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In Rainey v. Chever, the Georgia Supreme Court held unconstitutional section 53-2-4(b)(2) of the Official Code of Georgia Annotated ("O.C.G.A."), which required that before a natural father could inherit through his illegitimate child, the natural father had to either openly treat the child as his own or provide support for the child. Coming up only one vote short, the United States Supreme Court denied plaintiff's petition for writ of certiorari. The three dissenting Justices declared their belief that Georgia's statute addressed the "alarming trend" of outof- wedlock births.5 Furthermore, the dissenting Justices asserted that because of the "substantial tension" between Georgia's decision and the United States Supreme Court's decisions, certiorari should have been granted.