No court that has addressed the question of recognizing fraud in the context of an adoption has refused to do so where there was some kind of evidence of active concealment. In re Baby J., the court found fraudulent concealment of the truth where the adoption agency told the parents that the birth mother was an 18-year-old unwed mother who could not care for the baby. The birth mother was actually a 35-year-old patient in a mental institution and the father was presumed to be another patient which the agency knew. The truth was discovered by the adoptive parents after their 13-year-old adopted son was diagnosed with an inherited mental disorder. Roe v. Jones, the court awarded damages because the adoption agency placed three-school aged children