Whether the State violates the Due Process Clause when it assumes initial custody of a child from an involved biological parent utilizing dependency proceedings that exclude parental fitness as a factor in the decision.

Whether the application of the ore tenus rule in appellate review of judgments depriving a parent of the custody, control and care of a child in favor of a non-parent adequately and fairly protects the rights of parents to control the upbringing of their children from erroneous deprivation under the Due Process Clause.

Whether the State violates the Due Process Clause when it assumes initial custody of a child from an involved biological parent utilizing dependency proceedings that exclude parental fitness as a factor in the decision