1. WHETHER THE DISTRICT COURT IN GRANTING SUMMARY JUDGMENT IMPROPERLY
DECIDED FACTUAL ISSIES
WHETHER THE PLAINTIFF FACTUAL ALLATIONS ON AN UNPROVOKED BEATING BY
OFFENDER AT CORRROADS CORRECTION CENTER THAT SEVERLY ASSAULT ON MR.
WASHINGTON THAT PRISON OFFICIAL EXHIBITED DELIBERATE INDIFFERENCE TO
MR.WASHINGTON HEALTH AND SAFTY FAILURE TO PROTECT AND DIDNOT FOUNDING
THE JUDGE COURT ORDERED EIGHT CIRCUIT FINDS VERIFIED COMPLAINT DEFEATES
SUMMARY JUDGMENT MOTION IN FAILURE TO PROTECT CASE THE CONSTITUTIONALL
IS VIOLATED WHERE DEFENDANTS KNOW OF THE DAMGER OR WHERE THE THREAT OF
VIOLANCE IS SO SUBSTANTIAL OR PREVASIVE FAIL TO EMBRACE A POLICY OR TAKE
OTHER REASONABLE STEP WHICH MAY HAVE PREVENTED THE HARM.
THE DUTY TO PROTECT STANDARD REQUIRES PRISON OFFICEIAL TO SEEK OUT HARM
TO INMATE RATHER THAN ALLOWING THEM TO WAIT UNTIL A SUBSTANTIAL RISK OF
SERIOUS HARM DEVELOS . THE STANDARD RECOQNIZES THAT INMATE WILL ONLY BE
REASONABLY SAFE IF PRISON OFFICEIAL TAKE PREVENTIVE STEPS BEFORE RISK
BECOME SUBSTANTIAL. EVEN IF PRISON OFFICEIAL ARE NOT AWARE OF A SPECIFIC
DANGER OTHER THAN THE GENERAL RISK INHERENT IN ALL PRISON THE EIGHT AMENT-
MENDT DUTY TO PROTECT SHOULD REQUIRE BASIC MEASURE TO PREVENT (ASSAULT)
AND OTHER FORMS OF HARM TO OVER INMATE OR STAFF.
A DUTY TO PROTECT STANDARD WOULD ALSO ADDRESS THE PROBLEM OF ESTABLISHING
THE KNOWLEDGE OF THE PRISON OFFICIAL IS NOT EXCUSED FROM LIABILITY SIMPLY
BECAUSE HE DIDNOT KNOW OF THE RISK TO THE DEFENDANTS MR. WASHINGTON THE
DUTY TO PROTECT STANDARD WOULD CONTINUE BY ASKING WHETHER THE OFFFICIAL
COULD HAVE DISCOVERED AND PREVENTED THE RISK TO MR. WASHINGTON THROUGH
REASONABLE INSPECTION. RATHER THAN SENDING THE SIGNAL THAT IT IS POSSIBILITY
TO AVOID LIABILITY BY DENYING KNOWLEGE OR AVOLDING IT A STANDARD THAT.
REQUIRES OFFICIAL TO SEEK OUT KNOWLEDGE WOULD DEMONSTRATE A COMMITMENT
TOWARDS GREATER SCRUTINY OF THE INFLICTORS OF PUNISHMENT. IT WOULD ALSO
BROADEN THE SCOPE AND POTENCY OF THE EIGHT AMENDMENT DUTY TO PROTECT INTENT
OF PRISON OFFICIALS IMPLEMETING A LIABILITY STANDARD BASED ON NOT REASONABLY
PROTECTED BY DEFENDANTS.

2. ISSUES PRESENTED FOR REVIEW
WHETHER THE EIGHTH CIRCUIT OF APPEAL IMPROPERTLY DECIDED FACTUAL ISSIES
IN VIOLATION OF THE JUDGE COURT ORDERED ON POST JUDGMENT INJUCTIVE RELIEF
WHEN THE STATE OF MISSOURI CROSSROADS CORRECTION CENTER FAILURE TO ABIDE
BY THE TERMS OF THAT COURT ODERED WHICH THE DEFENDANTS FAILURE TO COMPLY.
THE DISTRICT COURT ABUSED ITS DISCRETION AND VIOLATION MR.

Whether the district court improperly decided factual issues in granting summary judgment