No Presumption that Child Should Bear the Last Name of One Parent Over the Other

Recent Case: M.R.H., Respondent, vs. J.N.P., Appellant.
Missouri Court of Appeals, Eastern District - ED97338

J.N.P. ("Mother"), biological mother of M.R.H. ("Child"), appeals from the judgment of the trial court following a paternity suit brought by M.R.H. ("Father") in the Circuit Court of St. Louis County. Mother argues the trial court erred in failing to grant her request to change Child's surname from Father's alone, to a hyphenated combination of both Mother and Father's surnames.

AFFIRMED. Division Three Holds: When analyzing requested changes to a child's surname during paternity actions, the trial court is afforded wide discretion. Here, the trial court rejected Mother's requested alteration to Child's surname after holding a hearing on the matter and listening to the testimony of both Mother and Father as to their respective positions. Upon our review of the record, the Court finds that the trial court did not abuse its discretion in making its determination.