Family Law Prof Blog

Editor: Margaret Ryznar
Indiana University
Robert H. McKinney School of Law

Friday, October 28, 2005

Case Law Development: Change of Newborn's Name Requires Proof of Best Interests of Child

This case involved a paternity action filed two days after the child was born. Father asked that the child's last name be changed to his own. The evidence consisted of father's testimony regarding his desire that his son carry on his family name and the fact that son's middle name was that of his maternal grandfather. The Missouri Court of Appeals held that this sparse evidence was insufficient for Father to meet his burden of proving that a name change was in the best interests of the child.

C.R.F. v. B.M.F., 2005 Mo. App. LEXIS 1540 (October 25, 2005)
Opinion on the web at (last visited October 28, 2005 bgf)

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