## Facts

- Renee Monique Melbourne (mother) and Marcus Taylor (father) married and had a child; the child was given Taylor’s surname.
- The parties later divorced. Melbourne received primary custody, and Taylor received reasonable visitation.
- Taylor was ordered to pay child support and provide health insurance for the child, and he remained current on those obligations.
- Because Melbourne and the child had different last names, third parties repeatedly assumed Melbourne’s surname was “Taylor.”
- At daycare, a worker incorrectly recorded Melbourne’s last name as “Taylor” when she dropped off the child; when Melbourne returned to pick up the child without identification showing “Taylor,” she had difficulty retrieving the child until a director intervened.
- A similar confusion occurred in a hospital setting due to the surname mismatch.
- Melbourne applied to change the child’s surname from Taylor to Melbourne, citing these recurring problems.
- Taylor opposed the application, testifying that he was trying to remain involved in the child’s life and that a surname change would estrange him from the child; he also testified he would not treat the child differently if the name changed.
- The trial court denied the application after stating it was applying a best-interests standard, but it relied on older D.C. name-change considerations, including the idea that the bond between a divorced father and child is “tenuous” and could be harmed by a name change.

## Issues

1. Whether the trial court used the correct legal framework for deciding a post-divorce request to change a minor child’s surname.
2. Whether a court may base a best-interests determination on father-centered, gender-based assumptions about post-divorce parent-child relationships.

## Decision

- The District of Columbia Court of Appeals reversed the denial of the surname-change application and remanded.
- The court held that the trial court applied an improper set of considerations drawn from older caselaw rather than the governing statutory best-interests framework.
- The court directed that the request be reconsidered under the gender-neutral best-interests factors in D.C. Code § 16-831.
- The court rejected reliance on generalized statements about divorced fathers’ relationships with their children, explaining that such gender-based assumptions are improper and raise serious constitutional concerns.

## Legal Principles

- A request to change a minor child’s surname in this context must be decided under the child’s best interests as expressed in D.C. Code § 16-831.
- Best-interests findings must be based on record evidence about the particular child and family, not generalizations about mothers, fathers, or divorce.
- Courts may not use gender-based assumptions—such as a presumption that a noncustodial father’s bond is especially fragile or that a name change presumptively harms that bond—as substitutes for a statutory, child-centered analysis.
- A trial court abuses its discretion when it applies the wrong legal standard or relies on legally impermissible considerations in deciding a child-related issue.

## Conclusion

Melbourne v. Taylor requires D.C. trial courts to decide a post-divorce child surname-change request under the statutory best-interests factors in D.C. Code § 16-831 and to avoid outdated, father-centered assumptions; because the trial court relied on such assumptions, the Court of Appeals reversed and remanded for a proper best-interests determination.


Melbourne v. Taylor, 147 A.3d 1151 (2016)