Ronan v. Adely

The trial court denied the request of the mother, the primary caretaker to change the surname of her son. The issue in this appeal is whether the court properly applied the best interests of the child standard, which includes a presumption in favor of the name selected by the primary caretaker. The Appellate Division affirmed in an unpublished opinion. We conclude that the courts below applied an improper standard and reverse.

I

Plaintiff Kathleen F. Ronan (plaintiff) and defendant Peter Adely, Jr. (defendant) are the biological parents of Brendan Peter Adely. They never married, but after…