ABSTRACT
United Nations data show that at the beginning of this century the rate of domestic adoptions (the irrevocable transfer of parental status between individuals) in the United States was one of the highest in the world, three times that in UK, whose rate itself was about twice that of Germany and four times that of Italy. 1 In many European countries almost all adoptions are intercountry adoptions 2 (on which, see Chapter 7.1 of this book). Excluding intercountry adoption, adoption is relatively unusual in most countries compared to the United States and the UK, although it is growing in some. 3
In both countries, adoption has responded to different pressures on families. The earliest US adoption laws provided additional placement options alongside indentured apprenticeships for poor, urban, children placed by their parents in ‘orphanages’. 4 Massachusetts enacted the fi rst US law regulating adoption in the United States. 5 The law was unique because it was the fi rst effort to establish judicial supervision over the irrevocable transfer of custody of a child from one adult to another, and because it shifted the focus of adoption policy from the parents to the child. To this end, the law provided for the investigation of prospective
1 UN Department of Economic and Social Affairs, Population Division, Adoption: Trends and Policies , New York, NY: United Nations, 2009, p. 69.
