in the Interest of S.M.-R., a Child, 02-15-00287-CV

In May 2014 the State (Attorney General) filed a parentage action for Stacy (born May 2011); Mother (D.M.) had custody since birth; Father (J.R.) initially denied, then conceded paternity and sought managing-conservator status.
Temporary order (Oct 2014) found Father was Stacy’s father, named both parents joint managing conservators, gave Mother right to designate primary residence, and ordered Father to pay $202/month child support starting Nov 1, 2014.
Mother (pro se) moved to modify the temporary order; no ruling in the record on that motion.
Final hearing (Aug 2015) produced a final order: hyphenated Stacy’s surname to include both parents, confirmed joint managing conservatorship with Mother having primary-residence right, awarded current support of $351/month, and ordered $4,570 in retroactive support beginning Jan 1, 2013.
The final order split court costs equally and did not award or require payment of attorney’s fees; Mother appealed three points (name change, retroactive support period/amount, and attorney’s fees).

Issue	Plaintiff's Argument (Mother)	Defendant's Argument (Father/State)	Held
Name change to hyphenated surname	Trial court erred; child should retain Mother’s surname only to avoid confusion	Father argued hyphenation fosters bond, eases insurance/administrative issues, and is in child’s best interest	Affirmed — no abuse of discretion; some probative evidence supported best-interest finding
Retroactive child support start/date	Court should have set retroactive support earlier; Mother contends no discretion (should be mechanical)	Court has discretion under Fam. Code and guidelines; factors include obligor’s knowledge, mother’s notice efforts, obligor’s resources, and prior support	Affirmed — trial court has broad discretion; evidence supported limiting retroactivity to Jan 1, 2013
Amount/calculation of retroactive support	(Implied) challenge to trial court’s calculation and any unstated factual findings	Father and State pointed to factors like Father’s prior unemployment and Mother’s delay in proving paternity	Affirmed — court’s factual findings (e.g., periods of unemployment) had evidentiary support and justified the calculation
Attorney’s fees	Mother contends fees should be paid by opposing party (apparently Father) because AG initiated action	No clear request for fees in trial pleadings; defendant/State argued no basis to award fees against them	Affirmed — no error: Mother did not request attorney’s fees below, so trial court’s omission was not reversible error

Anderson v. Dainard, 478 S.W.3d 147 (Tex. App.—Houston [1st Dist.] 2015) (standard for reviewing child-name changes and best-interest factors)
In re Guthrie, 45 S.W.3d 719 (Tex. App.—Dallas 2001) (name-change review and abuse-of-discretion standard)
Foundation Assessment, Inc. v. O’Connor, 426 S.W.3d 827 (Tex. App.—Fort Worth 2014) (discussion of abuse of discretion review)
H.E.B., L.L.C. v. Ardinger, 369 S.W.3d 496 (Tex. App.—Fort Worth 2012) (some evidence standard for discretionary rulings)
In re J.M.W., 470 S.W.3d 544 (Tex. App.—Houston [14th Dist.] 2014) (trial court discretion in ordering retroactive child support)
Rocha v. Villarreal, 766 S.W.2d 895 (Tex. App.—San Antonio 1989) (broad discretion for retroactive support awards)
In re R.V.M., 530 S.W.2d 921 (Tex. Civ. App.—Waco 1975) (discussion of attorney’s-fee awards in paternity/support context)