Everyone needs a hobby.
Mine is Fun Name Change Cases. I got hooked when I read about Michael Dengler, who wanted to change his name to 1069. "The only way [my] identity can be expressed is 1069," he told the court.
Then came the news about Talula Does the Hula From Hawaii, a 9-year-old New Zealand girl. A judge apparently saw the name as a form of child abuse - the girl had complained that "she fears being mocked and teased" about it - and took legal custody of her "to ensure that a proper name was found."
Now, for the would-be 1069s and Talulas Do the Hulas, thanks to my hobby, here are some legal precedents:
1069. No dice. The North Dakota (1976) and Minnesota Supreme Courts (1979) both say: Names can't be numbers.
III (pronounced "Three.") No, on the same grounds, said the California Court of Appeal in 1984 to Thomas Boyd Ritchie III.
Mary R. No, decided the Pennsylvania Superior Court in 2000, dealing with Mary Ravitch, who no longer wanted to use her ex's last name nor return to her maiden name (Gon). "Appellant's desired surname is so bizarre that it would likely be met with repeated suspicion and distrust in both business and social settings."
Misteri Nigger, second "i" silent. No, said a California court in 1992, because it constitutes "fighting words": "If a man asks appellant his name and he answers 'Mister Nigger,' the man might think appellant was calling him 'Mister Nigger.' Moreover, third persons, including children hearing the epithet, may be embarrassed, shocked or offended." Definitely does sound like asking for trouble- Russell Lawrence Lee is much safer.
Santa Claus. A split: An Ohio judge in 2000 rejected Robert Handley's attempt to become Santa Robert Clause:
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 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.
But the Utah Supreme Court in 2001 let David Porter become just plain Santa Claus, never mind the kids: "Porter's proposed name may be thought by some to be unwise, and it may very well be more difficult for him to conduct his business and his normal everyday affairs as a result. However, Porter has the right to select the name by which he is known, within very broad limits."
Koriander, with no last name, apparently chosen because of Rosa Linda Ferner's "attraction to a name that sounds appropriate for her work as an artisan." Just fine, a New Jersey judge ruled in 1996.
They, with no last name. OK, said a Missouri judge to the inventor formerly known as Andrew Wilson. "They" explained: " 'They do this,' or 'They're to blame for that.' Who is this 'they' everyone talks about? . . . Somebody had to take responsibility."
Darren QX (pronounced Lloyd) Bean! No problem!, holds our friend the California Court of Appeal in 2006.
Bean!, who took the Oregon bar exam, said that "Many of his close friends greet him as 'Bean!' When saying his name, friends raise the pitch and the volume of their voices above their usual spoken tone." The court didn't opine further on this because "this information is not contained in the appellate record." Still, the court reasoned, if O'Rourke with an apostrophe is fine, so is Bean!
"At least three people have changed their names to the names of websites with a '.com' in the name. Virginia animal rights activist Karin Robertson legally changed her name to GoVeg.com in 2003 to bring attention to a website of her employer, People for the Ethical Treatment of Animals . . . We do not find a legal distinction between a period inside a word, a hyphen between words, an apostrophe in a word, and an exclamation point at the end of a word."
Boys changing their names from, or to, Sue. No known cases. *
Eugene Volokh is a professor of law at UCLA School of Law and the co-founder of the Volokh Conspiracy blog.