Modern biotechnology now makes possible issues that were not contemplated by Congress in the adoption of the Social Security Act. One of those issues is whether a child conceived by artificial insemination a year after her father’s death is a “child” of her father entitled to survivor benefits under the Social Security Act. The 9th U.S. Circuit Court of appeals earlier ruled “yes.” In the recent ruling in Beeler v. Astrue, the 8th U.S. Circuit Court of Appeals ruled “no”, overturning a lower, trial court decisions and affirming the final decision of the Commissioner of Social Security.