Michael H. v. Gerald D.

In Michael H. v. Gerald D., 491 U.S. 110, 122-127 (1989), the U.S. Supreme Court held that a father of a child born out of wedlock has no common-law right, beyond the rights afforded him under state law, to direct his child's upbringing. The common law vested no specific rights in the father of a non-marital child. See M. Grossberg, Governing the Hearth 197, 207 (1985) (English law recognized "mothers' custodial rights over their illegitimate children"); J. Hamawi, Family Law 288-289 (1953) (at common law, parental rights over a non-marital child were "concentrated in its mother").