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During the late 1920's, infant adoption became more popular as the availability of infant formula increased. Adoption up to that point had been primarily seen with children ages two and up because the care of an infant could not be carried out by anyone but the babies biological mother. Ironically, nowadays, it is easier to adopt an infant because it is most often the birthmother that is making the decision to place her baby up for adoption and that decision is often made while she is still pregnant. It can be argued, however, that because of the popularity of birth control and abortion over the last 30 years, there are not as many infants available for adoption. It has been hypothesized that if the Supreme Court case Roe v. Wade were overturned, the number of infant adoptions in the United States would return to the same level as before the ruling.