Dana Watson v. Metropolitan Enforcement Group of Southern Illinois

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted June 16, 2026*
Decided June 16, 2026
Before
MICHAEL B. BRENNAN, Chief Judge
FRANK H. EASTERBROOK, Circuit Judge
JOHN Z. LEE, Circuit Judge
No. 25-1051
DANA WATSON,
Plaintiff-Appellant,
v.
METROPOLITAN ENFORCEMENT
GROUP OF SOUTHERN ILLINOIS,
et al.,
Defendants-Appellees.
Appeal from the United States District
Court for the Southern District of
Illinois.
No. 24-cv-1835-SMY
Staci M. Yandle,
Chief Judge.
O R D E R
Dana Watson sued a multijurisdictional law enforcement task force, the state
police, and individual officers to reclaim cash and a handgun they seized from her
* We have agreed to decide the case without oral argument because the briefs and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 25-1051 Page 2
home. The district court dismissed her complaint under the doctrine of claim preclusion
because her previous complaint covering the same events had been dismissed as
untimely. See Watson v. Metro. Enf’t Grp. of S. Ill., No. 23-1412, 2023 WL 5276607 (7th Cir.
Aug. 16, 2023) (nonprecedential decision) (Watson I). Because Watson’s complaint is
either precluded or otherwise fails to state a federal claim, we affirm the judgment.
In 2022, Watson filed a complaint against the Metropolitan Enforcement Group
of Southern Illinois under 42 U.S.C. § 1983 alleging several constitutional violations.1
She alleged that in January 2014, task-force officers executed a no-knock warrant at her
home in East St. Louis, where they seized drugs, $1,892 in cash, and her handgun.
Watson’s husband was charged with drug and firearm offenses. The state also sought
forfeiture of the cash. Watson challenged the forfeiture, and in 2018, the state
voluntarily dismissed the proceedings, but the funds and gun remained as evidence in
the criminal case. Three years later, the state trial court ordered the funds released from
evidence to Watson, but she asserts that she has been unable to access them and that the
gun remains in the clerk’s possession as evidence.
The district court dismissed Watson’s 2022 complaint as untimely under Illinois’s
two-year statute of limitations because her claims accrued in 2014. See 735 ILCS
5/13-202. We affirmed that decision in 2023. See Watson I, 2023 WL 5276607, at *2.
In 2024, Watson filed this new lawsuit under § 1983 against the task force, the
state police, and nine individual officers (including eight that were mentioned in her
2022 complaint) alleging violations of her due process rights. She included the same
facts about the 2014 incident and further alleged that the defendants have since
convinced the state court to reduce the amount she is owed by $20. She attached to her
complaint a March 2024 order from the state court amending the prior release order to
reflect $1,872 in cash as the accurate amount held in evidence.
The defendants moved to dismiss Watson’s complaint under the doctrine of
claim preclusion, arguing that the claims against the task force were identical to
Watson’s 2022 complaint and that the new defendants (the state police and individual
officers) were in privity with the task force. They argued in the alternative that
1 As we explained in Watson I, this task force of federal, state, and local law
enforcement is organized by the Illinois State Police. 2023 WL 5276607, at *1 n.1. It is still
not clear that the task force is subject to liability under § 1983 or if it is even a suable
entity at all, see id., but we need not decide those non-jurisdictional questions to resolve
this appeal.

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No. 25-1051 Page 3
Watson’s new complaint was also time-barred. The district court agreed that claim
preclusion applied and noted that Watson’s additional allegations about her subsequent
attempts to retrieve her property failed to plausibly state a constitutional claim. The
court dismissed her complaint with prejudice.
On appeal, Watson argues that the district court erred in concluding her claims
were precluded when they rest, in part, on developments that occurred after Watson I.
We review a dismissal based on claim preclusion de novo. Bell v. Taylor, 827 F.3d 699,
706 (7th Cir. 2016). That doctrine bars claims that were already litigated (or could have
been litigated) when there is “(1) an identity of the causes of action; (2) an identity of the
parties or their privies; and (3) a final judgment on the merits.” Id. (quoting Roboserve,
Inc. v. Kato Kagaku Co., Ltd., 121 F.3d 1027, 1034 (7th Cir. 1997)). Watson disputes only
the first element, arguing that this cause of action is distinct because she alleges the
defendants have continued to withhold her property and have failed to follow the state
court’s amended release order that issued after her prior suit.
Watson’s claim that the defendants have continued to withhold her property is
barred. There is an identity of the causes of action when “the claims comprise the same
core of operative facts that give rise to a remedy.” Adams v. City of Indianapolis, 742 F.3d
720, 736 (7th Cir. 2014) (quoting Matrix IV, Inc. v. Am. Nat. Bank & Tr. Co. of Chi.,
649 F.3d 539, 547 (7th Cir. 2011)). And here Watson’s claim concerning the seizure and
withholding of her property is based on the exact same set of facts as Watson I. That
Watson still does not possess her property since the first lawsuit does not create a
distinct cause of action. The defendants seized the property “only one time” and any
refusal to return it is not a new wrong separate from that seizure. Rexing Quality Eggs v.
Rembrandt Enters., Inc., 953 F.3d 998, 1004 (7th Cir. 2020) (applying Indiana law).
Watson appears to argue that she is really trying to enforce the state court’s
March 2024 order directing the clerk to return the money to her. She suggests that by
not giving her these funds, the defendants deprived her of due process. But merely
“intoning ‘due process’” does not state a constitutional claim. Portillo-Rendon v. Holder,
662 F.3d 815, 817 (7th Cir. 2011). Watson received process in state court regarding her
property and ultimately obtained an order releasing the funds to her. She does not
explain how any difficulty collecting her money from the clerk resulted from these
defendants’ actions beyond the original seizure. Indeed, the defendants do not have the
funds anymore. Watson cannot seek to enforce the state court order in this case because
the order merely directs the clerk of that court to release the funds to her; it is not a
money judgment against these defendants, let alone one that may be enforced in federal

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No. 25-1051 Page 4
court. See GE Betz, Inc. v. Zee Co., Inc., 718 F.3d 615, 624–25 (7th Cir. 2013) (recognizing
limited circumstances in which federal courts may enforce a state court’s judgment).
Watson must direct her collection efforts to the state court system. They are not a basis
for further litigation against these defendants.
AFFIRMED

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