Document Type

Case Summary

Publication Date

6-6-2024

Case Synopsis

Any incarcerated person can change their name, even if they were convicted of an offense that precludes their record from being sealed. The name change statute unambiguously accounts for an applicant’s criminal record. The criminal record follows them to their new name, so they cannot circumvent record-sealing requirements. The district court also reasoned that public policy precluded the petitioner from changing his name because he committed a sexual offense against a minor. The Court did not address the district court’s public policy findings.

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