Is the phrase “borne out of necessity” — as the writer for Yahoo! Style alleges — or “born out of necessity”?
It’s the latter. Both born and borne are the past tense and past participle of the verb bear.
Use born when you mean to bring forth by actual or figurative birth or being natural or innate: born free, born to be wild, American-born, born leader, and born of necessity.
For all other meanings of bear, borne is the correct word. It’s used when bear means to support, carry, hold in mind, or suffer: borne in mind, food-borne, and borne out by the facts.