Luke A. Giegerich v. Samantha A. Lahr, 16-0687

Samantha Lahr had a brief relationship with Luke Giegerich in 2013; a child was born during Samantha’s marriage to Jesse Lahr. A later DNA test established Luke as the father.
Samantha delayed informing Luke of the birth for six months and initially told him the child was Jesse’s.
Luke filed to establish paternity, custody, physical care, visitation, and support; Jesse was joined and later disestablished as legal father.
The parties agreed on most issues at mediation (including the mother’s maiden name for the child), but disputed physical care; the district court awarded joint legal custody, physical care to Luke, and ordered the child’s surname changed to Giegerich.
Samantha appealed both the physical-care placement and the surname determination. The appellate court reviewed de novo but deferred to trial credibility findings.

Issue	Plaintiff's Argument (Lahr)	Defendant's Argument (Giegerich)	Held
Whether physical care should be placed with Luke	Samantha argued she should retain physical care (or joint physical care); she contested findings on communication and support for Luke’s role	Luke argued he should have physical care because he better supports the parent–child relationship, communicates, and Samantha undermined his role	Affirmed: physical care placed with Luke based on poor parental communication, Samantha’s failure to support Luke’s role, and history of conflict
Whether child’s surname should be Giegerich	Samantha proposed using her maiden name and intended to resume it after divorce; she opposed changing it to father’s name	Luke sought the child’s surname be his so child would share name with custodial parent and siblings	Affirmed: child’s surname changed to Giegerich as in child’s best interest (convenience, family identification, mother’s intent to change her name)

In re Marriage of Williams, 589 N.W.2d 759 (Iowa Ct. App.) (standards for appellate review of equitable family-law issues)
In re Marriage of Brown, 487 N.W.2d 331 (Iowa) (trial court credibility findings accorded deference)
In re Marriage of Hansen, 733 N.W.2d 683 (Iowa) (nonexclusive list of factors for physical-care determinations; no parental-gender preference)
Heyer v. Peterson, 307 N.W.2d 1 (Iowa) (applicability of custody factors irrespective of marital status)
In re Marriage of Gulsvig, 498 N.W.2d 725 (Iowa) (parental naming rights and challenge to a child’s surname determined by child’s best interests)
Montgomery v. Wells, 708 N.W.2d 704 (Iowa Ct. App.) (best-interest focus for initial surname determinations)