Recent Development: Sieglein v. Schmidt: Pursuant to § 1-206(B) of the Estates and Trusts Article, Artificial Insemination Encompasses In Vitro Fertilization Using Donated Sperm; A Court May Use the Goldberger Factors to Determine Voluntary Impoverishment; A Trial Court Can Issue a Permanent Injunction for Harassment Based on § 1-203(A) of the Family Law Article.

The Court of Appeals of Maryland held that the term “artificial insemination” includes in vitro fertilization using donated sperm, and that a consenting husband is presumed to be the father of the child born as a result of the procedure. Sieglein v. Schmidt, 447 Md. 647, 652, 136 A.3d 751, 754 (2016). The court also held that the circuit court did not abuse its discretion in finding the husband to be voluntarily impoverished or in issuing a permanent injunction based on harassment.

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