Leonard v. Commonwealth, 296 Va. 479 (2018)

In the case Leonard v. Commonwealth, 296 Va. 479 (2018), a transgender inmate was seeking a name change. Inmates seeking a name change must establish good cause, which then permits the court to make a merits-based decision at a hearing. If an applicant alleges sufficient facts, taken as true, then the court must find good cause. The applicant stated that she was transgender and that a name change would psychologically benefit her. The lower court denied her application without scheduling a hearing for lack of good cause. On appeal, the Supreme Court of Virginia held that the applicant had established good cause and that the lower court was required to hold a hearing. The Court emphasized that good cause is not a discretionary matter and that a name-change application may be denied at the court’s discretion only after a hearing.