1. Implied Consent Under Rule 15(b). Whether the lower courts ' refusal to
recognize implied consent for a fully litigated excessive force claim —
despite Defendants ' extensive discovery, deposition questioning, and
summary judgment arguments —conflicts with controlling precedents of
this Court and Rule 15(b) of the Federal Rules of Civil Procedure which
hold that issues actually tried by consent are treated as if pleaded.

2. Summary Judgment and Video Evidence Contradictions. Whether the
district court 's grant of summary judgment in the face of video evidence
"blatantly contradicting " Defendants ' sworn accounts conflicts with Scott
v. Harris, 550 U.S. 372 (2007), and the Eighth Circuit 's requirement that
courts adopt the non-moving party 's version of events when video evidence
creates a genuine dispute of fact.

3. Excessive Force Against a Restrained Individual (Objective
Reasonableness). Whether classifying the continued use of force on a
compliant, handcuffed detainee as "objectively reasonable " contravenes
Graham v. Connor, 490 U.S. 386 (1989), Hudson v. McMillian, 503 U.S. 1
(1992), and Eighth Circuit authority (Chambers v. Pennycook, 641 F.3d
898 (8th Cir. 2011)), thereby requiring uniform guidance from this Court
to uphold the Fourth Amendment 's prohibition against excessive force.

4. District Court 's Selective Adoption of Magistrate 's Findings. Whether
the district court 's selective acceptance of only those portions of the
magistrate judge 's report favoring Defendants —while rejecting the
magistrate 's implied-consent finding without explanation —departs from
Eighth Circuit standards (Anderson v. City of Bessemer City, 470 U.S. 564
(1985)) that holds " Where there are two permissible views of the evidence, the factfinder's
choice between them cannot be clearly erroneous', and implicates due process by
undermining reasoned judicial review.

5. Failure to Disclose Judicial Conflict of Interest. Whether a judge 's
undisclosed prior attorney-client relationship with the defense 's counsel,
followed by rulings favoring that counsel 's clients, transgresses this
Court 's directives in Caperton v. A.T. Massey Coal Co., 556 U.S. 868
(2009), as well as the Eighth Circuit 's standards for recusal when
impartiality might reasonably be questioned.

6. Impact on Due Process and the Integrity of the Judiciary. Whether
these combined departures from binding Supreme Court and Eighth
Circuit precedent —refusal to acknowledge implied consent, ignoring
contradictory video evidence at summary judgment, and failure to disclose
a clear conflict of interest —raise an important federal question warranting
certiorari to safeguard the due process rights of litigants and preserve
public confidence in the judicial process.

Whether the lower courts' refusal to recognize implied consent for a fully litigated excessive force claim conflicts with controlling precedents of this Court and Rule 15(b) of the Federal Rules of Civil Procedure