184Children born in the U.S. receive birthright citizenship and may apply for a Green Card for their parents when they reach the age of twenty-one.185This is one factor that draws a large amount of international intended parents to the U.S.186Citizenship difficulties may result in a predicament where the child is considered “stateless.”187This issue was popularized by the Indian case Baby Manji Yamada v. Union of India, 180Matter of Paternity and Maternity of Infant R., 922 N.E.2d 59 (Ind. Ct. App. 2010). 181Johnson v. Calvert, 851 P.2d 776 (Cal. Sup. Ct. 1993). 182750III.COMP.STAT.§ 40/16 (2011). 183Mortazavi, supra note 10, at 2285. 184Tamar Lewin, Coming to U.S. for Baby, and Womb to Carry It, New York Times, July 5, 2014, -pregnancies.html. 185Id. 186Id. 187Kari Points, Commercial Surrogacy and Fertility Tourism in India: The Case of Baby Manji, Case Studies in Ethics, .