Whether a natural parent has a fundamental liberty interest, guaranteed by the Fourteenth Amendment, in the care, custody, and management of her child, precluding the grant of custody to an individual who is not a parent of the child and has not adopted the child simply because the individual was "there when she was born " and thus "feels " that the child is his daughter.

Whether constitutional rights of a parent to make decisions for the child preclude a court from granting custody to a non-parent over the objection of the natural parent.

Whether, if the concept of de facto parenthood exists — a claim never raised by the Respondent-, the constitutional protections afforded to a biological parent would remain intact, and would require a finding of, among other things, consent to such a relationship by clear and convincing evidence and should result only in visitation and not transfer of custody.

Whether a natural parent has a fundamental liberty interest in the care, custody, and management of her child