Bakambia v. Hart

Background

Plaintiff Marc Amouri Bakambia is a prisoner currently housed at the Minnesota Correctional Facility-Lino Lakes (MCF-Lino Lakes). His underlying lawsuit, which has been permitted to proceed on specific deliberate-indifference-to-medical-needs claims, alleges that defendants Kathy Reid and Christine Oberembt unlawfully delayed the scheduling of his medical appointments while he was incarcerated at MCF-Stillwater. The defendants are or were employees of the Minnesota Department of Corrections. Mr. Bakambia sued Reid and Oberembt in both their individual and official capacities, and defendant Michael Oliveras in his individual capacity.

During the pendency of the litigation, defendant Kathy Reid died. Mr. Bakambia filed what he styled as an 'Unopposed Motion for Substitution of Parties Pursuant to Fed. R. Civ. P. 25(a)(1) & (d)' (Federal Rule of Civil Procedure 25 governs substitution of parties when a party dies or a public officer changes). The motion sought to substitute Alexandria Hart, identified as Reid's official successor, for Reid. Mr. Bakambia also requested the addition of new defendants — officials at MCF-Lino Lakes holding positions equivalent to those held by Hart and Oberembt at MCF-Stillwater.

The Parties' Positions

Defendants did not oppose substitution of Hart for Reid with respect to official-capacity claims, but opposed the motion as to individual-capacity claims. Their argument was that Reid's individual-capacity claims were extinguished upon her death, making substitution of her successor inappropriate for those claims. Defendants did not address the request to add new defendants in the portion of the opinion summarized here.

Court's Analysis

Official-Capacity Substitution

The court granted the motion as to official-capacity claims. Under Rule 25(d), when a public officer who is a party in her official capacity dies or otherwise ceases to hold office, her successor is automatically substituted. Because Hart is Reid's official successor, substitution is proper for official-capacity claims. The clerk was directed to amend the docket accordingly.

Individual-Capacity Substitution

The court denied the motion as to individual-capacity claims. Quoting Attwood v. Clemons, 526 F. Supp. 3d 1152, 1163 (N.D. Fla. 2021), the court explained that individual-capacity suits seek only personal liability against a government official — the remedy does not run against the office itself. Accordingly, Hart's status as Reid's official successor does not make her Reid's personal successor in interest. The court therefore refused to substitute Hart for Reid on the individual-capacity claims.

Importantly, the court expressly declined to decide whether the individual-capacity claims against Reid were actually extinguished by her death, noting that no motion to dismiss those claims had been presented. That question remains open.

Adding New Defendants

The court denied Mr. Bakambia's request to add new defendants from MCF-Lino Lakes. The court noted that the lawsuit was permitted to proceed only on specific claims — namely, that Reid and Oberembt delayed scheduling his medical appointments while he was at MCF-Stillwater. Mr. Bakambia had not alleged facts supporting any claims against officials at his current facility, MCF-Lino Lakes, so adding those officials as defendants was not warranted.

Disposition

The motion was granted in part and denied in part. Alexandria Hart in her official capacity is substituted for Kathy Reid in her official capacity. The motion was denied in all other respects, including as to individual-capacity substitution and the addition of new defendants.