In 2015, over 200,000 in vitro fertilization (“IVF”) cycles treatment were recorded in the United States, resulting in approximately 75,000 pregnancies. In just under four decades since the first successful transfer in 1981, “test tube babies” went from rarefied headline fodder to a viable and plentiful option for many people living with infertility. Despite this growth, the legal landscape remains a jurisprudential frontier. With the opening of reproduction to scientific intervention, precedents of domestic relations fail to encompass the myriad outcomes of having children apart from sex. Couples experiencing infertility may endure extreme emotional stress in the struggle to have children, and the pursuit of this end goal oftentimes obscures contingencies for future conflicts. In the haze of the elusiveness of infertility and the satisfaction of pregnancy, couples may not foresee complicated breakups, divorce, and disagreement, resulting in many difficult cases for state courts in the last decades. Assisted reproduction is a largely unregulated field of legal inquiry, and many of these cases are of first impression in the individual states in which they take place.