Jerome Watts v. Milwaukee County Clerk of Court, Milwaukee County Jail, and Milwaukee County Sheriff

CourtDistrict Court, E.D. Wisconsin
DecidedMarch 19, 2026
Docket2:26-cv-00069
StatusUnknown

This text of Jerome Watts v. Milwaukee County Clerk of Court, Milwaukee County Jail, and Milwaukee County Sheriff (Jerome Watts v. Milwaukee County Clerk of Court, Milwaukee County Jail, and Milwaukee County Sheriff) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jerome Watts v. Milwaukee County Clerk of Court, Milwaukee County Jail, and Milwaukee County Sheriff, (E.D. Wis. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

JEROME WATTS,

Plaintiff,

v. Case No. 26-cv-0069-bhl

MILWAUKEE COUNTY CLERK OF COURT, MILWAUKEE COUNTY JAIL, and MILWAUKEE COUNTY SHERIFF,

Defendants.

SCREENING ORDER

Plaintiff Jerome Watts, who is currently serving a state prison sentence at the Green Bay Correctional Institution and representing himself, filed a complaint under 42 U.S.C. §1983, alleging that his civil rights were violated. This matter comes before the Court on Watts’ motion for leave to proceed without prepaying the full filing fee and to screen the complaint. MOTION TO PROCEED WITHOUT PREPAYING THE FILING FEE Watts has requested leave to proceed without prepaying the full filing fee (in forma pauperis). A prisoner plaintiff proceeding in forma pauperis is required to pay the full amount of the $350.00 filing fee over time. See 28 U.S.C. §1915(b)(1). As required under 28 U.S.C. §1915(a)(2), Watts has filed a certified copy of his prison trust account statement for the six-month period immediately preceding the filing of his complaint and has been assessed and paid an initial partial filing fee of $15.63. Watts’ motion for leave to proceed without prepaying the filing fee will be granted. SCREENING OF THE COMPLAINT The Court has a duty to review any complaint in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity and must dismiss any complaint or portion thereof if the prisoner has raised any claims that are legally “frivolous or malicious,” that fail to state a claim upon which relief may be granted, or that seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. §1915A(b). In screening a complaint, the Court must determine whether the complaint complies with the Federal Rules of Civil Procedure and states at least plausible claims for which relief may be granted. To state a cognizable claim under the federal notice pleading system, a plaintiff is required to provide a “short and plain statement of the claim showing that [he] is entitled to relief.” Fed. R. Civ. P. 8(a)(2). It must be at least sufficient to provide notice to each defendant of what he or she is accused of doing, as well as when and where the alleged actions or inactions occurred, and the nature and extent of any damage or injury the actions or inactions caused. “The pleading standard Rule 8 announces does not require ‘detailed factual allegations,’ but it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). “The tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions. Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. A complaint must contain sufficient factual matter, accepted as true, to “state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. at 556. “[T]he complaint’s allegations must be enough to raise a right to relief above the speculative level.” Id. at 555 (internal quotations omitted). ALLEGATIONS OF THE COMPLAINT According to Watts, sometime before he was convicted, the judge in his criminal case placed him on “GPR” status after the district attorney noted that Watts had violated a no-contact order when he sent an email request to the mother of an alleged victim. Watts explains that once on GPR status, all of his mail, telephone, visitation, and tablet privileges were stopped. Watts asserts that the judge stated it was up to Milwaukee County Jail officials whether to remove him from GPR status, but jail officials refused to do so because the judge would not enter a new order removing the status. Watts states that he tried to explain that his cellmate had most likely sent the offending email request, but the status was still applied. While not entirely clear, it does not appear that the status has any current impact on Watts now that he has been convicted and is confined in a state institution, but Watts states that the status will apply if he ever returns to the jail. Watts asserts that he was unable to contact his family or conduct legal research for nearly a year while housed at the jail. THE COURT’S ANALYSIS Watts fails to state a claim because his complaint does not include sufficient factual content for the Court to reasonably infer that someone violated his constitutional rights. See Fed. R. Civ. P. 8. Watts asserts that the judge in his criminal case imposed the restriction, but Watts does not sue the judge, presumably because he knows that judges are absolutely immune for performing actions “that are ‘closely associated with the judicial process.’” Smith v. Schwarz, 46 F. App’x 374, 375 (7th Cir. 2002) (quoting Cleavinger v. Saxn’r, 474 U.S. 193, 200 (1985)). Instead, Watts sues the Milwaukee County Clerk of Court and the Milwaukee County Sheriff without any explanation of how they were involved in the alleged violation of his rights. This is legally improper. Section 1983 requires that an individual defendant be personally involved in the alleged constitutional violation. Colbert v. City of Chicago, 851 F.3d 649, 657 (7th Cir. 2017). This means that a plaintiff must include allegations that connect the person he is suing to the alleged misconduct. Id. Watts makes no mention, however, of either the Clerk of Court or the Sheriff in the body of his complaint, and the Court will not speculate how—if at all—they were involved. To the extent Watts named them as Defendants because they are supervisors, the Court notes that the doctrine of respondeat superior cannot be used to hold a supervisor liable for the misconduct of a subordinate. Gentry v. Duckworth, 65 F.3d 555, 561 (7th Cir. 1995). The only other Defendant Watts names is the Milwaukee County Jail, but the jail is a building, not a “person” for purposes of §1983. See Whiting v. Marathon Cnty. Sherriff’s Dep’t, 382 F.3d 700, 704 (7th Cir. 2004). Finally, and in any event, the Court notes that it is not clear from Watts’ allegations whether anyone at the jail is responsible for the continued enforcement of the restriction. Watts asserts that the judge ordered application of the restriction and that, when jail officials requested that the judge remove the restriction, the judge refused.

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Related

Cleavinger v. Saxner
474 U.S. 193 (Supreme Court, 1985)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Smith v. Schwarz
46 F. App'x 374 (Seventh Circuit, 2002)
Colbert v. City of Chicago
851 F.3d 649 (Seventh Circuit, 2017)

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Bluebook (online)
Jerome Watts v. Milwaukee County Clerk of Court, Milwaukee County Jail, and Milwaukee County Sheriff, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jerome-watts-v-milwaukee-county-clerk-of-court-milwaukee-county-jail-and-wied-2026.