In re Name Change of M.J., 2019 Ohio 2065

Mother (L.L.) petitioned to change her minor daughter M.J.’s surname from Father’s (B.J.) to Mother’s maiden name; Father opposed.
Mother filed initially in 2015 but withdrew; she filed again in 2018. Hearing held September 25, 2018; petition denied October 1, 2018.
Mother testified M.J. is primarily raised by maternal family, enrolled at school under Mother’s surname, and is confused by use of Father’s surname.
Mother asserted the surname should match the family with whom M.J. lives and spends most time. School principal and maternal aunt supported that M.J. is known locally by Mother’s surname.
Father testified he pays child support, provides health insurance, claims Mother obstructed his parenting time, and that the legal surname is his sole remaining connection to the child.
Trial court found both parents at fault for the lack of relationship, concluded changing the name would likely completely alienate Father, and denied the petition as not in the child’s best interest. Appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the probate court abused its discretion in denying a minor’s surname change	Mother: trial court misapplied Willhite factors and erred by denying name change requested to reflect child’s lived identity	Father: opposes; name is his remaining legal tie; change would further alienate child from father	Court: No abuse of discretion; trial court applied Willhite, weighed best‑interest factors and permissibly denied petition

In re Willhite, 85 Ohio St.3d 28 (1999) (sets best‑interest factors for minor surname changes)
In re Crisafi, 104 Ohio App.3d 577 (1995) (appellate standard: review for abuse of discretion)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (defines abuse of discretion standard)
D.W. v. T.L., 134 Ohio St.3d 515 (2012) (burden on party seeking name change to show best interest)
In re Zachary Dayton, 155 Ohio App.3d 407 (2003) (Willhite factors do not automatically require name change)