## Facts

- A divorced mother filed a verified complaint to change her sixteen-year-old child’s legal name from “Veronica” to “Trevor Adam Betts.”  
- The parents shared joint legal custody; the father initially opposed the request but stated at the hearing that he would consent.  
- The child identified as male, lived socially as “Trevor” for several years, and was known by that name in school and the community; the father and stepfamily continued using the birth name.  
- With puberty, the child experienced severe distress tied to gender identity and was hospitalized twice for suicidal ideation.  
- The child participated in ongoing counseling and a treatment plan that included menstrual suppression and testosterone therapy.  
- The court found the statutory and rule-based filing requirements were satisfied and the request was not made for fraudulent purposes or to evade criminal proceedings.  
- Evidence showed practical and safety-related problems when official records did not match the child’s lived name (e.g., school, medical settings, identification documents).

## Issues

1. What standard governs a minor transgender child’s application for a legal name change under New Jersey law?  
2. Under that standard, was changing the child’s legal name from “Veronica” to “Trevor Adam Betts” in the child’s best interests?

## Decision

- The court applied the “best interests of the child” standard to a transgender minor’s name-change application.  
- The court adopted a nonexclusive, factor-based framework tailored to the transgender-minor context.  
- Applying those factors, the court found the requested change served the child’s best interests.  
- The court granted the legal name change to “Trevor Adam Betts.”

## Legal Principles

- A minor’s name change is governed primarily by the child’s best interests, not parental preference, when statutory prerequisites are met and no fraud or improper purpose is shown.  
- In transgender-minor name-change cases, relevant best-interest considerations include:  
  - the child’s age;  
  - the length of time the child has used the preferred name;  
  - likely anxiety, embarrassment, or discomfort from a name inconsistent with outward appearance and gender identity;  
  - the child’s medical and mental-health counseling history;  
  - the name used for the child in family, school, and community settings;  
  - the child’s preference and motivations; and  
  - whether both parents consent, and if not, the reasons for withholding consent.  
- Verified-complaint procedures and disclosures required by New Jersey’s name-change statute and court rules must be satisfied before reaching the merits.

## Conclusion

The court granted a transgender minor’s requested name change after holding that the controlling standard is the child’s best interests and identifying specific factors to assess how legal name congruence affects well-being, treatment history, social functioning, and parental positions.


Sacklow v. Betts, 450 N.J. Super. 425, 163 A.3d 367 (Ch. Div. 2017)