1. May a state court, or an arbitrator, order a
transfer of child custody in violation of the applicable
legal standards for a modification of custody — simply
by cloaking the attempted transfer in the guise of a
program of "therapy"? (See Moore v. East Cleveland,
431 U.S. 494, 499, 97 S.Ct. 1932, 1936, 52 L.Ed.2d 531
(1977); Lassiter v. Dept. of Social Services, 452 U.S.
18, 27, 101 S.Ct. 2153, 2159-60, 68 L.Ed.2d 640 (1981).

2. Are the constitutional rights of a custodial
parent, and of his children, under the Due Process
clause of the 14th Amendment violated by an order
forcing the children to participate in a coercive
program designed to isolate them from the custodial
parent and to "reunify" them with a non-custodial
parent they fear and do not want to live with? (See
Santosky v. Kramer, 455 U.S. 745, 753, 102 S.Ct. 1388,
1394-95, 71 L.Ed.2d 599 (1982); Troxel v. Granville,
530 U.S. 57, 65-66, 120 S.Ct. 2054, 147 L.Ed.2d 49
(2000). |

3. May children be removed from a parent's
custody and forcibly transferred to the other parent,
when the legal requirements for a modification are
demonstrably not met, simply because a court or
arbitrator describes this transfer as a concomitant of
"therapy"? (See Youngberg v. Romeo, 457 U.S. 307,
815, 102 S.Ct. 2452, 73 L.Ed.2d 28 (1982); Vitek v.
Jones, 445 U.S. 480, 491-494, 100 S.Ct. 1254, 12621264, 63 L.Ed.2d 552 (1980).

May a state court order a transfer of child custody by cloaking it as 'therapy'?