In United States v. Green, (WD VA, May 4, 2026), defendant was charged with failing to update his sex offender registration. In a pretrial motion, defendant asked that he be referred to by his Hebrew Israelite religious name--Dalayah Yashar’Al-- during his upcoming trial. Defendant contended that the failure to do so would violate his 1st Amendment free exercise rights as well as his rights under RFRA. The court said in part:
Defendant may refer to himself as Mr. Yashar’Al throughout the upcoming trial. But the court and the government need not do so. Even assuming Defendant has legally changed his name under Michigan common law, the name “Deon Green” may appear in records necessary to prove the government’s case. A categorical prohibition on the court or the government from using the name “Deon Andre Green” risks confusing and misleading the jury....
... Defendant offers no argument that the court and the government’s use of his birth name in court will pressure him to modify his beliefs or to choose between his beliefs and a government benefit....
... Moreover, the government’s inclusion of Defendant’s preferred name in the indictment is an adequate religious accommodation....
... [T]o avoid confusion, the court will instruct the jury that Defendant—born Deon Green—has adopted the name Dalayah Yashar’Al, and that the two names refer to the same person....