Virginia's Supreme Court upheld the denial of a father's petition to change his out-of-wedlock's child's last name to his own. The child had the mother's maiden name and the mother had married, so that the child's last name was not shared with either parent. The father claimed that this made the standard from Spero v. Heath, 267 Va. 477 (2004) not applicable. However, the Court found that the father complained only of minor inconveniences to himself, not actual detriment to the child, from the child's existing name, and "the controlling standard remains the same - - that the petitioning party must prove by satisfactory evidence that the change is in the child's best interests." McMahon v. Wirick (9/12/14).