No, American courts favor joint custody. However, the American court in this case was not ruling on a divorce case, but a termination of parental rights/adoption case, some of th elements of which are 1) the bio-dad has notice and 2) the abandonment of the child in the absence of his consent to the adoption.
You wouldn’t believe the calls we field with loving fathers -sarc- wanting to voluntarily terminate their rights so they don’t have to pay child support.
You wouldn’t believe how many men I know who paid their child support and the courts failed to protect their visitation rights. You wouldn’t believe how many men get badgered by allegations by their Childs mother to give up their parental rights.