The name 1069 is not illegal in the sense that using it will get you arrested. It is illegal in the narrower, more practical sense that no state will record it as your legal name. Two state supreme courts have said so directly, and the reason sits in centuries of common law: a legal name has to be made of words, and 1069 is not a word.
The Man Who Tried to Become 1069
Michael Herbert Dengler, an adopted man from North Dakota, petitioned Cass County district court in 1976 to change his name to 1069. He said the four digits carried deep philosophical and personal meaning for him. The district court denied the petition, and the North Dakota Supreme Court upheld that denial on appeal.1Justia Case Law. Petition of Dengler
Dengler then moved to Minnesota and filed again. The Minnesota Supreme Court also turned him down. It did leave him one narrow option: he could try petitioning for the alphabetic spelling “One Zero Six Nine,” because that version at least consisted of words.2Freedom Forum. Can a Person’s Name Be Illegal? The How (and Why) Behind Banned Names
Why a Number Is Not a Name
The North Dakota Supreme Court rooted its ruling in the common law tradition that shapes American name-change law. Under that tradition, a name consists of a given name and a surname, and both must be words. The court could find no accepted definition of “word” that stretches to cover a string of digits.1Justia Case Law. Petition of Dengler
There was also a plain practical issue. How do you say 1069 out loud? “One thousand sixty-nine”? “Ten sixty-nine”? “One-oh-six-nine”? A name nobody can pronounce the same way twice fails at the one thing a name is supposed to do, which is identify a person in records, in court, and in daily speech. The court accepted that a person may informally use a number if they wish, but it refused to require the government to recognize that number as an official legal identity.1Justia Case Law. Petition of Dengler
What “Illegal” Really Means Here
Nothing in the Dengler decisions makes it a crime to call yourself 1069. You can introduce yourself that way, sign personal correspondence that way, and ask friends to use it. What the courts refused to do was order the state to put those four digits on a court order, a birth certificate, or a driver’s license. That is the sense in which 1069 is an illegal name. It is unrecognizable as a legal identity, not punishable as a label.
How Other States Handle Numerals in Names
Dengler lines up with how most of the country treats this question. The majority of states limit legal names to the 26 letters of the English alphabet. Numerals, pictograms, emojis, and most symbols are not accepted on a birth record or in a court-ordered name change. A small number of states, including Illinois and South Carolina, do allow numbers and symbols, but those are the outliers.
Some of these rules come from statutes, and some come from agency handbooks. California’s restriction, for example, sits in a Department of Public Health vital records handbook that tells clerks to use “the 26 alphabetical letters of the English language” on birth certificates. That rule drew attention in 2020 when Elon Musk and Grimes tried to name their son X Æ A-12 and had to drop the Arabic numerals before the state would record it.2Freedom Forum. Can a Person’s Name Be Illegal? The How (and Why) Behind Banned Names
Character counts and diacritical marks vary too. Some states cap each name field at 30 characters, others allow up to 141 characters total across first, middle, and last. Alaska, Hawaii, and North Carolina accept accents and tildes; Texas and California restrict names to standard English keyboard characters.
Can You Use 1069 Informally?
Many states still recognize the old common law rule that a person can change their name just by using a new one consistently in everyday life. No petition, no fee, no judge. In that sense, nothing stops someone from going by 1069 socially.
The limit is the paperwork. Common law use will not update your driver’s license, passport, or Social Security record. Those require a court order, and under Dengler, a court will not issue one for 1069. You also cannot adopt any new name, formal or informal, to defraud creditors or evade law enforcement.
That gap between what you can call yourself and what the government will record is exactly where the Dengler courts drew their line. Nearly fifty years later, the ruling still stands as the reason 1069 remains the most famous name in the country that no one can legally have.