Bakambia v. Craane

Background

Marc Amouri Bakambia filed this prisoner civil-rights action under 42 U.S.C. § 1983 and applied to proceed without paying the full filing fee upfront. The court conducted the required initial screening of his amended complaint under 28 U.S.C. § 1915A. The complaint was about 60 pages and primarily challenged medical care at the Minnesota Correctional Facility–Stillwater and Bakambia’s efforts to obtain related records. The opinion did not decide whether those medical-care claims ultimately stated valid claims; it concluded only that they could proceed past this screening stage.

Claims Addressed

The court addressed claims unrelated to the medical-care allegations. Bakambia alleged that Jennifer Stevens denied him educational programming in retaliation for lawsuits he had previously filed. The court concluded that he did not allege facts connecting the denial of programming to those lawsuits. It noted that several months separated the earlier lawsuits from the alleged denials, that Bakambia did not allege Stevens knew about the earlier lawsuits, and that his retaliation allegation was conclusory. The court therefore recommended dismissal of the retaliation claim for failure to state a claim.

Bakambia also alleged that Stevens violated the Minnesota Government Data Practices Act by refusing to provide a list of inmates allegedly ineligible for a college program. The court concluded that the statute did not permit claims against Stevens in her individual capacity because such claims must be brought against the responsible government authority or entity. It also concluded that the official-capacity claim was barred by the state’s immunity because Minnesota had not waived immunity for this type of claim. The court therefore recommended dismissal of both versions of the data-practices claim.

Bakambia further alleged that prison officials deactivated a code needed to buy a particular type of envelope, preventing him from effectively litigating. The court found that he did not identify a defendant responsible for the alleged conduct or allege facts showing that any defendant personally caused it. It also found no plausible access-to-the-courts claim because Bakambia did not explain how the inability to buy those envelopes caused actual injury to a nonfrivolous and arguably meritorious legal claim. The court recommended dismissal of that claim. The court also noted that these unrelated claims could alternatively be severed from the medical-care claims.

Rulings

The report and recommendation recommended that the claims against Jennifer Stevens in both her individual and official capacities under the Minnesota Government Data Practices Act be dismissed for failure to state a claim; that the First Amendment retaliation claim against Stevens be dismissed for failure to state a claim; that Stevens be terminated from the action; and that the access-to-the-courts claim concerning the envelopes be dismissed for failure to state a claim.

The accompanying order denied Bakambia’s motion to file the first amended complaint as moot because the amended complaint was already timely and became the operative pleading without further permission. It directed the clerk to refile that document as the first amended complaint and granted Bakambia’s application to proceed without paying the full filing fee upfront. The order directed Bakambia to complete marshal-service forms for the remaining defendants, required payment of the unpaid $231.52 balance of the statutory filing fee through prison account deductions, and directed the U.S. Marshals Service to serve the remaining defendants under the terms stated in the order. The opinion is signed by United States Magistrate Judge Elizabeth Cowan Wright.