The Volokh Conspiracy

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How North Dakota Is More Like Windows than UNIX

If your official name is YATES, you can't (and presumably needn't) file a petition to change it to Yates. "Petitioners have offered no authority or reasoned argument that there is any legal significance to the capitalization of their names."

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From a decision of the North Dakota Supreme Court in In re Yates (Jan. 6):

Shane Lance Yates and Amy Jo Yates petitioned the district court to change their respective names from "SHANE LANCE YATES" (in all uppercase letters) to "Shane Lance Yates" and "AMY JO YATES" (in all uppercase letters) to "Amy Jo Yates." They requested the changes to "terminate the guardian-ward relationship and to distinguish from all other aliases, correct any mistakes, errors or identity confusion that exists in relation to the ALL CAPS STATE CREATED NAME." The district court denied the petitions … [in part on the grounds that] they did not seek to change from one name to another and the requested change would not affect any action or legal proceeding or other right, title, or interest, as was the stated purpose….

[T]he district court concluded the Petitioners are not requesting a change from one name to another name. On this record, we agree. In effect, the Petitioners request a change in the capitalization of their names from all capital letters to initial capital letters followed by lowercase letters. Petitioners have offered no authority or reasoned argument that there is any legal significance to the capitalization of their names. The district court did not abuse its discretion in denying the petitions….