Names shape a person’s entire life, so parents must choose carefully. However, courts have made some baby names illegal that could harm a child’s future in schools, workplaces, or government records. These rejected names show what happens when parental creativity crosses legal boundaries, forcing judges to protect children from choices that could follow them for decades. Here are ten names that U.S. courts and officials have rejected.
1. Messiah/Jesus Christ
In 2013, Tennessee judge Lu Ann Ballew forced parents to change their baby’s name from Messiah to Martin, declaring the name illegal. She ruled that “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,” arguing the name would burden the child and offend Christians. The parents quickly appealed and won. While officials fired the judge for letting religious beliefs influence her legal decisions. Messiah ranked as the fourth-fastest growing name for boys nationwide from 2011 to 2012, according to Social Security Administration statistics.
2. X Æ A-12
In 2020, Elon Musk and Grimes changed their child’s name from X Æ A-12 (pronounced “X Ash A-12”) to X Æ A-Xii because California restricts names to the 26 letters of the alphabet, though it permits hyphens and apostrophes. This high-profile case demonstrates how state computer systems that store birth certificates dictate what names officials can legally record. Plus, the couple’s workaround using Roman numerals kept their carefully chosen name’s meaning while meeting legal requirements.
3. 1069
In 1976, Michael Herbert Dengler attempted to change his name to 1069 because the numbers held personal meaning for him. North Dakota and Minnesota courts both rejected his request. Ruling that most states prohibit numbers in names due to confusion and problems with official records. Minnesota offered a compromise, suggesting he could use the spelled-out version “One Zero Six Nine” instead.
Read More: 15 Baby Names Texas Doesn’t Allow
4. @ (pronounced “at”)
As email gained popularity in the 1990s, some parents attempted to use the @ symbol in their children’s names, attracted by its uniqueness as a modern digital symbol. Multiple state courts rejected these requests because computer databases can’t handle symbols, creating problems for school records and job applications. Like other symbols, it falls outside standard naming rules, making these baby names illegal despite technology’s growing influence on modern culture.
5. III (Roman numerals)
n 1984, Thomas Boyd Ritchie III, known by friends simply as “III,” applied to legally change his name to just those Roman numerals. But a California court rejected the request. The court ruled that the numerals function as symbols rather than legitimate names and worried about practical problems with identification documents and database searches. While “Thomas Boyd Ritchie III” is legal, using “III” alone removes the actual name it’s supposed to modify.
6. King/Queen/Majesty
Courts reject names like King, Queen, and Majesty because they are titles, not names. Parents often choose these hoping to give their child a sense of importance, but judges rule that names should identify people, not grant royal authority. Using titles creates confusion on birth certificates and government forms. Courts classify these royal names as illegal and have similarly rejected Lord, Duke, and Princess.
7. Offensive Language
Courts prohibit hate speech by name. In 1992, Russell Lawrence Lee attempted to change his name to a racial slur, but a California court denied the request. The court ruled this constituted “fighting words,” a legal exception to free speech for language likely to incite violence. Lee believed the name could help conquer racial hatred, but the court disagreed, establishing that names designed to offend or potentially harm others lack protection.
8. R (single letter)
After her divorce, Mary Ravitch wanted the simplest fresh start possible by changing her name to simply “R,” but the Pennsylvania court rejected her request. The judges ruled that single letters could cause problems in official records and worried about opening the door for names made of initials, numbers, or symbols. The court established that names must have substance beyond mere letters.
Read More: 20 Old Baby Names From The ‘70s You Don’t Hear Anymore
9. Santa Claus
In 1999, Robert William Handley of Ohio, who had played Santa for over 40 years, tried to change his name to “Santa Robert Claus” but faced denial. The judge ruled that the public holds a claim to Santa’s identity. Saying Handley was trying to claim “the identity of an individual that this culture has recognized throughout the world.” However, David Lynn Porter successfully changed his name to “Santa Claus” in Utah in 2001 after the state Supreme Court overturned a lower court’s denial.
10. Texting Shortcuts
Parents who attempt to use numbers in names like “Mon1ka” face rejection in most states. Birth certificate systems handle letters only, not numbers. This applies to other number-based names like “K8” for Kate or “2morrow,” which parents often try after years of texting shortcuts. While some states like Illinois have updated their systems to accept numbers, most states still follow the traditional rule that treats numbers as symbols rather than legitimate name components.
What This Means for Parents
Parents considering unconventional names should research their state’s laws first, since states enforce different rules. Contacting the birth certificate office early in pregnancy prevents hospital surprises. Most states allow appeals when they reject names, though the process can take months. While creativity shows love, the goal is to give children names that open doors rather than close them. The most important question isn’t whether names are illegal, but whether they will serve a child well throughout life.
