Rappleye v. Rappleye

Mackenzie, J.

(dissenting). The issue in this case is whether a custodial mother may, over the objection of the noncustodial father, informally change their minor child’s surname to that of the child’s stepfather. Under the circumstances of this case, I conclude that she may not.

The parties were married in 1977. Their only child, Adria, was born November 27, 1978. In 1981, the parties separated and defendant mother took custody of Adria. By 1982, defendant and Adria were living with William Gregory. The parties were divorced in 1984. The judgment of divorce granted defendant mother physical custody of the child. Following the divorce, defendant married William Gregory.

From the time defendant and William Gregory began living together, they have called Adria ”Ad*401ria Gregory” rather than "Adria Rappleye,” the child’s birth name. Adria’s medical, dental, and school records state her surname to be Gregory, although legal documents such as her passport,, social security card, and bank account are listed in the surname Rappleye. Adria and her friends refer to her as Adria Gregory.

In 1988, plaintiff father filed a motion which in relevant part sought an order preventing defendant mother from using any surname for the minor child other than Rappleye. Following a hearing, the trial court denied the motion. The court essentially found that the child preferred to be called Adria Gregory, and found that preference controlling.

Under the common law a person may adopt any name he or she wishes, without resort to any court and without any legal proceedings, provided it is not done for fraudulent purposes. Piotrowski v Piotrowski, 71 Mich App 213, 215-216; 247 NW2d 354 (1976). There is no requirement that any person go through the courts to establish a legal change of name. Piotrowski, supra, p 216. While Michigan, as most states, has a statute authorizing procedures by which a probate court can, upon petition, change the name of any person, see MCL 711.1; MSA 27.3178(561), such name change statute does not abrogate or supersede the common-law right. Id. Moreover, the common-law right to change one’s name without legal formality extends to minors. Laks v Laks, 25 Ariz App 58; 540 P2d 1277 (1975), 57 Am Jur 2d, Name, §42, p 679. Thus, a minor can effectuate a common-law change of name on his or her own initiative, provided he or she is of sufficient age and maturity to make an intelligent choice. Id.

In this case, the decision to change Adria’s surname to Gregory was not made on her own *402initiative, nor was it made when she was capable of expressing a meaningful opinion about the change. It was instead made unilaterally by her mother and William Gregory when Adria was approximately three years old. Adria’s mother has acted to effectuate a common-law change of the child’s name; Adria has not.

A mother who has been awarded custody of a minor child may not, over the objection of the noncustodial father, unilaterally change the surname of a child to that of the mother’s subsequent husband unless the change would be in the best interest of the child. See Sobel v Sobel, 46 NJ Super 284: 134 A2d 598 (1957), Kay v Bell, 95 Ohio App 520: 121 NE2d 206 (1953), Nitzberg v Bd of Ed of City of New York, 104 NYS2d 421 (1951), Hall v Hall, 30 Md App 214; 351 A2d 917 (1976), Laks v Laks, supra, Young v Young, 356 NW2d 823 (Minn App, 1984), and Cohan v Cunningham, 104 AD2d 716; 480 NYS2d 656 (1984). See, generally, Anno: Rights and remedies of parents inter se with regard to the names of their children, 92 ALR3d 1091, §10, pp 1118-1123. There appear to be at least three rationales for this rule. Some courts have noted that, while under the common law one may adopt any name he or she chooses, that right does not grant other persons the right to select for a person a name different from the name by which such person is known. See, e.g., Kay v Bell, supra. Second, at least one court has refused to allow a unilateral name change because neither parent has a superior right to determine a child’s name. See Cohan v Cunningham, supra. The third rationale advanced is that, when there is a divorce and the mother is given custody of the children, the bond between the father and his children becomes tenuous, and if the children’s name is changed *403that bond may be further weakened or destroyed. See Laks v Laks, supra.

In deciding whether a custodial mother’s unilateral change of a child’s surname from that of the child’s father is in the child’s best interest, courts look to several factors. Primary considerations are whether the father has engaged in misconduct, or abandoned or refused to support the child. Hall v Hall, supra. The preference of the child may be given some weight, depending on the age of the child and the circumstances of the case. Id. The desirability of maintaining a bond with the father and the father’s family is given substantial weight. Id. The inconvenience or embarrassment of having more than one surname in the mother’s household has been held not to be determinative. Id.

In this case, plaintiff father has shown an interest in Adria’s welfare. He retains joint legal custody. There are no allegations of misconduct. While there have been ongoing visitation problems, plaintiff has sought to exercise his visitation rights. With one exception, when he was denied visitation, plaintiff has made support payments. The child maintains contact with plaintiff’s family; her paternal grandparents appear to exercise their visitation rights regularly. Given Adria’s young age and the circumstances of this case, it is questionable whether she is capable of making an intelligent choice in the matter. See Hall v Hall, supra. Her preference with respect to a change of name should thus be given minimal weight. On the other hand, it is apparent that the bonds between the child and her father have been greatly weakened by this divorce, and the desirability of maintaining some bond should be given substantial weight.

In light of the above, I am convinced that the trial court abused its discretion in concluding that *404defendant should not be restrained from unilaterally changing Adria’s name to Adria Gregory. There is insufficient justification for such a common-law name change at this time. Accordingly, I would reverse.