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.