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 and official capacities.
- Dulce Foster
- 0:24-cv-03653
- U.S. District Court · District of Minnesota
- 3
In Bakambia v. Hart, Magistrate Judge Foster granted in part and denied in part a prisoner's motion to substitute parties, allowing Alexandria Hart to replace the deceased defendant Kathy Reid only in her official capacity, while denying substitution for individual-capacity claims and rejecting the request to add new defendants from a different prison facility.
Prisoners and other civil rights plaintiffs whose lawsuits involve a defendant who dies during proceedings, and who need to understand the distinction between official-capacity and individual-capacity claims when seeking to substitute a new party. Also relevant to litigants who seek to add new defendants based on changed circumstances (such as a prison transfer) without alleging new factual claims against those parties.
What happened
In Bakambia v. Hart (Case No. 24-cv-3653), Marc Amouri Bakambia, a prisoner at the Minnesota Correctional Facility-Lino Lakes, is suing several Minnesota Department of Corrections employees, alleging they unlawfully delayed scheduling his medical appointments while he was held at a different facility, MCF-Stillwater. During the lawsuit, one of the defendants, Kathy Reid, passed away, prompting Mr. Bakambia to file a motion to substitute her with Alexandria Hart, Ms. Reid's official successor. Mr. Bakambia also sought to add new defendants from his current facility, MCF-Lino Lakes.
The core legal question was whether Ms. Hart could step in for Ms. Reid in all respects or only in her official capacity. When a government official is sued in her 'official capacity,' the lawsuit is essentially against the office or government position she held, not her personally — so a successor in that role can be substituted. When sued in her 'individual capacity,' the lawsuit targets the person herself for her personal conduct, and her official successor does not automatically inherit that personal liability. Because Mr. Bakambia's underlying claims involve specific alleged misconduct at MCF-Stillwater, the court also found no basis to add entirely new defendants from MCF-Lino Lakes, where no relevant events are alleged to have occurred.
Magistrate Judge Foster granted the motion in part, ordering that Alexandria Hart be substituted for Kathy Reid in her official capacity only, and directed the court clerk to update the case records accordingly. The motion was denied with respect to substituting Ms. Hart for Ms. Reid's individual-capacity claims, and also denied as to adding new defendants from MCF-Lino Lakes. The court noted it was not deciding whether Mr. Bakambia's individual-capacity claim against Ms. Reid was legally extinguished by her death, as no formal motion to dismiss that claim had been filed.
The detailed version
Case: Marc Amouri Bakambia v. Alexandra Hart et al., Case No. 24-cv-3653 (LMP/DJF), United States District Court, District of Minnesota. Decided October 17, 2025, by Magistrate Judge Dulce J. Foster.
Background
Plaintiff Marc Amouri Bakambia is a prisoner who was formerly housed at the Minnesota Correctional Facility-Stillwater (MCF-Stillwater) and has since been transferred to the Minnesota Correctional Facility-Lino Lakes (MCF-Lino Lakes). He brought suit against several Minnesota Department of Corrections employees, alleging deliberate indifference to his serious medical needs — specifically that defendants Kathy Reid and Christine Oberembt unlawfully delayed the scheduling of his medical appointments while he was at MCF-Stillwater. The court had previously allowed the case to proceed only on those specific deliberate-indifference claims. During the pendency of the lawsuit, defendant Kathy Reid passed away.
The Motion
Mr. Bakambia filed a motion styled as an 'Unopposed Motion for Substitution of Parties' under Federal Rule of Civil Procedure 25(a)(1) and (d). Rule 25 governs substitution of parties when a party dies or when a public officer who is a party to a case leaves office. Mr. Bakambia sought two things: (1) to substitute Alexandria Hart, Ms. Reid's official successor, for Ms. Reid in all capacities; and (2) to add new defendants — officials at MCF-Lino Lakes who hold equivalent positions to Ms. Hart and Ms. Oberembt at MCF-Stillwater.
Ruling on Substitution
The defendants did not oppose substitution for the official-capacity claims against Ms. Reid, but opposed substitution for the individual-capacity claims, arguing those claims were extinguished by Ms. Reid's death. The court agreed with defendants in principle: individual-capacity claims seek to impose personal liability on a government official, meaning any remedy flows to the plaintiff from that specific individual, not from the office. Ms. Hart being Ms. Reid's official successor does not make her Ms. Reid's personal successor in interest. Therefore: - The motion was granted as to substituting Alexandria Hart for Kathy Reid in her official capacity. - The motion was denied as to substituting Ms. Hart for Ms. Reid in her individual capacity.
Importantly, the court expressly declined to rule on whether the individual-capacity claim against Ms. Reid was legally extinguished upon her death, because no motion to dismiss that specific claim had been presented. That question remains open.
Ruling on Adding New Defendants
The court denied Mr. Bakambia's request to add officials from MCF-Lino Lakes as new defendants. The court emphasized that the lawsuit was permitted to proceed only on the basis of specific factual allegations concerning events at MCF-Stillwater. Mr. Bakambia had not alleged facts supporting any claims against officials at his current facility, MCF-Lino Lakes. Adding new parties without supporting factual allegations was therefore not appropriate.
Court's Order
1. Alexandria Hart is substituted for Kathy Reid in her official capacity; the Clerk of Court is directed to update the docket accordingly. 2. The motion is denied in all other respects.
Note on defendant's name
The case caption spells the defendant's first name as 'Chrstine' Oberembt (apparently a typographical error for 'Christine'), and the substituted party is referred to as both 'Alexandria' and 'Alexandra' Hart in different parts of the opinion and case caption. This summary uses the spelling as it appears in the court's substantive discussion.
Reviewer note from the AI+
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