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

QUESTIONS PRESENTED 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).