Bakambia v. Bolin
Marc Amouri Bakambia v. William Bolin, Warden at MCF-Stillwater; Stephen Craane, Medical Director for Centurion; Louis Shicker, Medical Director for Centurion; Andrew Brosted, Security Officer at MCF-Stillwater; Stephen Watt, Security Officer at MCF-Stillwater; Olarinde, Associate Warden of Admin. at MCF-Stillwater; Mercedes Salas, Captain at MCF-Stillwater; Eric Anderson, Security Sergeant at MCF-Stillwater; Morrin William, Registered Nurse at MCF-Stillwater; Ben Petersen, Registered Nurse at MCF-Stillwater; Christine Oberembt, Medical Record Staff at MCF-STW; and Paul Schnell, Commissioner of Corrections, each in their individual and official capacities; Kathy Reid, in her individual capacity; and Alexandria Hart, in her official capacity.
- Eric Tostrud
- 0:25-cv-00461
- U.S. District Court · District of Minnesota
- 7
In Bakambia v. Bolin, Judge Tostrud accepted a magistrate judge's recommendation and dismissed all claims brought by prisoner Marc Amouri Bakambia against prison and medical staff, agreeing that his complaint failed to adequately allege deliberate indifference to his medical needs or other civil rights violations.
Prisoners and other incarcerated individuals who bring federal civil rights lawsuits alleging deliberate indifference to medical needs or retaliation by prison staff, as well as those litigating pro se (without an attorney) against government and private contractor defendants in federal court.
What happened
In Bakambia v. Bolin, prisoner Marc Amouri Bakambia, representing himself, sued a large number of staff at the Minnesota Correctional Facility-Stillwater and two medical directors employed by a private contractor called Centurion, alleging they violated his constitutional rights — primarily by being deliberately indifferent to his serious medical needs — and also raising claims under Minnesota state law. A magistrate judge recommended dismissing all claims, and Bakambia filed objections.
Judge Tostrud reviewed the objections and the underlying record. He found no error in the magistrate judge's procedural rulings, including allowing the Centurion defendants to refile a brief that had been filed in the wrong case, and permitting defendants to join each other's motions to dismiss. On the substance, the court found that the complaint's allegations about delayed prescriptions, missed follow-up appointments, and the conduct of nurses and security officers did not meet the legal standard for deliberate indifference — meaning the complaint did not plausibly allege that defendants consciously disregarded a serious risk to Bakambia's health. The court also declined to consider facts Bakambia raised from a separate lawsuit, since only the allegations in this complaint were properly before the court.
Judge Tostrud overruled all of Bakambia's objections, accepted the magistrate judge's Report and Recommendation, and granted both motions to dismiss — one filed by the state Department of Corrections defendants and one by the Centurion medical defendants. The motion for a preliminary injunction (an emergency court order requiring action before a full trial) was denied as moot because the case was being dismissed entirely. The state-law claims were also dismissed because federal courts are directed not to keep state-law claims once all federal claims are gone before trial.
The detailed version
Marc Amouri Bakambia, a prisoner at MCF-Stillwater (Minnesota Correctional Facility-Stillwater) proceeding without an attorney (pro se), filed this civil rights lawsuit under 42 U.S.C. § 1983 — a federal statute allowing individuals to sue state actors for constitutional violations — against a broad group of defendants including the warden, security staff, medical staff employed by Centurion (a private medical contractor), and the Commissioner of Corrections. His claims included Eighth Amendment deliberate indifference to serious medical needs, First Amendment retaliation for filing grievances and prior lawsuits, and various state-law claims.
Magistrate Judge Elsa M. Bullard issued a Report and Recommendation on January 27, 2026, recommending that the DOC (Department of Corrections) Defendants' motion to dismiss [ECF No. 35] and the Centurion Defendants' motion to dismiss [ECF No. 78] both be granted, that Bakambia's motion for a preliminary injunction [ECF No. 23] be denied as moot, and that the action be dismissed. Bakambia filed objections [ECF No. 130], triggering de novo review by District Judge Eric C. Tostrud under 28 U.S.C. § 636(b)(1).
Procedural Objections
Bakambia objected that Judge Bullard abused her discretion by allowing the Centurion defendants to substitute a corrected brief after filing one intended for a different case, without holding a hearing. Judge Tostrud treated these as challenges to a non-dispositive pretrial order, reversible only for clear error or contrary-to-law rulings. He found no abuse of discretion, citing the strong judicial policy favoring merits decisions (citing Chrysler Corp. v. Carey, 186 F.3d 1016 (8th Cir. 1999)). He also rejected Bakambia's objection that allowing defendants to join each other's motions was improper, finding it fell within the court's discretion and served efficiency (citing United States ex rel. Ambrosecchia v. Paddock Lab'ys, LLC, 855 F.3d 949, 956 (8th Cir. 2017)). Bakambia's argument that the motion should have been converted to a summary judgment motion under Fed. R. Civ. P. 12(d) was rejected because no materials outside the pleadings were presented.
Deliberate Indifference — Medical Claims
On the merits, Judge Tostrud reviewed de novo Bakambia's objections to findings about specific defendants. Regarding Dr. Craane (Centurion Medical Director), the court found the allegations about a missed neurosurgery follow-up and delayed prescription did not rise above gross negligence — which is insufficient for a constitutional deliberate indifference claim (citing Est. of Rosenberg ex rel. Rosenberg v. Crandell, 56 F.3d 35, 37 (8th Cir. 1995)). The complaint itself undermined Bakambia's theory: it alleged Dr. Craane delayed processing a prescription because he was waiting for transcribed notes from an appointment, not out of deliberate disregard. Regarding Nurse Morrin William and security officers Watt and Brosted, the court found the complaint failed to plausibly allege deliberate indifference. The court also declined to consider facts Bakambia alleged in a separate lawsuit but did not include in this complaint, as a Rule 12(b)(6) motion to dismiss (for failure to state a claim) is limited to the allegations in the complaint before the court.
First Amendment Retaliation
Bakambia's Count II alleged retaliation for filing a § 1983 lawsuit and grievances. Judge Bullard analyzed it as a First Amendment retaliation claim, and Judge Tostrud found no error in that analysis or in the citation to a related case, Bakambia v. Ghebre, No. 24-cv-3653 (LMP/DJF), 2025 WL 2936880 (D. Minn. May 23, 2025).
Immunity and Captain Salas
Bakambia objected that Judge Bullard failed to analyze defendants' immunity arguments; the court found this inconsequential because even without immunity, the claims failed on the merits. The claims against Defendant Captain Mercedes Salas arose only under Minnesota law, so they were properly dismissed along with all state-law claims.
Supplemental Jurisdiction over State-Law Claims
Judge Tostrud declined to exercise supplemental jurisdiction (the power of a federal court to also decide related state-law claims) over the remaining state-law claims once all federal claims were dismissed, consistent with Eighth Circuit guidance in Hervey v. County of Koochiching, 527 F.3d 711, 726–27 (8th Cir. 2008).
Disposition
All of Bakambia's objections were overruled. Both motions to dismiss were granted. The motion for a preliminary injunction was denied as moot. The entire action was dismissed. Judgment was ordered to be entered accordingly.
Reviewer note from the AI+
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.