In re Name Change of J.P.H.
Annotate this CaseWhen Son was born to Mother and Father, Son received the surname of Father. Mother and Father subsequently divorced, and Mother was granted primary physical custody of Son. Mother later married Stepfather. Mother petitioned to change Son’s surname to a hyphenated surname combining Mother’s new last name and Father’s last name. The circuit court found that Son’s name change was in his best interests and granted Mother’s request to change Son’s surname. The Supreme Court affirmed, holding (1) the circuit court did not err in granting Mother’s request to change Son’s surname; and (2) there is no need to modify the best interests of the child standard to include a finding of clear and compelling evidence by the circuit court.
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