When Parents Disagree, Should Child Bear the Mother’s Last Name or the Father’s?

Veronica Goudreau and Andrew Lemieux conceived a child, Alexander. (As it happens, they were minors, in high school, but that needn’t matter for the legal analysis.) They then broke up, but Lemieux wants to help raise the child.

When the child was born, Goudreau named the child Alexander Bailey Goudreau. But when the child was a year old, the father (represented by his parents as plaintiffs) asked that the child’s name be changed to Alexander Bailey Lemieux. The court renamed the child Alexander Goudreau Lemieux, reasoning,

The court makes it[s] decision based on the best interests of Alexander. Alexander has two parents who both care for him and love him. Andrew Lemieux’s commitment to Alexander should be demonstrated in Alexander’s name, as should Veronica Goudreau’s.

And on appeal, the New Hampshire Supreme Court (In re Name Change of Alexander Goudreau (N.H. Oct. 30, 2012)) agreed:

[W]e hold that the trial court sustainably exercised its discretion in changing the child’s name to Alexander Goudreau Lemieux. The record supports the trial court’s findings that, at the time of the petition’s filing, both mother and father cared for, loved, and were committed to Alexander — findings which mother does not challenge on appeal. Accordingly, we conclude that the trial court had an objective basis sufficient to sustain its conclusion that Alexander’s full name should include both parents’ surnames. On appeal “[w]e consider only whether the record establishes an objective basis sufficient to sustain the discretionary judgment made, and we will not disturb the trial court’s determination if it could reasonably have been made.” Although additional fact finding might have aided our review of the trial court’s order, we conclude that the trial court could reasonably have found that the name Alexander Goudreau Lemieux was in the child’s best interest.

But, accepting the value of maintaining a connection in the name to both parents, why does it follow that the child should be named Alexander Goudreau Lemieux, rather than Alexander Lemieux Goudreau?