Bakambia v. Schnell
- Nancy Brasel
- 0:20-cv-01434
- U.S. District Court · District of Minnesota
- 5
In Bakambia v. Schnell, Judge Menendez granted in part and denied in part the motion to amend the complaint.
Marc Amouri Bakambia may proceed in this case with amendments related to his original medical-care and access-to-courts claims, but may not add the COVID-19 allegations through this motion. The defendants must respond to the operative amended complaint within 14 days.
What happened
In Bakambia v. Schnell, Marc Amouri Bakambia asked to add defendants and allegations concerning medical care after an assault, access to courts, and COVID-19. The defendants did not oppose the amendments concerning the original claims, but they opposed adding the COVID-19 allegations.
The court allowed Bakambia to add defendants and allegations connected to his claims about medical care after the assault and his access-to-courts claim. It refused to add allegations that a corrections officer deliberately exposed him to COVID-19 and that defendants failed to provide adequate care after his infection, because those events were unrelated to the original lawsuit and adding them would cause delay and require new discovery.
In Bakambia v. Schnell, Judge Katherine Menendez granted in part and denied in part the motion to amend. The court treated the existing amended complaint as the operative pleading and ordered the defendants to respond within 14 days. The order said Bakambia was not barred from raising the COVID-19 issues in a separate case.
The detailed version
- Bakambia v. Schnell · No. 0:20-cv-01434
- Nancy Brasel
- Apr. 26, 2021
Background
Marc Amouri Bakambia moved to amend his complaint. His original claims concerned the adequacy of medical care after a May 20, 2019 assault by other inmates while he was incarcerated at MCF-Rush City, and alleged interference with his attempts to contact a lawyer. His proposed amended complaint added allegations against additional Minnesota Department of Corrections personnel and included allegations related to those original claims.
Bakambia also sought to add claims concerning events in October and November 2020. He alleged that a corrections officer deliberately exposed him to COVID-19, that he later tested positive, and that his treatment and medical attention were delayed. The opinion states that these allegations could be understood as claims under the Eighth Amendment, including deliberate indifference to serious medical needs.
Legal standard
Federal Rule of Civil Procedure 15 generally requires courts to allow amendments when justice requires, but courts may deny leave for reasons including undue delay, prejudice, or futility. The court also explained that a supplemental pleading may address events occurring after the original pleading when those events pertain to the original cause of action. Courts may deny amendments or supplements that are unrelated to the original complaint and would make the litigation inefficient or confusing.
Analysis and ruling
The court granted the motion in part to allow new defendants and factual allegations concerning the original medical-care claims and the access-to-courts claim. The original Department of Corrections defendants and the Centurion defendants did not oppose those proposed amendments.
The court denied the motion to the extent Bakambia sought to add allegations about deliberate exposure to COVID-19. Although those events occurred after the case began, the court found that they were not related to the original complaint. Adding them would require a new round of discovery, substantially modify the case schedule, and delay resolution of the issues already in the lawsuit.
The court ordered that the amended complaint at docket entry 117 would be the operative pleading. It ordered the defendants to file responsive pleadings within 14 days of the order. The court stated that denying leave to add the COVID-19 claims in this case did not prevent Bakambia from raising those issues in a separate action.
Disposition
The motion to amend was GRANTED IN PART and DENIED IN PART. The case was not dismissed, and the order did not decide the merits of the underlying medical-care, access-to-courts, or COVID-19 allegations.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.