Civil Rights — freedom of religion

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United States Court of Appeals For the Seventh Circuit

Civil

Civil Rights — freedom of religion — name change

Wisconsin’s policy of requiring prisoners to get judicial approval to change their names does not violate the First Amendment or RLUIPA.

“For an inmate who finds his committed name religiously intolerable, the statutory question would be whether the need to use the judicial name–change mechanism creates a ‘substantial burden’. That could depend on how readily state courts accommodate inmates’ requests for changes of name. Mutawakkil tells us that he has never sought a formal change, because Williams v. Racine County Circuit Court, 197 Wis. 2d 841 (Wis. App. 1995), establishes that inmates’ requests for changes of name cannot be granted. That is not what Williams holds, however. The circuit court denied one inmate’s request, holding that a new name could be confusing to the prison and that the inmate did not have a good reason for his request. The court of appeals held that the circuit court’s decision was not an abuse of discretion. Williams did not say that a circuit court is forbidden to approve a new name for an inmate. Nor did that case deal with a prisoner’s contention that religious beliefs lay behind his desire to use a different name. (The name Williams proposed was ‘Romanceo Sir Tasty Maxibillion’; he was trying to play games, not to exercise a sincerely held religious belief.)”

Affirmed.

12-3121 Green v. Huibregtse

Appeal from the United States District Court for the Western District of Wisconsin, Crabb, J., Easterbrook, J.