In the cases where there was no marriage nor relationship nor live-in, more courts seems to be asking if the woman did not actually WANT, even DESIGN to have the child...and victimize some man as a mere sperm donor...
More women are deciding they don't WANT the kids, just dump them on Daddy. [0ver 20 yrs ago, an aquaintance of mine with seven children including a baby girl, suddenly had his wife run away with a man nearing 70 who had money, and she wouldn't have anything to do with her own children.]
More women today are so obviously unfit to love and care for ANYTHING, plus with increasing awareness of successful parenting by fathers alone (lower crime rates, more successful children and not just boys, either)...causes that to be looked at at least casually by some judges, as a possible option, whereas 20 yrs ago the mother would just automatically get them regardless of her low morals and lack of decency or character...