Thursday, May 7, 2026
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Court of Appeal:
No Error in Denial of Name-Change Petition Seeking to Add ‘Hitler’ as New Surname
By a MetNews Staff Writer
Div. One of the Fourth District Court of Appeal held yesterday that a trial judge did not err in denying an application for court approval to change her name from three monikers to eight based on a finding that the proposal “raises the likelihood of inciting violence” due to the inclusion of “Hitler” as an additional surname.
Daniele Eugenia Springsteed filed a petition in the superior court to have her name legally changed to “D. Envy Kagome Lara Artemis Neko Hitler Springsteed” in June, citing a desire to “have the same last name as my 8 kids and have 8 names like my kids do.”
On July 29, San Diego Superior Court Judge Blair Soper denied the request, citing the 1992 decision by this district’s Div. Six in Lee v. Superior Court, which held that there was no error in an order denying a name-change application by a party seeking to use a racial slur as a surname based on findings that the proposal would be confusing and raise the potential for violence. Soper commented:
“The court states that due to the length of the name it is inherently confusing and…because one of the proposed names is Hitler, it raises the likelihood of violence due to its incendiary history.”
Yesterday’s unpublished opinion, authored by Justice David M. Rubin and joined in by Acting Presiding Justice Terry B. O’Rourke as well as retired Justice Richard D. Huffman, sitting by assignment, affirms the order.
Judicial Discretion
The petition was filed under Code of Civil Procedure §§1275 and 1278, which together specify that “applications for change of names must be determined by the Superior Courts” and that a judge “may make an order changing the name, or dismissing the petition…, as the court may deem right and proper.”
Rubin acknowledged that Springsteed, “appear[ed] as a self-represented litigant,” but said that her status did not eliminate the obligation to affirmatively show error in the underlying decree. Finding that she had failed to do so, he wrote:
“Springsteed does not address the court’s findings that her proposed name was ‘inherently confusing’ or that the name Hitler ‘raises the likelihood of inciting violence due to its incendiary history.’ ”
He added:
“Even if Springsteed had not forfeited her challenge to the trial court’s ruling, we fail to see how it abused its discretion in applying Lee to its analysis of the surname Hitler. In different contexts, courts throughout the country have determined that name is offensive….We conclude the trial court did not abuse its discretion in determining…‘that the proposed surname was vulgar, offensive, and a racial slur.’ ”
Failed Attempt
The court noted that Springsteed attempted to distinguish Lee but that “she incorrectly” asserted that the case “involved a petitioner seeking to impersonate a public figure for improper purposes.” Rubin explained:
“In upholding the trial court’s denial of the name change petition, the Court of Appeal [in Lee] explained, ‘The proposed surname is commonly considered to be a racial epithet and has the potential to be a “fighting word.” Appellant has the common law right to use whatever name he chooses. He may conduct whatever social experiment he chooses. However, he has no statutory right to require the State of California to participate therein.’ ”
Saying that “case law supports denying a name change petition” when the new name would be “inherently confusing,” Rubin wrote:
“Here, however, due to forfeiture, we decline to address whether the court acted within its discretion to conclude the proposed name was ‘inherently confusing’ due to its ‘length.’ ”
The case is Springsteed v. Superior Court (San Diego), D086523.
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