The New Hampshire Supreme Court affirmed a Circuit Court decision denying an incarcerated individual's petition for a legal name change based on religious beliefs, ruling that the petitioner failed to make the required "compelling showing" under state law.
In *In re Name Change of Zebadiah Kellogg-Roe*, decided Sept. 26, 2025, the state's highest court upheld Judge Cabrera's denial of Kellogg-Roe's petition to legally change his name. The petitioner had argued that the trial court erred in finding that his religious beliefs did not constitute sufficient grounds for the name change.
Kellogg-Roe, who is currently incarcerated, testified at the hearing that he had experienced "a religious awakening" and had been "called, through visions and dreams and circumstance, to embrace the arch-goddess of the fae in a pagan wiccan state." According to his testimony, the goddess "communicated with him in dreams that [he was] to take the name Sol-Anin in accordance with her wishes and gifts."
The petitioner told the court he sought the name change so that he would not "offend or disobey [his] divinity by defying her will." His request was grounded in what he described as divine communication received through dreams and visions as part of his pagan religious practice.
New Hampshire law establishes a heightened standard for incarcerated individuals seeking name changes. Under RSA 547:3-i, II, "before the [trial] court may grant a change of name for a person who is incarcerated . . . the petitioner shall make a compelling showing that a name change is necessary." This statute creates additional requirements beyond those applicable to the general population.
The Supreme Court applied the standard established in *Sutton v. Town of Gilford* (2010), affirming the trial court's determination unless the ruling was "unsupported by the evidence or erroneous as a matter of law." Under this deferential standard of review, the high court examined whether the Circuit Court properly applied the "compelling showing" requirement.
The trial court had assumed for purposes of its analysis that Kellogg-Roe's religion provided a "compelling reason" for his name change request. However, the court found that the petitioner failed to demonstrate that a legal name change, as opposed to informal use of his desired name, was necessary for the practice of his religion.
This distinction proved crucial to the outcome. During the hearing, counsel for the New Hampshire Department of Corrections informed the court that inmates are permitted to refer to themselves by names other than their legal names and may request that others address them by their preferred names as well. This accommodation allows for religious expression without requiring formal legal proceedings.
The trial court's analysis focused on whether the legal formality of a name change was essential to Kellogg-Roe's religious practice, rather than questioning the sincerity or validity of his beliefs. By finding that informal use of the desired name could satisfy his religious needs, the court distinguished between religious accommodation and legal necessity.
The Supreme Court's affirmance reinforces the higher burden of proof required for incarcerated individuals seeking name changes. While the court did not question the authenticity of Kellogg-Roe's religious experience or beliefs, it upheld the principle that administrative convenience and security concerns justify additional scrutiny of such requests in the correctional context.
The ruling demonstrates how courts balance religious freedom with the practical constraints of incarceration. The decision suggests that when alternative accommodations can address religious needs without formal legal proceedings, courts may find that the "compelling showing" standard has not been met.
This case illustrates the complex intersection of religious liberty, administrative law, and correctional policy. While inmates retain constitutional rights to religious practice, those rights must be balanced against institutional security and administrative efficiency. The availability of informal name use provides a middle ground that respects religious beliefs while maintaining legal and administrative clarity.
The decision may influence how other incarcerated individuals approach similar religious accommodation requests. Future petitioners will likely need to demonstrate that formal legal name changes are specifically required by their religious practices, rather than merely preferred or beneficial.
The case also reflects broader questions about religious accommodation in correctional settings and the extent to which administrative alternatives can satisfy constitutional requirements for religious freedom. The court's ruling suggests that when practical accommodations exist, they may be sufficient to meet constitutional obligations without requiring formal legal changes.
Kellogg-Roe's case concluded with the Supreme Court's brief order affirming the denial, issued without oral arguments under the court's summary disposition procedures. The ruling provides guidance for future cases involving religious name change requests by incarcerated individuals in New Hampshire.