In the Matter of Michael, a 1945 U.S. Supreme Court case, dealt with issues surrounding child custody and parental rights. The primary issue was whether or not a biological parent's right to their child could be superseded by the best interests of that child. In this particular case, an unwed mother had given her son up for adoption shortly after his birth due to financial instability. However, once she regained financial stability several years later, she sought to regain custody from the adoptive parents who had been raising him since infancy. The court ruled in favor of the adoptive parents based on two key factors: first being that they were deemed fit and proper custodians for the boy; secondly because it would cause emotional harm to remove him from what he knew as his home and family. This ruling set a precedent emphasizing "the best interest of the child" over biological ties in certain circumstances where removing them may cause significant distress or harm.

The dissenting opinion in the case of "In the Matter of Michael" argued that the court's decision to allow a child custody change based on religious differences between parents was unconstitutional. The justice contended that this ruling violated both freedom of religion and equal protection under law, as it essentially penalized one parent for their religious beliefs. They further asserted that such decisions should be made solely on what is best for the child's welfare, not parental faiths. The justice also expressed concern about potential bias against less popular religions or those misunderstood by courts, which could lead to unfair rulings in future cases involving similar circumstances.