D.W. v. T.L., 134 Ohio St. 3d 515

Child L.D.W.L., born June 2005 to unmarried parents T.L. and D.W., was initially named with the mother’s surname per agreement and birth certificate.
Parents’ relationship deteriorated; father deployed and later pursued a surname change request in juvenile court.
Magistrate granted the name change to the father’s surname; juvenile court adopted the magistrate’s ruling and amended the birth certificate.
Mother objected, arguing the change would not be in the child’s best interest and that the record lacked sufficient supporting evidence.
Appellate court affirmed, and the mother sought review, challenging discriminatory assumptions and adherence to precedents.
Ohio Supreme Court reversed, holding the record did not establish sufficient evidence that changing the surname was in the child’s best interest and remanded for denial of the change.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the surname change was supported by the child’s best interest.	W.L. argues insufficient evidence; change reflects father's interest, not child’s best interest.	D.W. contends the change serves family interests and child’s welfare.	Change not supported by sufficient evidence; reversed.
Whether the trial court relied on gender-based assumptions.	Mother asserts reliance on gender stereotypes biased against mothers.	Father contends no improper bias was used.	Bias found; improper focus on paternal preference.
Whether Bobo and Willhite standards govern the decision.	Mother argues the decision violated guidelines ensuring best interests are paramount.	Father argues standard requires best-interest proof.	Standards require best-interest proof; error to prioritize paternal surname.

Bobo v. Jewell, 38 Ohio St.3d 330 (1988) (burden to show best interest; avoid discriminatory emphasis on paternal surname)
In re Willhite, 85 Ohio St.3d 28 (1999) (expands Bobo factors; cautions against gender-based assumptions; notes residential-parent surname considerations)