The case below conflicts with the precedents of the Sixth Circuit, other circuits, fellow state supreme courts as well as is violative of constitutional rights and the precedents of this Honorable Court on matters of pure federal law resulting in splits between both state and federal courts.

Whether §1983 provides for $50 million in exemplary damages to be vicariously awarded against a city and its supervisor police chief without a showing of deliberative indifference when the officer assailant was inebriated, off duty and tasked to an outside law enforcement agency.

Whether the trial court's denial of judicial notice, rebuttable evidence (from a corollary criminal case, State v. Black, CR 12-562242) and a contradictory Admissions statement (approved inapposite of an appellate order, Ohio Appellate Eighth District Case No. 16-105248) was an abuse of discretion violative of City Petitioners' Due Process rights.

Whether the Ohio Eighth District Court of Appeals committed plain error and the Ohio Supreme Court abused its discretion in denying review of this case