Objective-Reasonableness Standard Governs Civil Detainee Diet Claims; Qualified Immunity Applies Where Kosher Request Appears Insincere and Officials Lack Personal Involvement

Introduction

In Logan Dyjak v. Melanie Kluzek, et al., Logan Dyjak, a civil detainee at the McFarland Mental Health Center in Springfield, Illinois, sued multiple facility officials under 42 U.S.C. § 1983. Dyjak alleged (1) unconstitutional conditions of confinement under the Fourteenth Amendment Due Process Clause based on an allegedly inadequate diet, and (2) violation of the First Amendment Free Exercise Clause for failure to provide a nutritious kosher diet and for restrictions affecting access to kosher foods.

The Seventh Circuit affirmed summary judgment for defendants, holding that the dietician’s conduct was objectively reasonable, that administrators/dietary management were not personally responsible for the asserted deprivations, and that—given the record—qualified immunity protected the dietician on the free-exercise theory because it was not clearly established that her conduct substantially burdened a sincerely held religious belief. The court also affirmed the district court’s rulings on discovery sanctions and costs.

Summary of the Opinion

  • Fourteenth Amendment (conditions of confinement): Even assuming dietary problems existed, the record could not support a finding that dietician Melanie Kluzek responded unreasonably; she designed and adjusted a high-calorie/high-protein plan, warned against self-restriction, and added supplements. Administrators Dana Wilkerson and Lana Miller, and dietary manager Dana Carlson, lacked the personal involvement required for § 1983 liability.
  • First Amendment (free exercise / kosher diet): The court emphasized that only sincerely held religious beliefs must be accommodated and that officials may test sincerity. On this record—where Dyjak agreed to vegetarian/vegan alternatives and the dietician noted the request did not appear religious—qualified immunity applied, and other defendants were not personally responsible.
  • Discovery sanctions: No reversible error where Dyjak identified no compensable “reasonable expenses” incurred (as a pro se litigant) and did not show what sanctions were warranted.
  • Costs (Rule 54(d)(1)): The district court did not abuse discretion awarding $292.05 in costs; a prior settlement did not bar costs in future litigation. The court also noted a second notice of appeal (and fee) was required for the separately appealable costs award.

Analysis

Precedents Cited

1) Summary-judgment posture and inferences

The panel began by applying the standard summary-judgment lens from Lee v. Milwaukee Cnty., 175 F.4th 877 (7th Cir. 2026), construing facts and reasonable inferences in Dyjak’s favor. This framing mattered because the court still concluded that, even under Dyjak-favorable inferences, the evidence could not support constitutional liability.

2) Civil detainees’ Fourteenth Amendment right to “basic human needs” and the governing test

For civil detainees, the court reiterated that due process protects “basic human needs” (including food), citing Hardeman v. Curran, 933 F.3d 816 (7th Cir. 2019) (quoting DeShaney v. Winnebago Cnty. Dep't of Soc. Servs., 489 U.S. 189 (1989)), and confirming parity with pretrial detainees via Echols v. Johnson, 105 F.4th 973 (7th Cir. 2024).

The opinion emphasized the doctrinal shift from Eighth Amendment “deliberate indifference” (subjective) to Fourteenth Amendment “objective reasonableness” for detainees, relying on Pittman v. Madison Cnty., 108 F.4th 561 (7th Cir. 2024) (relying on Kingsley v. Hendrickson, 576 U.S. 389 (2015)), cert. denied, 145 S. Ct. 1154 (2025). It further clarified that negligence is insufficient because the officer must intend the course of action, citing Kemp v. Fulton Cnty., 27 F.4th 491 (7th Cir. 2022), with the Kingsley reference underscoring that accidental harms do not create liability under the objective-reasonableness framework.

Substantively, the panel adopted Kingsley’s formulation: conduct is objectively unreasonable if it is not rationally related to a legitimate nonpunitive purpose or is excessive relative to that purpose, and it cited Lee v. Milwaukee Cnty., 175 F.4th at 885, for the requirement that an objectively reasonable response must sufficiently abate a risk of serious harm from the perspective of a reasonable officer.

3) Reasonableness of medical/dietary response

The court analogized Kluzek’s iterative dietary adjustments to the constitutionally adequate responsiveness recognized in Williams v. Ortiz, 937 F.3d 936 (7th Cir. 2019), where repeatedly modifying a plan to address complaints—even without granting every request—was not objectively unreasonable. Here, Kluzek’s high-calorie/high-protein plan, modifications to accommodate availability, warnings about restriction, and prescription of Ensure supported judgment as a matter of law.

4) Personal involvement and supervisory liability under § 1983

The court applied Zemlick v. Burkhart, 164 F.4th 1004 (7th Cir. 2026), for the rule that § 1983 liability requires personal responsibility, and that supervisors can be liable only if they know of and facilitate, approve, condone, or turn a blind eye to unconstitutional conduct. Zemlick also supported the court’s conclusion that nonmedical administrators may rely on the expertise of medical staff—critical to rejecting claims against Wilkerson and Miller, who believed the diet was nutritionally sound because dieticians followed federal guidelines.

5) Free exercise: substantial burden, sincerity, and qualified immunity

The free-exercise framework came from Thompson v. Holm, 809 F.3d 376 (7th Cir. 2016), which requires evidence that defendants “personally and unjustifiably” imposed a substantial burden on religious practice and recognizes that forcing a person to choose between nutrition and faith can be a substantial burden.

But the panel emphasized sincerity as a threshold requirement under Vinning-El v. Evans, 657 F.3d 591 (7th Cir. 2011). Quoting Vinning-El’s caution that officials may ensure a request reflects genuine religious belief rather than taste, ethics, or troublemaking, the court concluded that—given Kluzek’s notes about restrictive eating habits and Dyjak’s agreement to vegetarian/vegan alternatives—qualified immunity applied because not “every reasonable official” would understand her conduct to be unlawful.

The qualified-immunity standard was drawn from District of Columbia v. Wesby, 583 U.S. 48 (2018): the unlawfulness must be clearly established such that every reasonable official would understand the conduct is unlawful. The court also invoked Vinning-El to reject liability against other officials absent evidence they “made or ratified” diet decisions, underscoring the recurring “personal involvement” requirement in religious-diet cases.

6) Sanctions and costs

On sanctions, the court referenced FED. R. CIV. P. 37(a)(5)(A) (expenses after a granted motion to compel) and Rule 37(b)(2)(C) (sanctions for disobeying an order), but affirmed because Dyjak identified no reimbursable expenses beyond pro se time and did not show what sanctions were appropriate.

On costs, the abuse-of-discretion standard came from Lange v. City of Oconto, 28 F.4th 825 (7th Cir. 2022). For appellate procedure, the court cited Grunt Style LLC v. TWD, LLC, 140 F.4th 839 (7th Cir. 2025), and Ammons v. Gerlinger, 547 F.3d 724 (7th Cir. 2008), to explain that a costs award is independently appealable and requires its own timely notice of appeal (and fee).

Legal Reasoning

  1. Fourteenth Amendment claim narrowed to reasonableness of defendants’ conduct: The court stated defendants did not meaningfully dispute the objective seriousness of conditions, so it focused on whether each defendant’s conduct was objectively unreasonable under Kingsley/Pittman.
  2. Dietician’s conduct was constitutionally adequate: The record showed active, medically oriented engagement—creating a calorie/protein-dense plan, adjusting to availability and preferences, warning about self-imposed restriction, and adding supplements—placing the case within the “reasonable response” line exemplified by Williams v. Ortiz.
  3. Administrators and dietary manager lacked personal responsibility: Even if systemic food problems occurred (including pandemic disruptions and menu/stock issues), Dyjak did not tie them to actionable conduct by Wilkerson, Carlson, or Miller, as required by Zemlick v. Burkhart.
  4. Free-exercise claim failed on “clearly established” and personal involvement: While Thompson v. Holm recognizes substantial burden when one must choose between diet and religion, Vinning-El v. Evans permits officials to evaluate sincerity. Given Dyjak’s mixed statements and agreement to non-kosher vegetarian/vegan alternatives, the court held qualified immunity protected Kluzek because the unlawfulness was not clear under District of Columbia v. Wesby. Other defendants again failed for lack of evidence of personal decisionmaking.
  5. Procedural rulings affirmed due to lack of showing of prejudice/entitlement: Without identifiable expenses, Rule 37 fee-shifting could not help Dyjak; and the prior settlement did not plausibly waive costs for future litigation under Rule 54(d)(1).

Impact

Although designated a NONPRECEDENTIAL DISPOSITION, the order is practically significant as a roadmap for how the Seventh Circuit applies existing detainee-conditions and religious-diet doctrine:

  • Diet claims: A medically documented, iterative dietary plan (and documented responses to complaints) is strong evidence of objective reasonableness under the Fourteenth Amendment detainee standard.
  • Personal involvement remains decisive: Plaintiffs must connect each defendant to specific diet-related decisions; broad references to institutional failures, supply shortages, or policy changes are insufficient without proof of individual facilitation/approval/condonation under Zemlick v. Burkhart.
  • Religious diet requests: The case illustrates how Vinning-El v. Evans can combine with qualified immunity to protect officials when the record gives an objective basis to doubt sincerity or to view accommodations as voluntary alternatives rather than coercive burdens.
  • Litigation practice: Pro se litigants seeking Rule 37 expenses should identify actual compensable costs; and parties must treat costs awards as separately appealable judgments, per Grunt Style LLC v. TWD, LLC and Ammons v. Gerlinger.

Complex Concepts Simplified

  • “Objective reasonableness” (Fourteenth Amendment detainee standard): The question is not what the official subjectively believed, but whether the official’s actions were reasonable in light of legitimate nonpunitive goals and whether the response sufficiently addressed serious risk. It is more demanding than mere “not negligent,” but it does not require proof of intent to harm.
  • “Personal involvement” under § 1983: A defendant is not liable just because they supervise others or work at the institution. The plaintiff must show the defendant personally caused the deprivation or knowingly facilitated/approved it.
  • “Sincerely held religious belief”: Free exercise protections attach to genuine religious obligations, not mere preferences. Officials may ask whether a request is religiously motivated, especially when the requester’s statements and conduct point to nonreligious reasons.
  • “Qualified immunity”: Even if a right exists in the abstract, an official is not liable for damages unless prior law made it clear—beyond debate—that the specific conduct was unlawful in the situation confronted.
  • “Costs” vs. “sanctions”: Costs (Rule 54) are routine litigation expenses a prevailing party may recover; sanctions (Rule 37) punish or remedy discovery misconduct and often require a concrete showing of incurred expenses or disobedience.

Conclusion

The Seventh Circuit affirmed summary judgment because the record showed a constitutionally reasonable medical/dietary response by the dietician, no evidentiary basis to pin diet deficiencies on other named officials as required by § 1983 personal-responsibility doctrine, and qualified immunity on the free-exercise claim where the sincerity of the kosher request was reasonably in doubt under the parties’ documented interactions. The court also reinforced that Rule 37 relief requires an identifiable expenses showing and that Rule 54 costs awards are separately appealable and not barred by unrelated settlement terms absent clear language.