Shockey v. Ohler

Shockey v. Ohler is an unpublished April 2026 opinion from the Court of Appeals. Father filed a name change action which the family court denied. After he appealed, Mother retained me to defend the appeal.

The Court of Appeals affirmed the family court. It found that Father had not made a request for a hyphenated last name to the lower court so he could not raise that issue for the first time on appeal.

The Court of Appeals found Father failed to show that the preponderance of the evidence favored changing the child’s last name. It noted Mother had primary physical custody and final decision-making authority and Child primarily lived with Mother, Mother’s parents, and Child’s half-sibling, all of whom shared Mother’s surname, whereas Father lived alone with much of his family residing out of state. Accordingly, it held Father had not shown that changing the Child’s surname was in the Child’s best interest.