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 capacity
- Dulce Foster
- 0:24-cv-03653
- U.S. District Court · District of Minnesota
- 3
In Bakambia v. Hart, Magistrate Judge Foster denied prisoner Marc Amouri Bakambia's motion asking the court to force defendants to rewrite their answer and to order his prison to give him more law library time.
Incarcerated individuals litigating civil cases who seek court orders requiring prisons to provide more law library access, and litigants attempting to use Federal Rule of Civil Procedure 12(e) to compel defendants to rewrite their answers.
What happened
In Bakambia v. Hart, prisoner Marc Amouri Bakambia sued several Minnesota Department of Corrections employees and filed a motion with two requests: (1) that the defendants be required to rewrite their answer to his complaint because he believed it was evasive, and (2) that the court order his prison, Minnesota Correctional Facility-Lino Lakes, to give him at least two hours of law library access per week so he could prepare his case.
On the first request, the court found that the procedural rule Mr. Bakambia relied on — Federal Rule of Civil Procedure 12(e), which allows a party to demand a clearer pleading — simply does not apply to an answer filed by a defendant. That rule only covers documents that require a response, and a defendant's answer does not require one unless the court separately orders it. The court had not done so here, making his argument legally unavailable. On the second request, the court noted that managing law library schedules is a matter of internal prison administration, which courts must approach with caution before overriding. The court also pointed to Mr. Bakambia's own submitted documents, which showed he had recently been scheduled for three law library slots within one week, received a one-hour slot the following week, and was told by the law librarian he could request hour-long slots going forward.
Magistrate Judge Foster denied both parts of the motion in full. The court did leave open one avenue for Mr. Bakambia: if he is ever unable to meet a court-set deadline specifically because of limited law library access, he may file a separate motion asking for more time and explaining why, after first discussing the request in good faith with the opposing side's attorney.
The detailed version
Case: Marc Amouri Bakambia v. Alexandra Hart et al., No. 24-cv-3653 (LMP/DJF), U.S. District Court for the District of Minnesota. Decision issued October 22, 2025, by United States Magistrate Judge Dulce J. Foster.
Background
Plaintiff Marc Amouri Bakambia is a prisoner who was recently transferred from the Minnesota Correctional Facility-Stillwater (MCF-Stillwater) to the Minnesota Correctional Facility-Lino Lakes (MCF-Lino Lakes). The defendants are current or former Minnesota Department of Corrections employees stationed at MCF-Stillwater, sued in various official and individual capacities. The underlying case (ECF No. 1) is not described in detail in this order.
The Motion (ECF No. 107)
Mr. Bakambia filed a combined motion seeking two forms of relief: 1. An order directing defendants to amend their answer to his complaint, which he characterized as evasive. 2. An order requiring the prison to provide him two hours per week of law library access to allow him to litigate the case.
Ruling on Request 1 — More Definite Answer
The court denied this request. Mr. Bakambia invoked Federal Rule of Civil Procedure 12(e), which permits a party to move for a more definite statement of a pleading 'to which a responsive pleading is allowed.' The court held that Rule 12(e) is inapplicable here because an answer (the defendants' filing) is not itself a document that requires a response under the Federal Rules of Civil Procedure — specifically Federal Rule of Civil Procedure 7(a)(7) — unless the court separately orders a reply. No such order had been issued, making Mr. Bakambia's reliance on Rule 12(e) legally misplaced.
Ruling on Request 2 — Law Library Access
The court also denied this request. Mr. Bakambia stated he was limited to 30-minute windows of law library time — windows that included travel time to and from the library — and that these slots occurred only once a week, once every other week, or sometimes only once a month (ECF No. 109 at 1-2). He argued this was insufficient to prepare his case.
The court applied the principle from Goff v. Harper, 60 F.3d 518, 520 (8th Cir. 1995), that courts must exercise restraint before compelling changes to prison administration. The court then examined Mr. Bakambia's own submitted exhibits (ECF No. 114), which showed: (a) he had been scheduled for three separate law library time slots within a single week; (b) he received an hour-long slot the following week; and (c) the law librarian informed him he could request hour-long slots in the future. Based on this record evidence, the court concluded that Mr. Bakambia's situation was not dire enough to warrant judicial intervention into prison operations.
Important Caveat
The court noted that if Mr. Bakambia is unable to meet a court-ordered deadline due to inadequate law library access, he may file a motion requesting an extension of time, provided he first meets and confers in good faith with opposing counsel before doing so (consistent with how he handled this motion).
Disposition
Motion (ECF No. 107) DENIED in its entirety.
Reviewer note from the AI+
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.