In practice, it seems, KH is not widely understood. Child protection petitions for temporary custody continue to name multiple men as the "father" of a child when there is a legal father. Some courts insist on terminating the parental rights of "John Doe" when no man has established paternity. After KH, are such actions necessary? Are they permissible?
Vandervort, Frank E. "Addressing Putative Fathers in Child Protection Proceedings: Is 'John Doe' Still Alive?" W. Lansat, co-author. Mich. B. J. 85, no. 9 (2006): 39-42.