In Barry E. v. Hollis Ingraham (43 NY2d 87 [1977]) the Court of Appeals rejected the Mexican adoption of a New York child by New York residents, because the transcript of the foreign judgment was not clear that the adoptive parents appeared physically before the Mexican court, and the Mexican court performed only a cursory investigation into the advisability of the adoption (Id. at 97). The Court of Appeals decried the Mexican court's attempted arrogation of jurisdiction over the adoption of a child who was a resident of New York and who was brought to Mexico only for the purpose of adoption (Id.). In addition, the Court of Appeals admonished the lower courts to carefully review the background of the adopted child and the circumstances surrounding the foreign adoption (Id. at 95).