In re Carol A. Boardman, 166 A.3d 106

Carol A. Boardman petitioned the Cumberland County Probate Court to change her surname to Currier; petition was unopposed and she satisfied statutory filing, notice, and fee requirements.
At the hearing Boardman stated Currier was not her maiden name but the last name of a close friend/partner and that she sought a "fresh start" after her husband's death.
The Probate Court denied the petition, reasoning that adopting her partner's surname would falsely suggest the two were married and could mislead creditors, lessors, or record holders — a deception constituting fraud under 18‑A M.R.S. § 1‑701(f).
Boardman appealed, arguing that potential public misunderstanding of her marital status does not amount to fraud sufficient to deny a name change under the statute.
The Supreme Judicial Court reviewed the statutory interpretation de novo and examined whether mere potential misunderstanding of marital status satisfies the statutory prohibition on name changes sought to "defraud another person or entity."
The Court concluded the record contained no evidence of intent to deceive or of actions to evade legal or financial obligations; therefore the Probate Court erred and the denial was vacated and remanded with instructions to grant the name change.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a name change that may cause others to mistakenly infer the petitioner is married qualifies as seeking the change "for purposes of defrauding another person or entity" under 18‑A M.R.S. § 1‑701(f)	Boardman: Potential misunderstanding of marital status alone is not fraud; there is no intent to deceive or evidence of actions to evade obligations	Probate Court: Adopting a partner's surname would create a false impression of marriage that could mislead creditors/lessors, amounting to fraud and justifying denial	The Court held mere potential public misunderstanding of marital status, without evidence of intent to deceive or resulting reliance causing detriment, does not satisfy the statute's fraud bar; grant the name change.

In re A.M.B., 997 A.2d 754 (Me. 2010) (name-change petitions should generally be granted absent fraudulent intent)
In re Reben, 342 A.2d 688 (Me. 1975) (denial of a name change for supposed misleading effect absent fraud is an abuse of discretion)
In re McIntyre, 715 A.2d 400 (Pa. 1998) (confusion created by a name change does not alone constitute the financial fraud the statute targets)
Rand v. Bath Iron Works Corp., 832 A.2d 771 (Me. 2003) (elements of fraudulent misrepresentation in civil context)
Picher v. Roman Catholic Bishop of Portland, 974 A.2d 286 (Me. 2009) (elements of fraudulent concealment)