The first question involves the Florida Practice and Rule which do not permit litigants to seek review in the Florida Supreme Court when the District Court of Appeal issue unelaborated affirmances (PCA's) of trial court decisions. The issue is whether this practice unconstitutionally deprives Florida resident's full and complete access to their courts in violation of their 5th and 14th Amendments due process rights. As well as being violative of their 14th Amendment equal protection rights, in that it invidiously discriminates against Florida residents. Wherefore, residents of other states who enjoy full and meaningful review of their cases on appeal. Most egregious, however, is the fact that the great majority of PCA's are rendered in criminal and dependency cases, which mainly involve the indigent population of Florida.

The second question presented is whether Florida Statute 39.806(1)(d)1 and 39.806(1)(d)3. Which denies the parent the possibility of defending against charges which have already been decided in a prior, non-trial surrender of parental rights, violated the fathers fundamental liberty interest in parenting; (Troxel v. Granville, 530 U.S. 57, 65 (2000); Lassiter v. Dept. of Social Services, 452 U.S. 18,27(1981); Stanley v. Illinois, 405 U.S. 645, 651; et.al . which interest is also protected by Florida's Privacy Act, Art. Sec. 23 Fla. Const.) Due process, equal protection, and his right against punishment by ex post facto ma/urn per se laws.

Whether the Florida practice and rule that do not permit litigants to seek review in the Florida Supreme Court when the District Court of Appeal issues unelaborated affirmances (PCA's) of trial court decisions unconstitutionally deprives Florida residents of full and complete access to their courts in violation of their 5th and 14th Amendment due process rights and 14th Amendment equal protection rights