1)
Does a trial court violate the requirements of the
Equal Protection clause of the Fourteenth Amendment when it bases a permanent child custody order on a racially discriminatory theory, holding
that treatment that would be abusive if perpetrated against white children is not abusive, and
even beneficial, when applied to black children?
(See M.L.B. v. S.L.J., 519 U.S. 102, 117 S. Ct. 555,
136 L. Ed. 2d 473 (1996); Santosky v. Kramer, 455
U.S. 745, 753, 102 S.Ct. 1388, 1394-95, 71
L. Ed. 2d 599 (1982); Nordlinger v. Hahn, 505 U.S.
:
1, 112, S. Ct. 2326, 120 L. Ed. 2d 1 (1992).)

2)
Does a state appellate court violate the requirements of the Due Process clause of the Fourteenth
Amendment by wrongly denying a petition for a
writ of error coram vobis, where newly available
evidence demonstrates that a custody ruling was
based on a racially discriminatory theory and was,
in addition, procured through fraud and/or mistake? (See Meyer U. Nebraska, 262 U.S. 390, 43
S. Ct. 625, 67 L. Ed. 1042 (1923).)

Does a trial court violate the Equal Protection clause when it bases a child custody order on a racially discriminatory theory?