Baby M can be seen as the recurrence of the Parrish case. The reason why Baby M is so controversial is that surrogacy was a startling novelty then. But it become simpler by making an analogy: the children that are paid to work. Let's assume that a contract had been made before the employment relationship went into effect, but the compact cannot justify the existence of child labor: one cannot purchase the agreement of children to perform oppressive labor, as stated in 29 U.S.C. 212.
Third, surrogacy might infringe the right of surrogate mothers and their children. When children grow up and are informed that they are not raised by their birth mothers, children will not likely to accept the fact that they were somehow abandoned by their birth
