Stanley Kappell Watson v. Shenekka Bradsher, 147 F.4th 1330

Stanley Watson, a former county commissioner, unjustly accused Sheneeka Bradsher and Zarinah Ali of stealing his wallet, demanded their arrest, and threatened law enforcement who hesitated.
Bradsher and Ali were detained by police due to Watson's persistent accusations, but Watson later found his wallet in his car.
The women sued Watson in Georgia state court for slander, battery, and false imprisonment, securing a $150,500 general verdict against him.
Watson filed for bankruptcy; the women sought to except the judgment debts from discharge under 11 U.S.C. § 523(a)(6), arguing that the debts resulted from a "willful and malicious injury."
The bankruptcy court found the false imprisonment debts nondischargeable but allowed discharge of debts for slander and battery. The district court affirmed as to false imprisonment, remanded for clarity on slander, and ultimately the false imprisonment judgment was upheld as nondischargeable by the Eleventh Circuit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are false imprisonment debts nondischargeable under §523(a)(6)?	Watson willfully and maliciously caused their confinement, making debts nondischargeable.	Watson genuinely believed plaintiffs stole his wallet; confinement was not willful or malicious.	Debts for false imprisonment are nondischargeable; Watson’s belief did not negate willful, malicious conduct.
Allocation of state trial damages between dischargeable and nondischargeable claims	Damages largely resulted from false imprisonment, so more should be excepted from discharge.	Bankruptcy court's allocation (two-thirds to false imprisonment) was arbitrary and unsupported.	Bankruptcy court’s allocation was evidence-based and not clearly erroneous.
Whether intent to injure is required for nondischargeability of intentional torts	Tort of false imprisonment requires intent to confine; injury was willful and malicious.	Intent to harm was lacking due to genuine belief in theft; injury was not willful under bankruptcy law.	Statute requires intent to cause injury, not intent for every tort element; willfulness and malice established.
Burden of proof regarding dischargeability findings	Watson has burden to show bankruptcy court’s factual findings were clearly erroneous.	Bankruptcy court improperly shifted burden for proving dischargeability/non-dischargeability.	No improper burden-shifting; Watson failed to show clear error in findings.

Kawaauhau v. Geiger, 523 U.S. 57 (1998) (discharge exception under § 523(a)(6) applies only to acts done with actual intent to cause injury, not merely intentional acts leading to injury)
Kane v. Stewart Tilghman Fox & Bianchi P.A. (In re Kane), 755 F.3d 1285 (11th Cir. 2014) (standard for willful and malicious injury in bankruptcy context)
Maxfield v. Jennings (In re Jennings), 670 F.3d 1329 (11th Cir. 2012) (malicious injury under § 523(a)(6) does not require specific intent to harm)
Rush v. JLJ, Inc. (In re JLJ Inc.), 988 F.2d 1112 (11th Cir. 1993) (standards for reviewing bankruptcy court findings)