I.
Whether the Fourteenth Amendment's Due Process Clause is satisfied when state courts at three
successive levels either ignore or refuse to rule on whether a trust can be adjudicated without the
complete trust instrument in the record —the district court and Court of Appeals remaining silent
on the issue, and the Kansas Supreme Court acknowledging but declining to address it—despite
the universal rule of trust law recognized by every American jurisdiction including Kansas that
courts must read trust instruments "in their entirety" to ascertain the settlor's intent, thereby
rendering any "opportunity to be heard" inherently meaningless under Armstrong v. Manzo, 380
U.S. 545, 552 (1965), which requires that due process be "meaningful. "

II.
Whether the Kansas Supreme Court violated the Supremacy Clause by misinterpreting United
Student Aid Funds, Inc. v. Espinosa, 559 U.S. 260, 271 (2010), to require that due process
violations must "effectively eliminate personal jurisdiction" before voiding a judgment, when
Espinosa established that judgments are void based on "either" jurisdictional error "or" due
process violations —two independent pathways, not a single merged requirement —and the
Kansas Supreme Court cited no authority or reasoning for collapsing Espinosa's two pathways
into one.

III.
Whether the Fourteenth Amendment is violated when a state applies its acquiescence doctrine to
bar appellate review of a judgment rendered without meaningful due process, by forcing a party
to choose between (a) leaving his pre-existing property interest as a trust beneficiary in the hands
of opposing counsel taking unauthorized attorney fees in violation of state law, or (b) accepting
distribution of that property and forfeiting appellate review of a judgment entered without any
evidentiary hearing, without the complete trust instrument in the record, without any factual
evidence, and at a hearing noticed as a status conference rather than a final adjudication.

Whether the Fourteenth Amendment's Due Process Clause is satisfied when state courts at three successive levels either ignore or refuse to rule on whether a trust can be adjudicated without the complete trust instrument in the record