Is there a fairly easy way to select just one color from a lot of clutter like sky through leaves and limbs or skin through fish net? I have been using the magic wand after choosing discontiguous but that is not as accurate as I want. I am using CS5.
Things like skin through fishnet can be tough because you often get a lot of shadows and reflections, depending on the quality of the photo. But try using Select>Color Range. Here's a good tutorial for how to use it.