New York Court of Appeals
Barbara Merl v. Paul Merl
May 13, 198667 N.Y.2d 359
Summary
The New York Court of Appeals reversed the Appellate Division's order and denied the defendant's motion to modify child support based on his sons' change of surname. The court held that a change of surname does not constitute an unanticipated and unreasonable change in circumstances justifying modification of a separation agreement incorporated into a divorce decree.