Julie Ann Anderson v. Anthony Douglas Dainard, 2015 Tex. App. LEXIS 10320

Julie Ann Anderson (mother) and Anthony Dainard (father) had an unwed relationship; Anderson gave birth in April 2012 and initially gave the child the surname Anderson.
The Office of the Attorney General filed a parentage and child support action; DNA testing established Dainard as the biological father.
Temporary orders named both parents joint managing conservators, awarded primary residence to Anderson, required child support and insurance from Dainard, and provided limited visitation.
Dainard sued to change the child’s surname to Dainard; the parties resolved most issues in a mediated settlement agreement but disputed the surname.
At trial (child ~2 years old), both parents testified: Anderson emphasized the child’s 90% residence with her and established use of Anderson; Dainard argued a name change would promote a father–daughter bond and noted his regular support and visitation.
The trial court granted the name change; Anderson appealed arguing insufficient evidence that the change was in the child’s best interest.

Issue	Plaintiff's Argument (Anderson)	Defendant's Argument (Dainard)	Held
Whether the trial court abused its discretion by ordering a child’s surname change	Evidence was legally and factually insufficient to show the name change is in the child’s best interest (claims potential confusion, established use of Anderson)	Changing the name is in the child’s best interest because it will help form a father–daughter bond; father is meeting obligations and participates in the child’s life	Affirmed: no abuse of discretion; sufficient evidence supported best-interest finding

In re A.E.M., 455 S.W.3d 684 (Tex. App.—Houston [1st Dist.] 2014) (standard for reviewing child name-change orders and best-interest focus)
In re Guthrie, 45 S.W.3d 719 (Tex. App.—Dallas 2001) (name-change best-interest is fact-specific; appellate deference to trial court)
In re H.S.B., 401 S.W.3d 77 (Tex. App.—Houston [14th Dist.] 2011) (enumeration of nonexclusive best-interest factors for name changes)
Moreno v. Perez, 363 S.W.3d 725 (Tex. App.—Houston [1st Dist.] 2011) (abuse-of-discretion review incorporates sufficiency analysis)
City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (legal-sufficiency standards)
Retamco Operating, Inc. v. Republic Drilling Co., 278 S.W.3d 333 (Tex. 2009) (implied findings where trial court issues no findings)
McGuire v. McGuire, 4 S.W.3d 382 (Tex. App.—Houston [1st Dist.] 1999) (two-pronged inquiry for sufficiency under abuse-of-discretion)
In re M.C.F., 121 S.W.3d 891 (Tex. App.—Fort Worth 2003) (trial court not required to avoid conflicting evidence when exercising discretion)