In re Change of Name of J.K.J.M. to K.J.A.W.

CourtOhio Court of Appeals
DecidedJuly 10, 2026
Docket25 CO 0044
StatusPublished

This text of In re Change of Name of J.K.J.M. to K.J.A.W. (In re Change of Name of J.K.J.M. to K.J.A.W.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Change of Name of J.K.J.M. to K.J.A.W., (Ohio Ct. App. 2026).

Opinion

[Cite as In re Change of Name of J.K.J.M. to K.J.A.W., 2026-Ohio-2727.]

IN THE COURT OF APPEALS OF OHIO SEVENTH APPELLATE DISTRICT COLUMBIANA COUNTY

IN THE MATTER OF:

THE CHANGE OF NAME OF J.K.J.M. TO K.J.A.W.

OPINION AND JUDGMENT ENTRY Case No. 25 CO 0044

Civil Appeal from the Court of Common Pleas, Probate Division, of Columbiana County, Ohio Case No. 2025 NC 00034

BEFORE: Cheryl L. Waite, Carol Ann Robb, Katelyn Dickey, Judges.

JUDGMENT: Reversed.

Atty. Timothy A. Barry, Fitch, Kendall, Cecil, Robinson & Barry Co., LPA, for Appellant

No Brief filed on behalf of Appellee

Dated: July 10, 2026 –2–

WAITE, P.J.

{¶1} Appellant Lindsay Amber West, mother of J.K.J.M., appeals the denial of

her application seeking a name change for her child. Father did not appear or oppose

the name change at trial and has not filed a brief on appeal. Appellant provided evidence

that she is the sole caretaker of the child, that it is inconvenient for the child to have a last

name that is different than hers, that Father has a reputation for violence, Father’s family

and family name is infamous in the Canton, Ohio area, and the name change would have

no effect on the child’s relationship with Father. Based on this record, the trial court

abused its discretion in denying the name change application. Appellant’s assignment of

error has merit and the trial court’s judgment is reversed.

Facts and Procedural History

{¶2} On August 6, 2025 Appellant filed an Application for Change of Name of

Minor (“Application”) in the Columbiana County Court of Common Pleas, Probate

Division. In support of the Application she filed a statement of support, the birth certificate

of her son J.K.J.M., an affidavit in support, a statement of the reason for the requested

change, the dockets of two criminal cases filed against Father, photos of the damage

Father caused to the couple’s residence, and two pages of text messages between

Appellant and Father. Appellant and Father are not, and have never been, married.

{¶3} A hearing on the Application occurred on October 1, 2025. Appellant

testified in support of the Application. Appellee Father did not appear and filed nothing in

opposition to the name change application. On October 2, 2025 the probate court denied

the Application. This timely appeal followed. Appellee has not appeared or filed a brief

in this appeal.

Case No. 25 CO 0044 –3–

{¶4} Appellant raises one assignment of error.

ASSIGNMENT OF ERROR

THE TRIAL COURT ABUSED ITS DISCRETION WHEN IT DENIED THE

APPLICATION OF LINDSAY AMBER WEST TO CHANGE THE NAME OF

HER MINOR SON.

{¶5} Appellant requested to change the last name of her minor son from that of

Father to her last name. Appellant mother and Appellee were never married, but Father’s

last name was given to the child. Father did not appear in the trial court to oppose the

name change Application and has not appeared in this appeal. The Columbiana Court

of Common Pleas, Probate Division, denied the Application. Appellant argues on appeal

that the trial court’s denial in this matter amounts to an abuse of discretion.

{¶6} An appellate court reviews a probate court decision to grant or deny an

application for name change of a minor under an abuse of discretion standard.

Evangelista v. Horton, 2011-Ohio-1472, ¶ 63 (7th Dist.). “The term ‘abuse of discretion’

means an error in judgment involving a decision that is unreasonable based upon the

record; that the appellate court merely may have reached a different result is not enough.”

Craig v. Athey, 2025-Ohio-336, ¶ 22 (7th Dist.), quoting In re S.S.L.S., 2013-Ohio-3026,

¶ 22 (7th Dist.).

{¶7} Pursuant to App.R. 18(C), “if an appellee fails to file the appellee's brief

within the time provided by this rule . . . the court may accept the appellant's statement of

the facts and issues as correct and reverse the judgment if appellant's brief reasonably

appears to sustain such action.” In applying this rule, the appellate court may reverse the

Case No. 25 CO 0044 –4–

trial court judgment solely upon the consideration of the Appellant’s brief if reversal is

reasonable. In re Change of Name of Dotson, 2005-Ohio-367, ¶ 10 (4th Dist.). This is

true even when the issue under review is whether the trial court abused its discretion in

denying an application for a change of name. Id.

{¶8} An application for a change of name of a minor is governed by R.C. 2717.01

et seq. Most of the caselaw reviewing name change applications is based on a prior

version of the statute, which was completely changed and amended effective August 17,

2021. Under the current law, the court may order the name change “upon proof that the

facts set forth in the application show reasonable and proper cause for changing the name

of the applicant ” R.C. 2717.09. Caselaw has also determined that the name change

must be in the best interests of the child. In re Willhite, 85 Ohio St.3d 28 (1999),

paragraph one of the syllabus. “When the name change involves a minor child, the [trial]

court must consider the best interests of the child in making its determination.”

Evangelista at ¶ 66.

{¶9} Appellant argues that there are eight factors for the trial court to consider

when evaluating which last name a child shall bear when the parents have never been

married: “[T]he effect of the change on the preservation and development of the child's

relationship with each parent; the identification of the child as part of a family unit; the

length of time that the child has used a surname; the preference of the child if the child is

of sufficient maturity to express a meaningful preference; whether the child's surname is

different from the surname of the child's residential parent; the embarrassment,

discomfort, or inconvenience that may result when a child bears a surname different from

the residential parent's; parental failure to maintain contact with and support of the child;

Case No. 25 CO 0044 –5–

and any other factor relevant to the child's best interest.” Willhite at 32. Although Willhite

was based on a previous version of the relevant statute, the Willhite factors continue to

be cited as the basis for making a best interests determination in change of name cases.

In re J.A.M.V., 2013-Ohio-2502, ¶ 11 (7th Dist.); Matter of E.M.T., 2025-Ohio-4638, ¶ 24

(11th Dist.); In re Name Change of C.L.F., 2022-Ohio-2300, ¶ 7 (10th Dist.). Appellant

has addressed each of the eight factors to show that the trial court abused its discretion

in denying the name change Application in this matter.

{¶10} First: she contends the effect on the preservation and development of the

child’s relationship with the parents will be positive for Appellant and have no effect on

Father. Appellant is the sole caretaker of the child, the sole means of support, and the

child sees Appellant every day. Appellee Father is only minimally involved in the child’s

life, does not wish to be more involved, and provides no assistance of any kind. Again,

this record reflects that Appellee Father did not challenge the name change application

in any way, failed to appear in the trial court, and does not challenge this appeal.

{¶11} Second: the child’s identification with a family unit. Appellant argues that

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Related

In re S.S.L.S.
2013 Ohio 3026 (Ohio Court of Appeals, 2013)
In re J.A.M.V.
2013 Ohio 2502 (Ohio Court of Appeals, 2013)
Evangelista v. Horton
2011 Ohio 1472 (Ohio Court of Appeals, 2011)
State v. Grimes
477 N.E.2d 1219 (Ohio Court of Appeals, 1984)
Ford Motor Credit Co. v. Potts
502 N.E.2d 255 (Ohio Court of Appeals, 1986)
In Re Change of Name of Dotson, Unpublished Decision (1-28-2005)
2005 Ohio 367 (Ohio Court of Appeals, 2005)
State v. Middleton
619 N.E.2d 1113 (Ohio Court of Appeals, 1993)
Helmeci v. Registrar, Bureau of Motor Vehicles
598 N.E.2d 1294 (Ohio Court of Appeals, 1991)
Fuller v. Fuller
290 N.E.2d 852 (Ohio Court of Appeals, 1972)
State v. Miller
673 N.E.2d 934 (Ohio Court of Appeals, 1996)
Bell v. Horton
669 N.E.2d 546 (Ohio Court of Appeals, 1995)
State ex rel. Davidson v. Beathard (Slip Opinion)
2021 Ohio 3125 (Ohio Supreme Court, 2021)
In re Name Change of C.L.F.
2022 Ohio 2300 (Ohio Court of Appeals, 2022)
State v. Dehass
227 N.E.2d 212 (Ohio Supreme Court, 1967)
Seasons Coal Co. v. City of Cleveland
461 N.E.2d 1273 (Ohio Supreme Court, 1984)
In re Willhite
706 N.E.2d 778 (Ohio Supreme Court, 1999)
In re E.M.T.
2025 Ohio 4638 (Ohio Court of Appeals, 2025)
Bloor v. Barnes
Ohio Court of Appeals, 2026

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