Bakambia v. Hart
Marc Amouri Bakambia v. Alexandria Hart, in her official capacity; Kathy Reid, in her individual capacity; Christine Oberembt, in her individual and official capacities; and Michael Oliveras, in his individual and official capacities.
- Laura Provinzino
- 0:24-cv-03653
- U.S. District Court · District of Minnesota
- 2
In Bakambia v. Hart, Judge Provinzino denied prisoner Marc Amouri Bakambia's emergency motion seeking his immediate release from solitary confinement and the removal of related disciplinary charges from his record.
Prisoners or detainees who have been placed in segregation (solitary confinement) and have sought emergency court orders for release or removal of disciplinary records. Also relevant to litigants representing themselves who must understand the importance of filing timely objections to a magistrate judge's recommendations.
What happened
In Bakambia v. Hart, prisoner Marc Amouri Bakambia filed an emergency motion asking the court to order his immediate release from segregation (solitary confinement) at the prison facility where he is held and to expunge — meaning erase — disciplinary charges he described as false. The defendants are prison and government officials sued in various capacities.
Magistrate Judge Dulce J. Foster issued a Report and Recommendation on September 9, 2025, concluding that Bakambia's motion should be denied. Bakambia did not file any objections to that recommendation within the allowed time, which meant the court would review it only for obvious errors rather than conduct a full independent review.
Judge Provinzino found no clear error in Magistrate Judge Foster's Report and Recommendation and adopted it in full. As a result, Bakambia's emergency motion for release from segregation and expungement of disciplinary charges was denied.
The detailed version
Case: Marc Amouri Bakambia v. Alexandria Hart, et al., No. 24-cv-3653 (LMP/DJF), U.S. District Court for the District of Minnesota. Decision by District Judge Laura M. Provinzino, dated November 3, 2025.
Background
Plaintiff Marc Amouri Bakambia is a prisoner in a detention facility. He sued several government officials: Alexandria Hart (in her official capacity, substituted for Kathy Reid in her official capacity as of October 17, 2025), Kathy Reid (in her individual capacity), Christine Oberembt (in her individual and official capacities), and Michael Oliveras (in his individual and official capacities). The underlying claims are not detailed in this order, but the motion at issue concerned conditions of confinement.
The Motion
Bakambia filed an emergency motion (ECF No. 87) styled as a 'Motion for Emergency Injunction for Immediate Release of Mr. Bakambia from Segregation and Expunging Those False Disciplinary Charges.' A preliminary injunction is an emergency court order requiring or prohibiting action before a case is fully decided. Bakambia sought two forms of relief: (1) immediate release from segregation (solitary confinement) and (2) expungement (erasure) of the disciplinary charges he characterized as false.
Magistrate Judge's Report and Recommendation
United States Magistrate Judge Dulce J. Foster issued a Report and Recommendation (R&R) on September 9, 2025 (ECF No. 96), recommending that the motion be denied. An R&R is a preliminary recommendation by a magistrate judge that a district judge must review before issuing a final ruling.
Standard of Review
Because Bakambia did not file objections to the R&R, Judge Provinzino reviewed it only for clear error — a deferential standard — rather than conducting a de novo (fresh, independent) review. The court cited Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996), and Federal Rule of Civil Procedure 72(a).
Ruling
Judge Provinzino found no clear error in the R&R and adopted it in full. Bakambia's emergency motion (ECF No. 87) was denied. The order does not elaborate on the substantive reasons for denial beyond adopting the R&R's conclusions.
Note
The underlying case (No. 24-cv-3653) appears to remain pending; this order addresses only the emergency injunction motion, not the merits of the entire lawsuit.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.