7 Names That Have Been Challenged In U.S. Courts

Many baby names and adult name-change petitions have faced scrutiny.
The U.S. legal system is relatively lax when it comes to names, but there have still been many headline-making cases.
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The U.S. legal system is relatively lax when it comes to names, but there have still been many headline-making cases.

Many countries have strict laws regulating the names parents are allowed to give their children. In France, for instance, courts have rejected baby names like Nutella, Prince William and Fraise (French for “Strawberry”) on the grounds that they go against the best interests of the child by subjecting them to mockery.

The U.S., by comparison, is relatively lax when it comes to names. Though there are state laws forbidding things like numerical digits or pictograms as names, the possibilities remain vast. In 2009, a New Jersey toddler named Adolf Hitler Campbell made headlines after a bakery refused to decorate a birthday cake with his name. Although the bakery objected to inscribing the name, it seems the state of New Jersey could only object to the name if it contained an obscenity, numerals or symbols.

“If the Campbells had named their son ‘R2D2,’ state authorities would have intervened,” University of California, Davis School of Law professor Carlton Lawson wrote in a 2011 report on baby naming rights in the U.S. ”‘Adolf Hitler Campbell,’ by contrast, presented no legal impediments.”

So what names have come under scrutiny in the U.S. legal system? HuffPost took a look at baby name and adult name-change cases that have sparked interest over the years.


In 2013, a child support magistrate in East Tennessee ruled that a 7-month-old boy named Messiah must have his name changed to Martin.

“The word ‘Messiah’ is a title, and it’s a title that has only been earned by one person, and that one person is Jesus Christ,” Magistrate Lu Ann Ballew proclaimed.

After the parents appealed, Chancellor Telford E. Forgety overturned the decision on the basis of unconstitutionality and Ballew was fired.


In 1976, the North Dakota Supreme Court ruled that short-order cook and high school teacher Michael Herbert Dengler could not change his name to “1069.”

“The only way [my] identity can be expressed is 1069,” Dengler insisted, breaking down the significance of each digit.

“The first character, 1, stands for my concept of nature which manifests itself as one individual among the various forms of life,” he noted. “I stand as a single entity amongst millions of other entities, animate and inanimate. But yet even though I am an entity unto myself, I am part of the whole of life which is one. I am one; life is one; and together we are one.”

Dengler later pursued the matter in Minnesota, but was again unsuccessful, as neither state would allow a number as a name.


A 1984 ruling from the California Courts of Appeal denied a request from Thomas Boyd Ritchie III to change his name to the Roman numeral “III” ― pronounced “Three.”

“Here petitioner wants to be called ‘Three’ but he wants to have it spelled ‘III,’” reads a concurring opinion. ”‘III’ is simply not a word, it is a symbol. A person might change his name to ‘number’ but surely he could not spell that name ‘#.’ The same rationale would apply to the name ‘period’ spelled ‘.’ or ‘question mark’ spelled ‘?’.”


San Francisco Chronicle writer Louis Freedberg lamented California policy barring accent marks from birth name records in a 2002 opinion piece.

“[W]hen I tried to record my newly-born daughter’s name Lucía on her birth certificate last week I was told I couldn’t,” he wrote. “At least not correctly. I was told I had to record her name without that pesky accent ― as Lucia (which would be pronounced LOOsha), rather than Lucía (as in LooSEEyah).”

Santa Claus

In December 1999, Robert William Handley of Ohio filed a petition to change his name to Santa Robert Claus. Handley reportedly played the role of Santa Claus at Christmastime for over 40 years, and went by the nickname “Santa Bob” year-round.

Judge Lawrence Belskis denied his petition, noting:

The petitioner is seeking more than a name change, he is seeking the identity of an individual that this culture has recognized throughout the world, for well over one hundred years. Thus, the public has a proprietary interest, a proprietary right in the identity of Santa Claus, both in the name and the persona. Santa Claus is really an icon of our culture; he exists in the minds of millions of children as well as adults.

The history of Santa Claus ― the North Pole, the elves, Mrs. Claus, reindeer ― is a treasure that society passes on from generation to generation, and the petitioner seeks to take not only the name of Santa Claus, but also to take on the identity of Santa Claus. Although thousands of people every year do take on the identity of Santa Claus around Christmas, the court believes it would be very misleading to the children in the community, particularly the children in the area that the petitioner lives, to approve the applicant’s name change petition.

It’s worth noting, however, that the Supreme Court of Utah allowed David Lynn Porter to change his name to Santa Claus in 2001.

Misteri Nigger

In 1992, the California Courts of Appeal denied Russell Lawrence Lee’s petition to change his name to Misteri (pronounced Mister) Nigger.

“The proposed surname is commonly considered to be a racial epithet and has the potential to be a ‘fighting word,’” wrote Justice Kenneth R. Yegan. “Appellant has the common law right to use whatever name he chooses. He may conduct whatever social experiment he chooses. However, he has no statutory right to require the State of California to participate therein.”

Though Lee said he hoped to take on the name to “steal the stinging degradation ― the thunder, the wrath, the shame and racial slur ― from the word,” the court believed it would pose too many problems.

Chief Piankhi Akinbaloye

Maurice Lee Thompson sought to change his name to Chief Piankhi Akinbaloye, in 1975, but the Civil Court of the City of New York rejected this request due to the “Chief” part:

“[T]o permit petitioner’s application as proposed would be tantamount to the bestowal of an apparent title of authority. Such indiscretion would tend to confuse those members of the public who might come into contact with the petitioner. While the court is certain that this petitioner’s motives are sincere, other less scrupulous persons should be discouraged from seeking undeserved titles of authority under the guise of seemingly innocent name changes.”

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