In City of Los Angeles v. Heller, this Court held that "neither Monell, nor any other of our cases authorizes the award of damages against a municipal corporation based on the actions of one of its officers when in fact the jury has concluded that the officer inflicted no constitutional harm." 475 U.S. 796, 799 (1986). The courts of appeals disagree about how Heller applies when, in a single trial, a jury returns a general defense verdict for an individual officer but is separately instructed to decide whether municipal policy and a final policymaker's decisions themselves deprived the plaintiff of constitutional rights, and the jury returns verdicts imposing municipal and policymaker liability.

The jury was instructed that Petitioners could prevail against the City if they proved "that Keagan Schweikle was deprived of his constitutional rights because of a City custom, policy, ordinance, regulation, or decision," and that they could prevail against former Chief Lane if they proved Schweikle "was deprived of his constitutional rights because of a City of Benton custom, policy, ordinance, regulation or decision that was instituted by Lane." The jury returned verdicts for Petitioners on those municipal and supervisory claims, awarding $30 million against the City and $2 million against Lane, also returning a general verdict for the shooting officer.

Accordingly, the questions presented in this Petition are as follows:

1. Whether a general defense verdict for an individual officer on a Fourth Amendment excessive force claim categorically bars municipal and supervisory liability under 42 U.S.C. § 1983 for a deliberately indifferent failure to train and failure to investigate excessive-force misconduct, where the jury was instructed that such liability required a finding that municipal policy or a policymaker's decisions deprived the decedent of constitutional rights and caused his death, and the jury returned verdicts imposing that liability.

2. Whether, consistent with the Seventh Amendment and Federal Rules of Civil Procedure 49 and 50, a district court may vacate a plaintiff's jury verdict and enter judgment as a matter of law for defendants based on an asserted inconsistency among general verdict forms, where the verdict form directed the jury to answer a special interrogatory that was never submitted, and no party objected before the jury was discharged.

Whether a general defense verdict for an individual officer on a Fourth Amendment excessive force claim categorically bars municipal and supervisory liability under 42 U.S.C. § 1983 for a deliberately indifferent failure to train and failure to investigate excessive-force misconduct, where the jury was instructed that such liability required a finding that municipal policy or a policymaker's decisions deprived the decedent of constitutional rights and caused his death, and the jury returned verdicts imposing that liability; and whether, consistent with the Seventh Amendment and Federal Rules of Civil Procedure 49 and 50, a district court may vacate a plaintiff's jury verdict and enter judgment as a matter of law for defendants based on an asserted inconsistency among general verdict forms, where the verdict form directed the jury to answer a special interrogatory that was never submitted, and no party objected before the jury was discharged