In Lassiter-Geers v. Reichenbach, 303 Md. 88, 492 A.2d 303 (1985), the Court of Appeals first addressed the question of what standard governs when a court is asked to resolve a dispute between parents over the initial surname for their child. The Court held that "when a father and mother of a child fail to agree at birth and continue to disagree upon the surname to be given the child, the question is one to be determined upon the basis of the best interest of the child." 303 Md. at 90. In that case, the parents were married, and both used the surname Reichenbach. They separated shortly before learning the wife was pregnant. Upon giving birth, the mother gave the child the surname Lassiter, which was her maiden name. The father was not consulted and did not learn for seven months that the child had not been given the last name Reichenbach. The parents were divorced when the child was a year old, and the mother resumed the use of the name Lassiter. The father raised the issue of the child's last name in the divorce proceeding; by agreement, the issue was reserved for future determination. By the time it came up for a hearing, the mother had remarried and was using the last name Lassiter-Geers, a hyphenation of her maiden name and her new husband's surname. The trial court ruled that it was in the child's best interests to have his father's surname. The court reasoned that because the mother's maiden name, Lassiter, was not being used by either parent, the child's use of that name would prompt people to think, in error, that she was born out of wedlock, which could "'lend itself to the child being put in an embarrassing position,'" which was not in her best interests. 303 Md. at 96. The Court of Appeals affirmed the trial court's ruling. It distinguished the case from a "change-of-name" case, in which the child's parents agreed upon a surname, which the child used, but one parent later sought to change it. In that situation, a name change only is warranted if it is in the child's best interests and the moving party shows "extreme circumstances." West v. Wright, 263 Md. 297, 299, 283 A.2d 401 (1971). By contrast, in Lassiter-Geers the child's parents never agreed upon a surname for the child, and the child thus "was without a surname," regardless of what he or she was being called. 303 Md. at 93. The Court held that the inquiry in that situation is "what the surname for the child should be," which is to be answered by determining what surname will serve the child's best interests. 303 Md. at 95. The Court in Lassiter-Geers concluded that the trial court properly exercised its discretion in finding it would not serve the child's best interests to have a surname that would cause people to think she was born out of wedlock, when she was not, or to put her in the awkward situation of having to explain her "legitimacy." In so concluding, the Court assumed, without deciding, that a judicial resolution of the name dispute by application of the customary preference for children to bear their father's surnames would violate the Maryland Equal Rights Amendment. 303 Md. at 94.