COA Affirms Trial Court Decision for Name Change of Child

Case: Korie M. Leslie v. Jeremy D. Farmer
by Mike Kohlhaas, Bingham Greenebaum Doll

HELD: Trial court did not abuse its discretion when, in a paternity matter, it granted Father’s motion that Child’s last name be changed to that of Father.

Child was born out of wedlock in 2010. Five months prior, Father had filed a petition to establish paternity and a request for genetic testing. Thereafter, Father was significantly – but not completely – current in his child support obligations, and maintained regular parenting time with Child.

In 2014, as Child was starting preschool, Father emailed Mother to request that Child’s last name be changed to Father’s last name. Mother would not agree. Shortly thereafter, Father filed a motion for change of name.

After a hearing, the trial court issued an order which discussed at some length the 2013 In re: Paternity of N.C.G. case dealing with the paternity name change issue. That case promoted the public policy considerations of a child taking the father’s last name where the father pays support, is actively involved with the child’s life, and has demonstrated a desire to solidify his bond with the child. Finding those circumstances to be true in this case, the trial court ordered that Child’s name be changed to Father’s last name. Mother appealed.

Mother argued that the order for name change was error because Father’s child support payment history was sporadic, the name change would be confusing to Child, and that Child is already known by Mother’s last name. The Court of Appeals rejected Mother’s arguments, finding that, Mother’s contentions notwithstanding; there was sufficient evidence to support the trial court’s decision such that it was not an abuse of discretion.

The trial court’s order for change of name was affirmed.

To view the text of this opinion in its entirety, click here: Korie M. Leslie v. Jeremy D. Farmer



James A. Reed and Michael R. Kohlhaas of Bingham Greenebaum Doll represent clients in a wide spectrum of relationship transition and wealth planning matters, including premarital agreements, estate planning, cohabitation, separation, divorce (especially involving high net worth individuals and/or complex asset issues), custody, parenting arrangements, adoption, and domestic partnerships. Bingham Greenebaum Doll, a multidisciplinary law firm serving regional, national, and international clients, is the fourth-largest law firm in Indiana. The firm’s main practices include corporate, property, litigation, labor, government law, and personal services law. Visit the firm’s website at

ICLEF • Indiana Continuing Legal Education Forum, Indianapolis, IN

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