In Re: Jalen O-H., M2016-01484-COA-R3-JV

Child born Sept. 25, 2014 to unmarried parents; father confirmed by DNA on Sept. 26, 2014 and began visiting the child; parents never married or cohabited.
Father obtained emergency placement in May 2015 after mother’s hospitalization and filed to establish parentage; magistrate initially ordered roughly equal parenting time then a later custody order (Oct. 21, 2015) named mother primary residential parent and assigned father 85 visitation days/year.
Juvenile court (Jan. 12, 2016) modified parenting time (mother 224 days, father 141 days) and reserved retroactive support and name-change issues for a later hearing.
Special judge heard retroactive support and name-change on May 12, 2016 and, in a June 27, 2016 order, (1) awarded retroactive child support back to birth, computed over four time periods using income-share worksheets, (2) set current support, and (3) changed the child’s surname to a hyphenation of both parents’ surnames.
Father appealed, challenging (a) retroactive support to date of birth, (b) the calculations/periodization of retroactive support, (c) the current support amount, and (d) the name change to a hyphenated surname.

Issue	Father’s Argument	Mother’s Argument	Held
1. Retroactive support to date of birth	Court should not award retroactive support to birth because father had substantial parenting time after paternity was filed	Guidelines require retroactive award to birth unless rebuttal evidence meets statutory standards	Affirmed: Award to date of birth appropriate; father did not prove statutory rebuttal provisions
2. Calculation/periodization of retroactive support	Court used arbitrary time blocks and incorrect income figures for different periods	Court used tax returns and childcare evidence to compute four distinct income-share worksheets tied to factual custody regimes	Affirmed: Court’s four-period calculations were explained and within discretion
3. Current child support amount	Court’s current support conflicted with an earlier final order and was erroneously modified	Court set current support after considering updated information	Issue waived on appeal for lack of developed argument; no relief granted
4. Child’s surname change	Father wanted child to bear his surname alone; court instead hyphenated surnames (which father now challenges)	Father had sought name change and proposed hyphenation; mother opposed any change	Affirmed: Under Barabas best-interest factors, hyphenated name is in child’s best interests; statutory defaults permit such surnames

Richardson v. Spanos, 189 S.W.3d 720 (Tenn. Ct. App. 2005) (standard of review and abuse-of-discretion framework for child support under the Guidelines)
Barabas v. Rogers, 868 S.W.2d 283 (Tenn. Ct. App. 1993) (best-interest factors for changing a nonmarital child’s surname)
Sneed v. Bd. of Prof’l Responsibility, 301 S.W.3d 603 (Tenn. 2010) (appellate courts will not construct parties’ arguments; undeveloped issues may be waived)
Stein v. Davidson Hotel Co., 945 S.W.2d 714 (Tenn. 1997) (courts cannot rewrite statutes; name-assignment statutory scheme is for the legislature)