Jonathan C. Davis v. Telfair County

USCA11 Case: 25-12765 Document: 45-1 Date Filed: 08/25/2026 Page: 1 of 5

NOT FOR PUBLICATION

In the United States Court of Appeals

For the Eleventh Circuit ____________________ No. 25-12765 Non-Argument Calendar ____________________

JONATHAN C. DAVIS,

Plaintiff-Appellant, versus TELFAIR COUNTY, through its Commission Chair Edwin Neal, in his official capacity, EDWIN NEAL, ANNIE WILLIAMS, JASONBOONE, JASON WHITE, Telfair County Commissioners, individual and official capacities, et al.,

Defendants-Appellees, THE SOUTHLAND MEDICAL GROUP, LLC., d.b.a. Southland Medical, et al.,

Defendants. 2 Opinion of the Court 25-12765

____________________

Appeal from the United States District Court for the Southern District of Georgia D.C. Docket No. 3:22-cv-00145-DHB-BKE ____________________

Before JILL PRYOR, NEWSOM, and BRANCH, Circuit Judges.

PER CURIAM:

Jonathan Davis alleges that he suffered various deprivations of his constitutional rights under 42 U.S.C. §§ 1983 and 1985(3) at the hands of Telfair County and its officers (“Telfair County De- fendants”) while detained at Telfair County Jail. He also alleges that Dodge County Hospital (“Hospital”), to which he was taken following the alleged assault, violated the Emergency Medical Treatment and Labor Act. Among other things, he seeks to re- cover medical expenses stemming from this incident. However, because Davis had these very same medical expenses discharged in a prior bankruptcy proceeding and because he disavowed under oath any interest in any potential cause of action during that pro- ceeding, the district court dismissed his claim under the doctrine of judicial estoppel. We affirm.

I

On or around October 21, 2020, Davis claims that he was assaulted in violation of his constitutional rights while detained at the Telfair County Jail. Facing extensive medical bills, he filed Chapter 7 bankruptcy on August 11, 2022. In his form bankruptcy petition, Davis answered “no” to the question whether he had any 25-12765 Opinion of the Court 3 “claims against third parties, whether or not you have filed a law- suit or made a demand for payment.” But when later asked in the same petition to disclose “other contingent and unliquidated dam- ages of every nature,” Davis acknowledged that he had a “[p]oten- tial cause of action against Telfair County et al for assault, forgery & neglect.”

On September 12, 2022, Chapter 7 Trustee Joelyn Pirkle conducted the meeting of creditors required under 11 U.S.C. § 341. At that meeting, Davis was asked directly: “Do you have a possible claim or lawsuit against anyone for personal injury, medical mal- practice, medical device, anything of that nature?” Davis re- sponded, under oath, that while “there was a possibility of that,” he had “been told since that we really don’t have anything . . . ba- sically there’s nothing they can do about, you know . . . I’ve learned a lot of the law and how it goes.” On the basis of that tes- timony, Pirkle deemed Davis’s bankruptcy a “no asset” case and abandoned the “potential cause of action” back to Davis.

Only weeks later, on October 21, 2022, Davis filed this action in the district court seeking recovery for what he claims are assault- linked constitutional violations. Among other damages, he seeks “medical expenses” relating to his injuries that he alleges he sus- tained while detained in jail.

On November 21, 2022, the bankruptcy court granted Davis a discharge of all his debts. Davis did not tell the bankruptcy court—nor even his bankruptcy lawyer—that he had filed this ac- tion in district court. And it was only in discovery in this case that 4 Opinion of the Court 25-12765 the Telfair County Defendants and the Hospital learned about the concurrent bankruptcy proceedings. Upon learning of this pro- ceeding, the defendants promptly amended their answers to assert a judicial estoppel defense. And the district court subsequently concluded that Davis’s claims were barred by the doctrine of judi- cial estoppel and granted both the Telefair County Defendants and the Hospitals summary judgment.

II

“Because judicial estoppel is an equitable doctrine, we re- view the district court’s decision to apply the doctrine for abuse of discretion.” Slater v. U.S. Steel Corp., 871 F.3d 1174, 1180 n.4 (11th Cir. 2017) (en banc). Judicial estoppel is appropriate when “the plaintiff (1) took a position under oath in the bankruptcy proceed- ing that was inconsistent with the plaintiff’s pursuit of the civil law- suit and (2) intended to make a mockery of the judicial system.” Id. at 1180. A district court’s discretion is guided by “all the facts and circumstances of the particular case.” Id. at 1185.

Here, both prongs are met. The first prong is straightfor- ward. During the creditor meeting, Davis declared under oath that while “[t]here was a possibility” of suit, he had been told “there’s nothing they can do about it.” This gave the trustee the unmistak- able impression that between Davis’s two contradictory responses on his petition about the existence of a claim against a third party, he meant it when he checked “no.” That he now seeks relief on a personal-injury claim is plainly inconsistent with the position he took under oath.

25-12765 Opinion of the Court 5

The district court similarly did not abuse its discretion in deeming the second prong satisfied. In finding that Davis intended to make a mockery of the judicial system, the district court high- lighted that Davis was “no stranger to judicial process,” having ob- tained bankruptcy relief once before. The district court also under- scored that Davis was set on bringing this present action from the moment he was released from jail, as evidenced by his hiring an attorney to send a notice of representation to Telfair County just 11 days after his release, consulting with at least six attorneys in connection with this suit, and meeting with his attorney in this ac- tion prior to his meeting of creditors. The district court further concluded that Davis intended to mislead the bankruptcy court by “failing to notify the Bankruptcy Trustee or his bankruptcy attor- ney” of this action prior to the discharge of his debts while admit- ting at deposition in the bankruptcy court that he specifically sought discharge of medical debts he incurred as a direct result of the de- fendants’ alleged actions. It was therefore “unmistakable” to the district court that Davis’s motivation was to “gain[] a substantial discharge of debts and the opportunity in this case to nevertheless recover money to which no creditor would have access.” Taking all of this together, we cannot say the district court abused its dis- cretion in determining that Davis intended to make a mockery of the judicial system in this action.

AFFIRMED.