In several cases, the courts have considered the parent's incarceration to be an aspect of abandonment. A second area in which incarceration cases arise is that of parental unfitness which, like abandonment, is often grounds for termination actions. A noticeable aspect of recent abandonment cases is the court's greater emphasis on incarceration versus the underlying criminal act. In several cases, the appellate court did not even mention the nature of the crime which resulted in the parent's incarceration. This focus seems reasonable, in that the usual conception of abandonment concerns the physical absence of the parent rather than the reason for absence. Cases in which incarceration indicates unfitness, however, appear to emphasize the underlying criminal act. This also appears logical, in that being unfit usually reflects an aspect of the parent's character. In general, the courts have shown an undertone of hostility toward incarcerated parents and seem unwilling to allow a parent to use the fact of incarceration as an excuse for failure to provide necessary material and emotional support. 45 footnotes