In Stewardson v. Biggs, the court (Ripple/Rovner/Jacson-Akiwumi, with Jackson-Akiwumi writing) dismissed a qualified immunity appeal for lack of jurisdiction. The facts of the case involve an excessive use of force in an Indiana jail, and the appeal arose from the district court’s denial of qualified immunity for one of the jail guards who failed to intervene to prevent the use of excessive force by another guard. As most readers familiar with section 1983 know, the ability to pursue an interlocutory appeal of a denial of qualified immunity is an exception to the normal rule that only final orders are appealable—an exception created by common law. But as the Seventh Circuit in Stewardson recognizes, there is an exception to the exception: where the district court’s denial of qualified immunity turns on disputed questions of fact (an issue not subject to interlocutory appeal) and the appellant’s arguments are inseparable from an argument about the disputed facts, rendering the appeal “a back-door effort to use disputed facts to support his arguments.” Slip Op. at 5 (cleaned up). The court finds that both conditions were satisfied as part of this appeal and so did not have jurisdiction to decide it.