1. Whether persons who are not government officials and not performing
governmental duties can claim qualified immunity from suit in a civil rights
action pursuant to 42 U.S.C. § 1983.

2. Whether it is harmless error to submit to the jury the purely legal issue
whether a defendant is entitled to qualified immunity.

3. Whether it is harmless error to submit to the jury for determination the legal
standard whether the defendants' conduct, in light of U.S. Supreme Court
precedent and historical understanding of the Constitution, meets the
"shocks the conscience" standard for constitutional violations.

4. Whether, if the defendants' conduct did violate the Constitution, a
governmental official in defendants' position could nevertheless reasonably
believed their conduct was lawful.

5. Whether Petitioner, a 31-year old autistic, mentally retarded woman living
with her parents, was entitled to a directed verdict when the evidence showed
that respondents acted jointly to involuntarily confine her at a residential care
facility for 11 months, her whereabouts kept secret from all but those working
with respondents, without due process, or indeed, any process of law at all,
or does the defendantsU professed desire to keep Petitioner UsafeU absolve
them from liability?

Whether persons who are not government officials and not performing governmental duties can claim qualified immunity