Bakambia v. Hart

Background

Marc Amouri Bakambia, who was incarcerated at the Minnesota Correctional Facility—Lino Lakes, brought claims based on events at the Minnesota Correctional Facility—Stillwater. He alleged that defendants were deliberately indifferent to his medical needs by delaying the scheduling of an off-site appointment with Dr. Todd, a neurologist at the Noran Neurological Clinic, in 2024.

The opinion addresses claims against Tammy Maenke, Jill Cairns, Beth Garnett, and Centurion. Maenke, Cairns, and Garnett were employees of Centurion, a private entity that provides services to the Minnesota Department of Corrections, including scheduling off-site medical appointments. The defendants filed an original motion to dismiss, followed by an amended motion adding Centurion as a moving party.

Rule 12(b)(6) Standard

The court applied Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim for relief. At this stage, the court generally assumes the complaint’s factual allegations are true and draws reasonable inferences in the plaintiff’s favor, but it does not accept unsupported conclusions or a bare recitation of legal requirements.

Claims Against the Individual Centurion Defendants

For a claim that prison officials were deliberately indifferent to serious medical needs, a plaintiff must allege both an objectively serious medical need and that the defendant knew about the need but deliberately disregarded it.

The court found that Bakambia adequately alleged that the individual defendants handled scheduling activities, reported deferred requests, and repeatedly failed to schedule neurologist follow-up appointments ordered by practitioners. But the court found that he did not adequately allege that these defendants knew about his medical conditions or understood that the appointments addressed serious medical needs. The complaint did not allege that they had medical expertise, knew the medical significance of delaying the appointments, or would have recognized the risks involved. The court therefore recommended granting the motions to dismiss as to Maenke, Cairns, and Garnett.

Claim Against Centurion

Although Bakambia did not specifically name Centurion in the amended complaint, the court had construed his official-capacity claims against Centurion employees as claims against Centurion because they worked for that private entity.

To state a civil-rights claim against a private entity under 42 U.S.C. § 1983, a plaintiff must allege that the entity had a policy or customary practice that caused the constitutional violation, or that the violation resulted from inadequate training or supervision. The court found that Bakambia alleged neither a Centurion policy or custom nor a failure to train or supervise employees. It therefore recommended granting the amended motion to dismiss as to Centurion.

Recommendation and Procedure

Judge Dulce J. Foster recommended that the original motion to dismiss filed by Maenke, Cairns, and Garnett be granted; that the amended motion to dismiss filed by Maenke, Cairns, Garnett, and Centurion be granted; and that all claims against those four defendants be dismissed without prejudice.

The document is a magistrate judge’s report and recommendation, not a final district court order or judgment. It states that it is not directly appealable to the U.S. Court of Appeals for the Eighth Circuit and that the parties may file written objections within the periods stated in the notice.