That this almost never happens is due largely to the fact that, as a rule, no one except the mother of a child is especially keen to possess it.
It is due also in large measure to the fact that courts of justice are growing reluctant to administer such archaic laws.
The famous Tillman case is an example.

Senator Ben Tillman of South Carolina has one son,--a dissipated, ill-tempered, and altogether disreputable man, whose wife, after several miserable years of married life, left him, taking with her their two little girls.

South Carolina allows no divorce for any cause.

The sanctity of the marriage tie is held so lightly in South Carolina that the law permits it to be abused at will by the veriest brute or libertine.

Mrs.Tillman could not divorce her husband, so she took her children and went to live quietly at her parent's home in the city of Washington.
One day the father of the children, young Tillman, appeared at that home, and in a fit of drunken resentment against his wife, kidnapped the children.