Note, Michael H. v. Gerald D.: The Constitutional Rights of Putative Fathers and a Proposal for Reform, 31 B.C. L.Rev. 1173 (1990). Some jurisdictions follow the line of reasoning established in Michael H. and hold statutes which deny a putative father standing constitutional under the state or federal constitutions. See, e.g., Dawn D. v. Superior Ct., 17 Cal.4th 932, 72 Cal.Rptr.2d 871, 952 P.2d 1139, 1146 (1998) (finding alleged biological father seeking to establish relationship with child born to married mother did not have constitutionally protected liberty interest in forming relationship with child under California Constitution); Hauser v. Reilly, 212 Mich.App. 184, 536 N.W.2d 865, 868 (1995) (agreeing with Justice Brennan’s dissent in Michael H.; in the absence of a pa .1998) (<HOLDING>); A v. X,Y, & Z, 641 P.2d 1222, 1224-27 (Wyo.
holding statute denying putative father standing to bring legitimation action under statute in effect at the time did not violate due process or equal protection of state or federal constitutions holding statute that conferred putative father no standing to challenge paternity of a child born in wedlock did not deny due process or equal protection holding that statute that imposed different requirements to establish parental rights on father than on mother did not violate fathers right to equal protection under the law holding that doctrine does not violate equal protection holding transfer rule did not violate federal equal protection