Watson v. Bradsher

Issue: (1) Whether the term “injury” in 11 U.S.C. § 523(a)(6) denotes mere “harm” (detriment in fact) or requires the intent to invade a legally protected interest (legal injury), such that a debtor who intentionally causes harm under a genuine but mistaken belief of legal justification has not inflicted a “willful” injury; and (2) whether a debt arising from the intentional tort of false imprisonment is nondischargeable under 11 U.S.C. § 523(a)(6) when the debtor held a subjective, genuine belief that confinement would be lawful and justified, or whether a court may obviate that subjective belief by defining the “injury” as the confinement itself and implying malice from the objective “excessiveness” of the debtor’s conduct.