Lujano v. Brown

CourtDistrict Court, S.D. Illinois
DecidedOctober 7, 2025
Docket3:25-cv-01452
StatusUnknown

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

Bluebook
Lujano v. Brown, (S.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

ADAM LUJANO, #R44373, ) ) Plaintiff, ) ) vs. ) Case No. 25-cv-01452-SMY ) JEREMIAH BROWN, ) BURTON (Warden), and ) JOHN DOE KITCHEN SUPERVISOR, ) ) Defendants. )

MEMORANDUM AND ORDER

YANDLE, District Judge: Plaintiff Adam Lujano, an inmate of the Illinois Department of Corrections (“IDOC”) currently incarcerated at Lawrence Correctional Center, filed the instant lawsuit pursuant to 42 U.S.C. § 1983 for alleged deprivations of his constitutional rights. He claims his meals are not being prepared according to his religious requirements, in violation of his constitutional rights. (Doc. 1). He seeks monetary damages and injunctive relief. (Docs. 1, 3). Also pending is Plaintiff’s motion seeking a preliminary injunction and temporary restraining order (“TRO”) (Doc. 3). This case is now before the Court for preliminary review of the Complaint under 28 U.S.C. § 1915A, which requires the Court to screen prisoner Complaints to filter out nonmeritorious claims. 28 U.S.C. § 1915A(a). Any portion of the Complaint that is legally frivolous, malicious, fails to state a claim for relief, or requests money damages from an immune defendant must be dismissed. 28 U.S.C. § 1915A(b). The Complaint Plaintiff makes the following allegations in the Complaint (Doc. 1): Since January 2025, Plaintiff, who is Muslim, has not been receiving properly prepared religious diet trays (Doc. 1, pp. 2-5). He has been forced to choose between following his religious practices and obtaining adequate nutrition. Certain food should be served in Halal unopened packages and cooked food must be properly prayed over, but these steps are not being taken. Plaintiff cannot eat the packages

that have been opened. He refuses to eat the improperly prepared food, and his weight has dropped from 200 pounds to 168 pounds. Starting in January 1015, Plaintiff wrote to the John Doe Kitchen Supervisor informing him of these failures to adhere to the Muslim/Halal religious dietary practices and Plaintiff’s resulting weight loss. The Doe Kitchen Supervisor never responded. Plaintiff also wrote Defendant Warden Brown more than 15 times, and filed grievances, also with no response. Plaintiff spoke personally to Warden Burton on August 2, 2025 to inform her of the dietary issues and his weight loss. Burton said she would talk to “them” but nothing has changed (Doc. 1, p. 3). He has also sent officials websites explaining how to properly prepare food during Ramadan, to no avail.

Based on the allegations in the Complaint, the Court designates the following claims in this pro se action: Count 1: First Amendment claim against Brown the John Doe Kitchen Supervisor, and Burton, for refusing to provide Plaintiff with a religious diet that conforms to Muslim/Halal dietary practices, thus depriving him of adequate nutrition and substantially burdening his right to freely practice his religion.

Any other claim that is mentioned in the Complaint but not addressed in this Order should be considered dismissed without prejudice as inadequately pled under the Twombly pleading standard. See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) (an action fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim that is plausible on its face.”). Discussion Count 1 Observance of religiously mandated dietary restrictions is a form of religious practice

protected by the First Amendment. Hunafa v. Murphy, 907 F.2d 46, 47 (7th Cir. 1990) (citing cases). However, a prison regulation that impinges on an inmate’s First Amendment rights is nevertheless valid “if it is reasonably related to legitimate penological interests.” O'Lone v. Estate of Shabazz, 482 U.S. 342, 349 (1987) (quoting Turner v. Safley, 482 U.S. 78, 89 (1987)). Such interests include inmate security and the proper allocation of limited prison resources. See O'Lone at 348, 352-53; Turner, 482 U.S. at 90; Al-Alamin v. Gramley, 926 F.2d 680, 686 and nn. 3-5 (7th Cir. 1991). To state a claim under the First Amendment, a plaintiff must plead facts suggesting his “right to practice [his chosen religion] was burdened in a significant way.” Kaufman v. McCaughtry, 419 F.3d 678, 683 (7th Cir. 2005). Here, Plaintiff has done so regarding the denial

of his Muslim/Halal diet. Therefore, Count 1 will proceed against Brown, Burton, and the John Doe Kitchen Supervisor. Official Capacity Claims Plaintiff raises claims against each defendant in his or her individual and official capacities (Doc. 1, p. 2). The injunctive relief claim is properly brought against Jeremiah Brown, the Warden of Lawrence Correctional Center, in his official capacity. However, Plaintiff’s claims for monetary damages may only be pursued against state officials in their individual capacities. Brown v. Budz, 904 F.3d 904, 918 (7th Cir. 2005); Shockley v. Jones, 823 F.2d 1068, 1070 (7th Cir. 1987). Accordingly, the official capacity claims against the other individual defendants are dismissed without prejudice. Unknown/John/Jane Doe Defendant Plaintiff is responsible for securing information aimed at identifying the Unknown/John Doe Kitchen Supervisor Defendant, in accordance with the John/Jane Doe Identification Order

that will be entered separately. Once the name of the unknown defendant is obtained, Plaintiff must file a motion to substitute the newly identified defendant in place of the generic designation in the case caption and throughout the Complaint. Lawrence Warden Brown, in his official capacity, will respond to Plaintiff’s requests for information regarding the identity of the Unknown Defendant. Injunctive Relief1 Plaintiff seeks a TRO and/or a preliminary injunction ordering defendants to stop opening his food packs, and to have a “qualified person” pray over the cooked food (Doc. 1, p. 5), (Doc. 3).2 A TRO is an order issued without notice to the party to be enjoined that may last no more than 14 days. FED. R. CIV. P. 65(b)(2). A TRO may issue without notice only if (A) specific facts

in an affidavit or a verified complaint clearly show that immediate and irreparable injury, loss, or damage will result to the movant before the adverse party can be heard in opposition; and (B) the movant’s attorney certifies in writing any efforts made to give notice and the reasons why it should not be required. FED. R. CIV. P. 65(b)(1). Because Plaintiff has not demonstrated the likelihood of immediate and irreparable harm before Defendants can be heard, his request for a TRO is DENIED. A preliminary injunction may issue only after the adverse party is given notice and an

1 Because the Complaint includes a request for injunctive relief, Lawrence Warden Brown will remain as a defendant in his official capacity regarding this request, as well as in his individual capacity. 2 Doc.

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