While Patrick certainly hasn't pled that, both sides admit that swatting is generally dangerous. I think it's reasonable for the court to, if it's deciding the issue generally, consider how its test would apply in a situation where the victim isn't as lucky. Particularly so where both parties already spent significant time arguing (if memory serves) whether MPD's actions were "objectively reasonable", which is one of the factors that disqualify (or qualify) excessive force.
It does, though, as "totality of the circumstances" now has no time limit, and every "circumstance" known to the police is to be considered. That is relevant particularly because MPD has spent all of its time arguing that the police didn't know shit, implying that were it otherwise they'd be fucked.
Granted, this is like two or three steps removed in applicability, but I found it still interesting