Bakambia v. Hart
Marc Amouri Bakambia v. Alexandra Hart, in her official capacity, Kathy Reid, in her individual capacity, Chrstine Oberembt, in her individual and official capacities, and Michael Oliveras, in his individual capacity
- Dulce Foster
- 0:24-cv-03653
- U.S. District Court · District of Minnesota
- 3
In Bakambia v. Hart, Magistrate Judge Foster denied prisoner Marc Amouri Bakambia's motion seeking a revised defendant answer and more law library time.
State prisoners litigating civil cases who seek court orders requiring prison officials to provide greater law library access, and litigants attempting to compel more definite answers from opposing parties under Rule 12(e).
What happened
In Bakambia v. Hart, No. 24-cv-3653, prisoner Marc Amouri Bakambia sued several Minnesota Department of Corrections employees and, during the litigation, filed a motion asking the court to (1) force the defendants to rewrite their answer to his complaint, which he found evasive, and (2) order his prison to give him at least two hours per week in the law library so he could prepare his case.
On the first request, the court found that the federal procedural rule Mr. Bakambia relied on — Rule 12(e), which allows a party to demand a clearer pleading — does not apply to answers. That rule only kicks in for documents that themselves require a formal written response, and an answer does not require one unless the court specifically orders it, which the court had not done. On the second request, the court noted that managing law library access is a matter of prison administration, and courts must be restrained about ordering prisons to change how they operate. The court also pointed to Mr. Bakambia's own submitted documents, which showed he had been scheduled for three law library slots within a single week, received a one-hour slot the following week, and was told by the law librarian he could request hour-long slots going forward.
Magistrate Judge Dulce J. Foster denied the motion in full on October 22, 2025. The court did note, however, that if Mr. Bakambia is unable to meet a court deadline specifically because of limited law library access, he may file a separate motion asking for more time and explaining why an extension is needed — after first trying in good faith to work it out with the defendants' lawyers.
The detailed version
- Bakambia v. Hart · No. 0:24-cv-03653
- Dulce J. Foster
- Oct. 22, 2025
Background
Marc Amouri Bakambia is a Minnesota state prisoner who was transferred from the Minnesota Correctional Facility-Stillwater (MCF-Stillwater) to the Minnesota Correctional Facility-Lino Lakes (MCF-Lino Lakes) during the pendency of this lawsuit. The defendants are current or former employees of the Minnesota Department of Corrections stationed at MCF-Stillwater and are sued in various combinations of their individual and official capacities.
Mr. Bakambia filed a motion (ECF No. 107) requesting two forms of relief: (1) an order directing defendants to amend their answer to the complaint on the ground that the answer is evasive; and (2) an order requiring the prison to give him at least two hours per week of law library access to prepare for this case.
Motion for a More Definite Answer (Rule 12(e))
Mr. Bakambia relied on Rule 12(e) of the Federal Rules of Civil Procedure, which permits a party to move for a more definite statement of a pleading "to which a responsive pleading is allowed" when the pleading is so vague or ambiguous that the opposing party cannot reasonably prepare a response. The court rejected this argument as meritless. Under Federal Rule of Civil Procedure 7(a), an answer is not a pleading that calls for a responsive pleading unless the court specifically orders a reply under Rule 7(a)(7). The court had issued no such order. Therefore, Rule 12(e) does not apply to defendants' answer, and the court denied this portion of the motion.
Motion for Law Library Access
Mr. Bakambia stated that he was limited to 30-minute windows of law library time — windows that he said included travel time to and from the library — and that these slots occurred only once a week, every other week, or sometimes even less frequently. He argued this was insufficient to litigate his case.
The court analyzed this request under the deferential standard applicable to prison-administration matters, citing Goff v. Harper, 60 F.3d 518, 520 (8th Cir. 1995), which requires courts to act with restraint before compelling a prison to alter its internal operations.
Applying that standard, the court found that Mr. Bakambia's own submitted exhibits (ECF No. 114) undermined his characterization of the situation. Those exhibits showed he had been scheduled for three separate law library slots within a single week, received a one-hour slot the following week, and had been told by the law librarian that he could request hour-long sessions in the future. The court concluded that the record did not show circumstances dire enough to warrant judicial intervention into prison administration, and denied this portion of the motion.
Preservation of Rights Regarding Deadlines
Although the court denied both requests, it noted that if Mr. Bakambia is actually unable to meet a specific court-ordered deadline due to lack of law library access, he may file a motion requesting an extension of time, explaining the reasons for the extension. The court added in a footnote that before filing any such motion, Mr. Bakambia must first attempt in good faith to confer with opposing counsel about the request, as he did with the present motion.
Disposition
The motion (ECF No. 107) was denied in its entirety.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.