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Name Change

  • 1.  Name Change

    Posted 09-17-2014 04:35 PM
    I am filing a Consent Order terminating a father's parental rights in a post-judgment FM matter.  My client is also asking that the Consent Order provide for both her and the parties' son to take her maiden surname, which she did not do at the time of the divorce.  No formal application was ever filed seeking this relief (although the motion regarding custody did include the catchall provision of "just and equitable relief").

    So long as I submit a Certification from my client detailing the necessary statements regarding the legitimacy of her desire to change her name, no criminal prosecutions pending, etc., is there anything I should consider presenting to the Court for either the Mother or the Child having their name changed?

    Thanks in advance.
    -------------------------------------------
    David Cardamone Esq.
    Little Silver NJ
    (732)741-6769
    -------------------------------------------


  • 2.  RE: Name Change

    Posted 09-17-2014 04:55 PM

    I think the child may have to go through a formal name change proceeding. 

     






  • 3.  RE: Name Change

    Posted 09-17-2014 05:09 PM
    My recollection is that New Jersey does not allow a parent to voluntarily terminate parental rights absent an adoption by a step-parent.  Has the law changed?

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    Nancy Marchioni Esq.
    Middlesex NJ
    (732)667-3668
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  • 4.  RE: Name Change

    Posted 09-17-2014 05:23 PM

    I thought the inquirer said it was by Consent. 

     






  • 5.  RE: Name Change

    Posted 09-17-2014 05:32 PM
    My recollection is that it does not matter.  Even if both parties consent, one parent cannot terminate his/her parental rights unless there is an adoption by another party.  The case I am thinking about said that, while the parties may mutually agree to termination of parenting time, the financial right to support belongs to the child, not the parent and, as a matter of public policy, a parent cannot waive that right on behalf of the child.

    -------------------------------------------
    Nancy Marchioni Esq.
    Middlesex NJ
    (732)667-3668
    -------------------------------------------




  • 6.  RE: Name Change

    Posted 09-17-2014 05:34 PM

    I agree with Nancy.  NJ has a strong public policy forbidding collusive terminations of parental rights, except in the context of a proposed adoption by a step parent.  Why?  Because taxpayers and Welfare want to be certain that there is an action over against the bio parent. The case law is clear.

     

    Hanan

     


    Hanan M. Isaacs, Esq.

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    Hanan M. Isaacs, P.C.
    4499 Route 27, Kingston, NJ
    t 609.683.7400
    f 609.921.8982
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    www.hananisaacs.com

    Compassionate counsel; tough advocacy.

     

    NJSBA | Communities | All Discussions | All Discussions | Family Law

    RE: Name Change

     

    From:

    Nancy Marchioni    

    To:

    Family Law    

    Posted:

    Sep 17, 2014 5:09 PM

    Subject:

    RE: Name Change

    Message:

    My recollection is that New Jersey does not allow a parent to voluntarily terminate parental rights absent an adoption by a step-parent.  Has the law changed?

    -------------------------------------------
    Nancy Marchioni Esq.
    Middlesex NJ
    (732)667-3668
    -------------------------------------------


    I think the child may have to go through a formal name change proceeding. 

     









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    Original Message------

    My recollection is that New Jersey does not allow a parent to voluntarily terminate parental rights absent an adoption by a step-parent.  Has the law changed?

    -------------------------------------------
    Nancy Marchioni Esq.
    Middlesex NJ
    (732)667-3668
    -------------------------------------------


    Original Message:
    Sent: 09-17-2014 16:52
    From: Steven Rubenstein
    Subject: Name Change

    I think the child may have to go through a formal name change proceeding. 

     










  • 7.  RE: Name Change

    Posted 09-17-2014 05:52 PM
    My understanding is you cannot consent to terminate parental rights in an FM or FD matter unless it's regarding an adoption by step parent.  Doesn't matter if both parties consent or not. 

    Jennifer D. Armstrong
     
    Jennifer D. Armstrong, LLC
    40 Bey Lea Road, Suite C 204
    Toms River, NJ 08753
    Tel. 732-281-6000
    Fax 732-281-6100
     
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  • 8.  RE: Name Change

    Posted 09-17-2014 07:11 PM
    You cannot terminate parental rights by Consent. The best you can do is terminate parenting time indefinitely and award custodial parent sole legal custody on all issues concerning the child, unless its a step-parent adoption. I see no reason why the name change can't be done by Consent.

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    Faith Ullmann Esq.
    Owner
    Newton NJ
    (973)579-9700
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  • 9.  RE: Name Change

    Posted 09-17-2014 10:57 PM
    How did this discussion get to termination of parental rights? The question was can the mother change the child's name at the time of the divorce when she regains her birth name.  Steve and others are right - the mother must file a regular name change application for the child.  The father must either consent or be served notice of the application. If he objects, the standard is what is in the child's best interest.  See Gubernat v. Deremer, 140 N.J. 120 (1995) and J.S. v. D.M. 285 N.J. Super (App. Div. 1995)

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    Debra Guston Esq.
    Glen Rock NJ
    (201)447-6660
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  • 10.  RE: Name Change

    Posted 09-18-2014 02:18 AM

    Deb, the original message was that the attorney was filing a consent order terminating Dad's parental rights and Mom wanted to change her name and the child's to her maiden name because she had not done so when the parties divorced.

    On Sep 17, 2014 10:57 PM, "Debra Guston via New Jersey State Bar Association" < [email protected] > wrote:
    NJSBA | Communities | All Discussions | All Discussions | Family Law
    RE: Name Change  
    You are subscribed to "Family Law" as [email protected]. To change your subscriptions, go to My Subscriptions. To unsubscribe from this community discussion, go to Unsubscribe.





  • 11.  RE: Name Change

    Posted 09-18-2014 10:20 AM
    I agree with the other responses on the termination of parental rights issue.  Can't do it voluntarily any more than you could voluntarily sign yourself into prison for 3-5 years(etc); parenting is a fundamental right.  This comes up on Avvo on a regular basis, and I have a canned response I post there:

    Outside of the context of an adoption or DYFS action, you can't voluntarily terminate parental rights / responsibilities in NJ. He can't be held to his offer to do so.

    There's an often-cited trial level case on the issue - RH v. MK - http://scholar.google.com/scholar_case?case=12666217077188208034 . The court has been clear that "Parental rights are not a sometime thing. The termination of those rights entails a permanent sundering of parental ties.... The termination of parental rights is governed strictly by statute. ... [T]he Supreme Court held that the termination of parental rights by consent of the parties is valid only when effected through voluntary surrender of a child to an approved agency or to the New Jersey Division of Youth and Family Services (DYFS) accompanied by a formal document acknowledging termination of parental rights, or through a private placement adoption."

    I have seen matters where the parties do this "de facto" - the CP agrees to CS of $1 / week (citing and departing from the guidelines) and "all parenting time will be by consent of the parties" (and none is agreed), but the door is always open on both sides to go back. I don't know whether your ex would agree to this or not.   


    On the name change -- if the child is under a certain age, you can amend the birth certificate by filling out a form.  Outside of that, I've had judges sign consent orders to change a child's name by consent, but, again, that was a younger child.  I'd try both methods and then resort to the more expensive "formal process" if that doesn't work.

    -------------------------------------------
    - Dave

    David Perry Davis, Esq.
    112 West Franklin Avenue
    Pennington, NJ 08534
    Voice: 609-737-2222
    Fax: 609-737-3222
    -------------------------------------------



  • 12.  RE: Name Change

    Posted 09-18-2014 10:41 AM
    Thank you everyone for your input.  

    I do want to make clear that I was aware of the legal precedent which would forbid a formal "termination of parental rights" in this context, which is why the Consent Order is worded in a way which attempts to get around the issue and does not make it a permanent termination, more so a present consent to sole custody and no parenting time and a pledge by the Plaintiff not to seek child support.  

    While I can see the purpose behind the restriction on termination of parental rights, this case is unique in that there are allegations of sexual assault on the child by the father, although not proven (the child is 4 and is the only "witness"), which makes me think that there is a strong argument to go against public policy based upon the best interests of the child.

    What I find interesting is that we allow single individuals to adopt.  We allow unmarried couples to adopt.  We allow unmarried non-cohabitants (whether good friends of the parents who name them guardians in a will, etc.) to adopt.  It seems odd that we would not allow a single mother to "adopt" away the rights of the father.  Would it be permissible to have the grandmother "adopt" the father's rights?  Is that necessarily different than a step-father adopting the child, beyond it not being a "traditional family"?  This is all a philosophical and ideological discussion, but it is interesting nonetheless, especially as our society changes.

    Thank you again for your comments and help.

    -------------------------------------------
    David Cardamone Esq.
    Little Silver NJ
    (732)741-6769
    -------------------------------------------




  • 13.  RE: Name Change

    Posted 09-18-2014 10:53 AM
    David,

    One last word of caution (and this is based solely on the wording of your e-mail); a "pledge" not to seek child support may not pass muster with the Court.  Rather, the wording should focus on the fact that, at the present time, the mother has the financial ability to support the child in accordance to standards maintained during the marriage and, as such, is not seeking child support at this time.  Again, the key to remember is that it is not the mother's right to waive child support nor can the consideration for the agreement regarding custody and parenting time be a bargaining away of the right to child support.  As long as it appears, from the face of the agreement that an allowance is made for modification in the future, if necessary, you should be all right.

    -------------------------------------------
    Nancy Marchioni Esq.
    Middlesex NJ
    (732)667-3668
    -------------------------------------------




  • 14.  RE: Name Change

    Posted 09-18-2014 12:35 PM

    I could not agree with you more, Mr. Cardamone.  In fact, many years ago (25 approx.) I had a grandfather come in and adopt in order to terminate the rights of the natural father.  It worked back then, but there may have been changes in the statute since then.

     






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