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The New Jersey court's finding that no contract can alter the legal position of a woman who bears a child as that child's mother seemed to settle the question of the status of surrogacy contracts in America, at least until technological advances permitting gestational surrogacy—in which a woman can bear and birth a child to whom she has no genetic relation—reopened the question in many jurisdictions.
At least in New Jersey, however, the Baby M. ruling continues as precedent. In 2009, New Jersey Superior Court ruled that ''In re Baby M'' applies to gestational surrogacy as well as traditional surrogacy cases, in ''[[A.G.R. v. D.R.H & S.H.]]''. The intended parents were a homosexual male couple. They created an [[embryo]] using an anonymous donor ovum and the sperm of one of the husbands. The sister of the other husband carried the embryo to term and originally delivered the child to her brother and his husband, but a year later asserted her own parental rights even though she was not
==Aftermath==
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