Today, abandonment of a child is considered to be a serious crime in many jurisdictions because it can be considered malum in se (wrong in itself) due to the direct harm to the child, and because of welfare concerns (in that the child often becomes a ward of the state and in turn, a burden upon the public fisc). For example, in the U.S. state of Georgia, it is a misdemeanor to willfully and voluntarily abandon a child, and a felony to abandon one's child "and" leave the state. In 1981, Georgia's treatment of abandonment as a felony when the defendant leaves the state was upheld as constitutional by the U.S. Supreme Court. 'Rehoming' is still legal in Arkansas where, in 2015, state legislator Justin Harris made national headlines by rehoming two young adopted children.