Paul v. Michel
A mother petitioned under section 68.07 to change her minor child's first and last name; the father filed an unverified answer in opposition but did not appear at the final hearing. The trial court denied the petition, reasoning the mother could have named or renamed the child under the birth-registration statutes (ss. 382.013(3)(c), 382.016(1)(a)) and that a prior name-change petition had been denied. The Fourth District reversed, holding those statutes are not a barrier to a section 68.07 petition, that there is no limit on the number of name-change petitions and res judicata does not bar a later petition based on changed circumstances, and that the uncontroverted evidence established the change was in the child's best interest.
Key facts
- Mother petitioned to change her minor child's first and last name under section 68.07; father filed an unverified answer in opposition but did not appear at the final hearing.
- Trial court denied the petition, reasoning that the mother could have used birth-registration statutes to change the name and that a prior name-change petition had been denied.
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Why it matters
The opinion clarifies that the birth-registration statutes create no preclusive bar to a later section 68.07 judicial name change petition — a point not previously addressed head-on — and reaffirms that successive name… — full analysis with a trial
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