Mr. McNally initiated and collaborated with the Reporter in drafting a key comment for inclusion in the Uniform Parentage Act, making clear that paternity is established in a civil action and tried by preponderance of the evidence. The new draft of the Uniform Act was the final step aligning the UPA with equal justice for non-marital children. Under common law, children born out of wedlock had no legal father-child relationship whatsoever, and so were denied access to court or to any forum to present their proof of paternity. After this absolute disability was struck down, they were still burdened in many states by legal fatherlessness unless and until their proof of paternity was found to be beyond a reasonable doubt or, in some states, by clear and convincing evidence. With the suit to establish the parent-child relationship firmly established as a civil action and the inclusion of this comment, proof will be by a preponderance in states adopting the UPC and other states independently reaching the conclusion that the preponderance standard was constitutionally required, as was the case in the 1999 Chavana case in Texas. The wide adoption of the Uniform Parentage Act and treatment of the UPA as a civil action under the preponderance standard forfends any later attempts to impose a more burdensome discriminatory standard.