A.G.R. v. D.R.H

[2] Before the embryo was implanted, Robinson signed a contract stating she would carry the pregnancy to term and relinquish her parental rights in favor of her brother and Hollingsworth.

However, after the birth, Robinson claimed she was coerced into entering into the agreement and she felt uncomfortable with Robinson-Hollingsworth and Hollingsworth raising the children due to her religious beliefs against homosexuality.

[2] Judge Schultz ruled in favor of Angela Robinson, expanding the Baby M precedent beyond a genetically related surrogate mother and declaring gestational surrogacy contracts to be a violation of public policy.

As noted by legal scholar Jonathan Turley, this ruling creates a split between those states that honor gestational surrogacy and those that do not.

[4] Attorney Harold Cassidy, who had represented both Robinson here and Mary Beth Whitehead in the Baby M case, praised the ruling and described gestational surrogacy contracts as "the exploitation of women.