, only to have the Michigan court of Appeals declare that the court in Michigan was without jurisdiction to act. The publicity abruptly halted when the Michigan Supreme Court entered its order on July 2, 1993, requiring that "Baby Jessica" be returned to her biological parents. (Baron, 72)In the Baby Jessica case, the birthmother intentionally identified the wrong man as the birth father. The adoptive parents took custody believing they had the consent of the birthfather, only to find out later that the real birthfather objected to the adoption. As a result of this case, state courts are recognizing that even when there is consent from a man who pretends to be a child's father, greater efforts must be made to identify others that may claim to be the father and steps must be taken to terminate their rights. (Gray, 18)Baby Richard's Case was riddled with even more deception than Baby Jessica's was. When Daniela Kirchner gave up her newborn son in March of 1991, she was angry that her then boyfriend (and now husband), Otakar, had left her two weeks before the baby was born and returned to Czechoslovakia. She believed rumors that he had run off with an old girlfriend. He believed her story that the baby was dead, even though Oto and Daniela had lived together for the first eight and a half months of her pregnancy. She refused to disclose that he was the father. He failed to search for his son as thoroughly as some thought he should have. Then, in May 1991, the couple reconciled in Chicago. And 80 days after Baby Richard's birth, Oto challenged the adoption. Although Illinois requires a father to demonstrate an "interest" within 30 days of the birth, Oto argued he couldn't stake a claim to a son he didn't know he had. Two lower courts ruled that Oto had abandoned his rights to his son. In the summer of 1994, though, the Illinois Supreme Court not only overturned the adoption but also told the adoptive parents that they didn't look hard enoug...