanctions.

On costs, applying Lange v. City of Oconto, the panel upheld the modest award. It construed the earlier settlement as limiting the State’s recovery of costs of confinement/services from settlement proceeds, not as a blanket waiver of the State’s ability to seek taxable costs for future litigation. It also relied on Grunt Style LLC v. TWD, LLC and Ammons v. Gerlinger to address the separate-appeal requirement for the costs order.

3.3. Impact

  • Operational guidance for civil-detainee diet litigation: The order reinforces that, in the Seventh Circuit’s post-Kingsley framework, documented clinical engagement—assessment, adjustments, warnings, supplementation—strongly supports objective reasonableness on summary judgment.
  • Administrator liability remains tightly cabined: Under Zemlick v. Burkhart, plaintiffs must connect supply failures or diet deficiencies to a specific defendant’s decisions or knowing acquiescence; generalized responsibility for operations or mere grievance responses are unlikely to suffice.
  • Free-exercise dietary claims hinge on sincerity and clarity: Even where denial of a religious diet can be a “substantial burden” (Thompson v. Holm), Vinning-El v. Evans supports qualified immunity when the record plausibly suggests preference or nonreligious motivations and officials accommodate via an alternative plan the detainee accepts.
  • Procedural takeaways: Pro se litigants seeking Rule 37 expenses must identify cognizable “expenses,” and parties must separately and timely appeal cost awards to avoid extra fees and jurisdictional issues.

4. Complex Concepts Simplified

Summary judgment
A pretrial ruling for one side when no genuine dispute of material fact exists and the movant is entitled to judgment as a matter of law; the court views evidence in the nonmovant’s favor (here, per Lee v. Milwaukee Cnty.).
Objective reasonableness (civil detainees)
Under Kingsley v. Hendrickson and its conditions-case extensions (e.g., Pittman v. Madison Cnty.), the question is whether the official’s intended actions were rationally related to legitimate, nonpunitive aims and not excessive—without needing proof of subjective intent to punish; but Kemp v. Fulton Cnty. emphasizes negligence alone is not enough.
Personal involvement under § 1983
Liability is individual, not vicarious. A defendant must have caused or knowingly facilitated the deprivation. Supervisors are liable only if they knowingly facilitate/approve/condone or deliberately ignore it (as described in Zemlick v. Burkhart).
Substantial burden (free exercise)
A government action that significantly pressures someone to violate religious beliefs—such as forcing a choice between adequate nutrition and religious practice (Thompson v. Holm).
Sincerity screening
Officials may test whether a claimed religious diet request is based on a sincere belief rather than preference or other motives (Vinning-El v. Evans).
Qualified immunity
Even if a right exists in the abstract, officials are immune unless the unlawfulness was “clearly established” such that every reasonable official would have known the conduct was unlawful (District of Columbia v. Wesby).
Taxable costs (Rule 54)
Limited litigation expenses (e.g., certain fees) that the prevailing party may recover under FED. R. CIV. P. 54(d)(1), subject to the district court’s discretion (reviewed under Lange v. City of Oconto).

5. Conclusion

The Seventh Circuit’s disposition affirms a practical, evidence-driven approach to civil detainee diet claims: where medical staff actively designs and adjusts diets to address nutritional risk, a plaintiff faces a steep burden to show objective unreasonableness on summary judgment. The decision also underscores two recurring barriers in institutional-rights litigation—personal involvement and qualified immunity—especially in religious-diet cases where the record supports reasonable doubt about sincerity or shows accepted non-kosher alternatives. Finally, the opinion highlights procedural discipline: sanctions require identifiable expenses, and costs awards are separately appealable and not easily barred by unrelated settlement language.