1. Did the state court err and violate the Supremacy
Clause and Petitioner's Fourteenth Amendment
rights in reclassifying a federal civil rights verdict as
divisible under state law when it engaged in extra
record fact-finding and judicial notice of disputed facts
to deprive Petitioner of a vested property interest?

2. Whether Ohio 's "best interest of the child "
standard, Ohio Revised Code §3109. 04(F)(1), as
applied to deprive a parent of custody or meaningful
parent-child contact, is vague, overly broad, and
delegates discretion without standards in violation of
the Fourteenth Amendment by permitting
infringement of a parent's fundamental liberty
interest without a clear and convincing evidentiary
burden or strict scrutiny judicial review, in conflict
with Troxel v. Granville, 530 U.S. 57 (2000).

3. Whether Fourteenth Amendment due process and
equal protection are violated when state courts
deprive a parent of custody or meaningful parent
child contact without any finding of parental
unfitness, based on discretionary reports or
recommendations of non-expert, quasi-judicial actors
who apply no evidentiary standards and operate
without constitutionally required safeguards.

4. Did the state court err in setting a visitation order
that burdens protected religious exercise, fails to
provide reasonable accommodation for disability, and
then imposes coercive sanctions, including severing
the parent-child bond and incarceration?

Did the state court err and violate the Supremacy Clause and Petitioner's Fourteenth Amendment rights in reclassifying a federal civil rights verdict as divisible under state law when it engaged in extra record fact-finding and judicial notice of disputed facts to deprive Petitioner of a vested property interest?