David Watts v. Kevin Jones

CourtCourt of Appeals for the Seventh Circuit
DecidedMay 29, 2026
Docket25-1046
StatusPublished
AuthorEasterbrook

This text of David Watts v. Kevin Jones (David Watts v. Kevin Jones) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
David Watts v. Kevin Jones, (7th Cir. 2026).

Opinion

In the United States Court of Appeals For the Seventh Circuit ____________________

No. 25-1046 DAVID W. WATTS, Plaintiff-Appellee, v.

KEVIN JONES and MARK SMIT, Defendants-Appellants. ____________________

Appeal from the United States District Court for the Western District of Wisconsin. No. 23-cv-87-wmc — William M. Conley, Judge. ____________________

ARGUED SEPTEMBER 25, 2025 — DECIDED MAY 29, 2026 ____________________

Before BRENNAN, Chief Judge, and EASTERBROOK and SYKES, Circuit Judges. EASTERBROOK, Circuit Judge. Two detectives investigating an inmate at the Wisconsin Secure Program Facility tried to speak with David Watts, another inmate, who had sent letters suggesting that he had valuable information about a murder and an attempted murder. One detective appeared at Watts’s cell. He feared that the inmate under investigation would get wind of anything he said, so he refused to talk. Watts relates that, even so, he was threatened and harassed. Though no 2 No. 25-1046 physical harm came to him, Watts filed this suit under 42 U.S.C. §1983 seeking damages from the detectives for expos- ing him to risk. Watts asked the district court to conduct the litigation un- der seal, and it largely obliged. Many papers were withheld from the public record, and others were heavily redacted. Af- ter the district court denied the defendants’ motion for sum- mary judgment, they took an immediate appeal to argue for qualified immunity. Watts asked us to conduct the appeal un- der seal. A motions judge of this court declined but author- ized redactions so severe that the case was docketed—and the briefs were captioned—as “Appellee v. K.J. and M.S.” The use of pseudonyms was explored at oral argument, during which the defendants consented to the disclosure of their names. Watts continued to assert a right to anonymity, but this court found secrecy unjustified and entered an order (reproduced as an appendix to this opinion) giving him a choice between withdrawing the suit and having his name placed in the public record. After that time passed without ac- tion on his part, the court revised the docket to use the parties’ real names. The facts that matter are few: defendants allowed other in- mates to learn (or suspect) that Watts furnished information valuable to an ongoing investigation. They asked Watts to meet them in an interview room, but he refused. That led one detective to appear at Watts’s cell and ask about a letter (but without referring to the letter’s contents). Watts refused to talk with the detective. He submits, however, that just by coming to the cell and mentioning a letter, the detective put him in danger—and Watts contends that the detective wanted the other inmate to learn that he was willing to talk. No. 25-1046 3 Watts suggests that we lack appellate jurisdiction, but an interlocutory appeal is proper when the public officials con- fine attention to the question whether the claim rests on clearly established law. Green v. Newport, 868 F.3d 629, 632 (7th Cir. 2017). The detectives have accepted all of the district judge’s conclusions about what facts a jury could find, and having done this they are entitled to present arguments about the state of the law. We know from Farmer v. Brennan, 511 U.S. 825 (1994), that prison guards may not inflict punishment by allowing in- mates to harm each other. We may assume that the same rule applies to detectives visiting a prison and that these detectives were deliberately indifferent to the risk that appearing at Watts’s cell door would lead other prisoners to harm Watts. But physical harm did not occur; he was hassled but not at- tacked. The question for qualified immunity: is it clearly es- tablished that public employees can be liable in damages when their choices do not lead to a prisoner’s bodily injury? Recognizing that Watts has not been injured physically, the district judge concluded that his recovery is limited to $1 in nominal damages, plus any punitive damages that a jury may see fit to award. Presumably the $1 would be a response to emotional injury, and it would encounter problems under 42 U.S.C. §1997e(e): “No Federal civil action may be brought by a prisoner confined in a jail, prison, or other correctional facility, for mental or emotional injury suffered while in cus- tody without a prior showing of physical injury or the com- mission of a sexual act[.]” All of Watts’s claims in this suit are difficult to square with §1997e(e). But the deeper problem is that there cannot be any recov- ery under §1983, nominal or punitive, unless it was clearly es- tablished at the time of the events that the defendants violated 4 No. 25-1046 the plaintiff’s rights. See, e.g., Zorn v. Linton, 146 S. Ct. 926 (2026) (summarizing the law of qualified immunity). And nei- ther the district court nor counsel for Watts has pointed to a decision clearly establishing that exposing a prisoner to a risk of physical harm that never comes to pass violates the Consti- tution. Quite the contrary, the norm in many parts of tort law is that risk alone is inadequate. See, e.g., Metro-North Commuter R.R. v. Buckley, 521 U.S. 424 (1997) (no liability for fear of dis- ease, caused by exposure to a carcinogen, if disease does not develop). When concluding that Watts has clearly established law on his side, the district judge pointed to decisions such as Monfils v. Taylor, 165 F.3d 511 (7th Cir. 1998), which held it clearly established that the release by police of tape record- ings showing that Thomas Monfils had identified a co-worker as a thief violated the Constitution, when the police expressly promised Monfils to maintain confidentiality. The judge cited many other decisions observing that allowing a prisoner to be identified as a snitch puts that person in danger. Thomas Monfils was not a prisoner, and Monfils goes about as far as an appellate court can in departing from the norm, see DeShaney v. Winnebago County Department of Social Services, 489 U.S. 189 (1989), that public officials do not owe free citizens a duty to protect them from harm. But Watts does not get mileage from Monfils, and not just because the defend- ants never promised Watts to maintain confidentiality. Thomas Monfils paid with his life for the police department’s error. He was “discovered at the bottom of [a] vat. The body was mutilated—the vat had propellers that stirred the thick pump mixture. A rope, with a 50-pound weight, was tied to Monfils’ neck.” 165 F.3d at 513. The suit was filed by Susan Monfils, administrator of his estate. Monfils does not establish a rule that a person not harmed physically following No. 25-1046 5 disclosure of information known to the police has a clearly es- tablished right to recover under §1983. At oral argument, counsel for Watts invoked Babcock v. White, 102 F.3d 267 (7th Cir. 1996), for the proposition that an unharmed inmate has a constitutional claim against guards who fail to protect him from other inmates, even when the feared harm does not occur. But Babcock actually establishes the opposite rule, holding (id. at 270–73) that the inmate can- not obtain damages for risk of harm.

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David Watts v. Kevin Jones, Counsel Stack Legal Research, https://law.counselstack.com/opinion/david-watts-v-kevin-jones-ca7-2026.