“Intent to Confine” Suffices: Eleventh Circuit Holds False-Imprisonment Judgments Are Nondischargeable under § 523(a)(6) Despite Debtor’s Good-Faith Belief

1. Introduction

The Court of Appeals for the Eleventh Circuit, in Stanley Kappell Watson v. Shenekka Bradsher, No. 24-11389 (Aug. 4 2025), addressed whether a state-court judgment for false imprisonment may be discharged in Chapter 7 bankruptcy when the debtor claims a genuine (but mistaken) belief in the victim’s guilt. The decision clarifies the “willful and malicious injury” exception in 11 U.S.C. § 523(a)(6) and sets a precedent that an intent to cause the confinement itself—not intent to cause an unlawful confinement—is sufficient to make the resulting debt nondischargeable.

Parties:

Plaintiff–Appellant / Debtor: Stanley K. Watson, former DeKalb County Commissioner.
Defendants–Appellees / Judgment Creditors: Shenekka Bradsher and Zarinah Ali.

After a jury awarded the women $150,500 for slander, false imprisonment, and battery arising from a nightclub incident, Watson filed for Chapter 7 relief. The Bankruptcy Court, later upheld by the District Court and now by the Eleventh Circuit, ruled that only the portions of the judgment attributable to false imprisonment are nondischargeable.

2. Summary of the Judgment

The Eleventh Circuit affirmed:

The bankruptcy court’s finding that Watson willfully and maliciously injured Bradsher and Ali by procuring their confinement, rendering those debts nondischargeable under § 523(a)(6).
The bankruptcy court’s two-thirds allocation of compensatory, punitive, and fee awards to the nondischargeable false-imprisonment component of the state-court verdict.

Key holdings:

“Willful” under § 523(a)(6) requires intent to cause the injury (here, confinement), not intent to violate the law.
“Malicious” can be implied from wrongful and excessive conduct; specific ill will is unnecessary.
A debtor’s bona fide yet mistaken belief that the victims committed a crime does not insulate him from nondischargeability when he procures their arrest.

3. Analysis

3.1 Precedents Cited and Their Influence

Kawaauhau v. Geiger, 523 U.S. 57 (1998) – Supreme Court held § 523(a)(6) covers “acts done with the actual intent to cause injury.” The panel applied Geiger to spotlight intent to confine as the requisite injury.
SE Prop. Holdings, LLC v. Gaddy, 977 F.3d 1051 (11th Cir. 2020) – Restated Eleventh Circuit’s “intentional act with purpose or substantial certainty of injury” test for willfulness.
In re Kane, 755 F.3d 1285 (11th Cir. 2014); In re Jennings, 670 F.3d 1329 (11th Cir. 2012); In re Walker, 48 F.3d 1161 (11th Cir. 1995); In re Ikner, 883 F.2d 986 (11th Cir. 1989) – Established that malice can be implied from “wrongful and excessive” acts without specific animus.
Georgia tort precedents (Stewart v. Williams, 255 S.E.2d 699 (Ga. 1979); Fields v. Kroger Co., 414 S.E.2d 703 (Ga. Ct. App. 1992)) – Confirm false imprisonment requires intent to confine, supporting the bankruptcy court’s willfulness analysis.
Fifth Circuit cases (In re Miller, In re Williams) – Cited to show that labeling a tort “intentional” is insufficient; the debtor must intend the specific injury.

The panel synthesized these authorities to hold that once a debtor intends the confinement, the subjective belief in its lawfulness is irrelevant to § 523(a)(6).

3.2 Court’s Legal Reasoning

Willful Injury – The injury is the detention itself. Watson’s relentless demands, threats, and status-based intimidation made it “substantially certain” that the women would be confined; thus the injury was intentional.
Malicious Injury – Conduct was “wrongful and without just cause or excessive.” The court inferred malice from Watson’s profane harassment, abuse of public office, and disregard for contrary evidence.
No “Good-Faith Defense” – Eschewing a subjective good-faith component, the court held that intentional confinement cannot be cleansed by mistaken beliefs.
Allocation Methodology – Using testimony on emotional harm, the bankruptcy court reasonably attributed two-thirds of damages to loss of liberty, and the Eleventh Circuit found no clear error.

3.3 Potential Impact

The decision tightens the nondischargeability net around debtors who:

Prosecute or instigate wrongful arrests, even out of sincere belief.
Leverage governmental or positional authority to effectuate confinement.

Going forward, debtors in the Eleventh Circuit cannot rely on “good-faith mistake” to discharge judgments for:

False imprisonment, malicious prosecution, or other liberty-depriving torts.
Certain defamation or abuse-of-process awards where intent to injure can be framed as intent to restrict liberty or legal rights.

Practitioners should expect closer scrutiny of settlement agreements and jury verdicts involving personal liberty harms, and plaintiffs may strategically plead false imprisonment to preserve nondischargeability leverage.

4. Complex Concepts Simplified

Discharge / Nondischargeable Debt – A Chapter 7 discharge wipes out most pre-petition debts; § 523 lists categories that survive bankruptcy (the creditor may still collect).
§ 523(a)(6) – Bars discharge of debts for “willful and malicious injury.” “Willful” = intentional injury; “malicious” = wrongful or excessive conduct without just cause.
False Imprisonment (Georgia) – Unlawful detention of a person, intentional, no physical force required; words or threats suffice.
General Verdict – Jury announces a lump-sum award without specifying amounts per claim; bankruptcy court may later apportion between dischargeable and nondischargeable components.
Clear-Error Review – Appellate courts overturn trial findings only if left with a “definite and firm conviction” that a mistake occurred. This deferential standard preserved the bankruptcy court’s factual allocations.

5. Conclusion

Watson v. Bradsher fortifies the principle that liberty-based tort judgments are presumptively nondischargeable when the debtor intentionally sets confinement in motion, regardless of subjective beliefs about guilt. The decision:

Clarifies that “willful injury” focuses on the deliberate act producing harm, not on the actor’s legal assessment.
Affirms malice can be implied from abusive, excessive conduct—even absent personal hatred.
Endorses pragmatic allocation of jury awards between dischargeable and nondischargeable components.

This precedent will guide bankruptcy courts within the Eleventh Circuit and beyond, signaling that victims of wrongful confinement retain powerful collection rights despite a perpetrator’s bankruptcy filing.