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Keywords

defendantstatuteappealcivil rights
defendantstatuteappeal

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Henne v. Wright, 904 F.2d 1208, 58 USLW 2715, 16 Fed.R.Serv.3d 908

Facts

Debra Henne gave birth to Alicia Renee Henne and wanted to name her daughter after the biological father, Gary Brinton. However, due to her marital status at the time of birth, hospital personnel informed her that she could not use the surname 'Brinton' and had to use 'Henne.' Similarly, Linda Spidell wished to name her daughter Quintessa Martha Spidell 'McKenzie,' the same surname as her other children, but was also denied this choice due to the statute. Both mothers subsequently filed a civil rights action against the state officials enforcing the statute.

Debra Henne gave birth to Alicia Renee Henne and wanted to name her daughter after the biological father, Gary Brinton. However, due to her marital status at the time of birth, hospital personnel informed her that she could not use the surname 'Brinton' and had to use 'Henne.' Similarly, Linda Spidell wished to name her daughter Quintessa Martha Spidell 'McKenzie,' the same surname as her other children, but was also denied this choice due to the statute.

Issue

Whether the Nebraska statute restricting the choice of surnames for children at birth unconstitutionally infringes on the mothers' rights under the Fourteenth Amendment.

Whether the Nebraska statute restricting the choice of surnames for children at birth unconstitutionally infringes on the mothers' rights under the Fourteenth Amendment.

Rule

The court determined that the Fourteenth Amendment right of privacy does not protect the specific right to give a child a surname with which the child has no legally established parental connection, and that the statute must only rationally further legitimate state interests to withstand constitutional scrutiny.

The court determined that the Fourteenth Amendment right of privacy does not protect the specific right to give a child a surname with which the child has no legally established parental connection.

Analysis

The court analyzed the statute under the rational basis test, concluding that it served legitimate state interests such as promoting the welfare of children, preventing the improper appropriation of names, and ensuring efficient record-keeping. The court found that the statute did not significantly infringe on a fundamental right, as the right to name a child was not deeply rooted in American tradition.

The court analyzed the statute under the rational basis test, concluding that it served legitimate state interests such as promoting the welfare of children, preventing the improper appropriation of names, and ensuring efficient record-keeping.

Conclusion

The Court of Appeals reversed the district court's judgment, holding that the Nebraska statute did not unconstitutionally restrict the mothers' rights to name their children.

The Court of Appeals reversed the district court's judgment, holding that the Nebraska statute did not unconstitutionally restrict the mothers' rights to name their children.

Who won?

Defendants (Nebraska Department of Health officials) prevailed because the court found that the statute did not infringe on a fundamental right and was rationally related to legitimate state interests.

Defendants (Nebraska Department of Health officials) prevailed because the court found that the statute did not infringe on a fundamental right and was rationally related to legitimate state interests.

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