In Adoption of O.M. (2008) 169 Cal.App.4th 672, the father failed to provide the mother with material support during the pregnancy while he was incarcerated and, when he was released, the mother avoided contact with him. The court held that these impediments were either of the father's own making, or played a small role in the father's actions. The court emphasized that the father was responsible for demonstrating his commitment to fatherhood in these circumstances and had failed to do so. The court recognized the possibility that the principles of Adoption of Kelsey S. (1992) might entitle a father to presumed-father status despite his inability to meet its requirements, if his efforts to demonstrate his commitment to his parental responsibilities were thwarted by the mother's unilateral efforts to deny him that status. (Adoption of O.M., supra, 169 Cal.App.4th at p. 680.) There, although some evidence indicated that the mother had acted to preclude the father from asserting his parental rights, it was the father's incarceration, not the mother's unilateral conduct, that was primarily responsible for frustrating the father's attempts to fulfill his parental responsibilities. The court found that no constitutional principle prevented it from "holding an unwed father's own criminal activity against him when assessing whether he has met the criteria for Kelsey S. rights," and affirmed the trial court's denial of presumed-father status. (Ibid.)In Adoption of O.M., supra, 169 Cal.App.4th 672, the court noted that some cases have upheld the right of an incarcerated Father to retain legal custody of a child after he had successfully arranged for the child's physical custody and care during the incarceration. (Id. at pp. 681-682.) It also noted, however, that none of those cases involved the circumstance here, where the incarcerated Father had neither cared for nor bonded with the child before the incarceration commenced. (Ibid.)