It’s incredible, but 11 years later, and even judges irrationally invoke September 11 as a means to enact their own agendas. A New Jersey parent requested, under New Jersey state law, to change the name of his daughter from “Honghong Zhan” to “Michelle Zhan.” According to the New Jersey appellate court, the judge denied the request, “without citing any specific statutory provision or case law” because “the federal ‘Immigration and Naturalization Control Act’ pre-empted state law on the issue of name changes, and stated his view that for security reasons, ‘the Country needs to identify who [is] here under the names that they have.'” However, as the appellate court noted in its reversal of the lower court, the name change process creates a paper trail of the name change.

Utah has a similar law to the New Jersey rule. Utah Code §42-1-1 through §42-1-3 and §77-27-21.5(20) governs name changes for Utah residents, and there is no requirement that the petitioner be a citizen of the United States. Unless the name change is requested for an illegitimate reasons—such as to avoid debts or commit fraud—residents of Utah are free to change their names. As Eugene Volokh noted, name changes can help immigrants Americanize, if that’s what they desire.