1. Does Maryland's adoption of "the best interest of the child" standard
when adjudicating termination of parental rights cases conflict with the firmly
established "clear and convincing evidence" standard that protects liberty interests
through the Due Process Clause of the Fourteenth Amendment of the United
States Constitution where an incarcerated parent serving a long-term sentence has
not been found to have committed abandonment, neglect or abuse that directly
harmed his or her child?

2. Does Maryland Code Annotated, Family Law §5-323 's inclusion of
undefined "exceptional circumstances" give carte blanche deference to the Court
to establish any circumstance it so desires to remove an individual's parental rights
in violation of the Due Process Clause's mandate against vagueness, thereby
declaring said statute void?

3. Has the arbitrary and capricious nature of Maryland Code Annotated.
Family Law §5-323 's "exceptional circumstances" clause allowed the judiciary,
through stare decisis, to create an irrebuttable presumption as well as a
classification that burdens the fundamental right of a parent to raise his or her
child and targets incarcerated individuals, a suspect class, in flagrant violation of
the Due Process and Equal Protection Clauses of the Fourteenth Amendment of
the United States Constitution?

Does Maryland's 'best interest of the child' standard conflict with the 'clear and convincing evidence' standard that protects liberty interests through the Due Process Clause?