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John Doe

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The names "John Doe" or "John Roe" for men, "Jane Doe" or "Jane Roe" for women, "Johnny Doe" and "Janie Doe" for children, or just "Doe" non-gender-specifically are used as placeholder names for a party whose true identity is unknown or must be withheld in a legal action, case, or discussion.[1] The names are also used to refer to a corpse or hospital patient whose identity is unknown. This practice is widely used in the United States and Canada, but is always used in other English-speaking countries including the United Kingdom, from which the use of "John Doe" in a legal context originates. The names "Joe Bloggs" or "John Smith" are used in the UK as placeholder names, (mainly to mean 'any old person', the classic 'Everyman')[citation needed] as well as in Australia and New Zealand.[citation needed]


John Doe is sometimes used to refer to a typical male in other contexts as well, in a similar manner to John Q. Public in the United States or Joe Public, John Smith or Joe Bloggs in Britain. For example: the first name listed on a form might be John Doe, along with a fictional address or other fictional information to provide an example of how to fill in the form. The name is also used frequently in US popular culture, for example in the Frank Capra film Meet John Doe. John Doe was also the name of a 2002 American television series.

Similarly, a child or baby whose identity is unknown may be referred to as Baby Doe. A notorious murder case in Kansas City, Missouri, referred to the baby victim as Precious Doe.[2] Other unidentified female murder victims have also been nicknamed by the public or investigators as "Cali Doe" and "Princess Doe". Additional persons may be called James Doe, Judy Doe, etc. However, to avoid possible confusion, if two anonymous or unknown parties are cited in a specific case or action, the surnames Doe and Roe may be used simultaneously; for example, "John Doe v. Jane Roe". If several anonymous parties are referenced, they may simply be labelled John Doe #1, John Doe #2, etc. (the U.S. Operation Delego cited 21 (numbered) "John Doe"s) or labelled with other variants of Doe / Roe / Poe / etc. Other early alternatives such as John Stiles and Richard Miles are now rarely used, and Mary Major has been used in some American federal cases.[3]

The Doe names are also used for anonymous or unknown defendants. Another set of names used for anonymous parties, particularly plaintiffs, are Richard Roe for men and Jane Roe for women (as in the landmark U.S. Supreme Court abortion decision Roe v. Wade).

Bearing the actual name John Doe can cause difficulty, such as being stopped by airport security or suspected of being an incognito celebrity.[4]

The term is sometimes used in lawsuits in Ireland and the United States; see, for example McKeogh v. John Doe[5] and Uber Technologies, Inc. v. Doe I.[6]

The term John Doe or Jane Doe is used in US police investigations when the identity of the victim(s) is unknown or incorrect.


The name "John Doe", often spelled "Richard Roe," along with "John Roe" or "Doo" were regularly invoked in English legal instruments to satisfy technical requirements governing standing and jurisdiction, beginning perhaps as early as the reign of England's King Edward III (1327–1377).[7]

Other fictitious names for a person involved in litigation under English law were John-Noakes, or John Noakes/Nokes and John-a-Stiles/John Stiles.[8]

The Oxford English Dictionary states that John Doe is "the name given to the fictitious lessee of the plaintiff, in the (now obsolete in the UK) mixed action of ejectment, the fictitious defendant being called Richard Roe".

This usage is mocked in the 1834 English song "John Doe and Richard Roe":

Two giants live in Britain's land,
John Doe and Richard Roe,
Who always travel hand in hand,
John Doe and Richard Roe.
Their fee-faw-fum's an ancient plan
To smell the purse of an Englishman,
And, 'ecod, they'll suck it all they can,
John Doe and Richard Roe ...[9]

This particular use became obsolete in the UK in 1852:

As is well known, the device of involving real people as notional lessees and ejectors was used to enable freeholders to sue the real ejectors. These were then replaced by the fictional characters John Doe and Richard Roe. Eventually the medieval remedies were (mostly) abolished by the Real Property Limitation Act of 1833; the fictional characters of John Doe and Richard Roe by the Common Law Procedure Act 1852; and the forms of action themselves by the Judicature Acts 1873–75."
Secretary of State for Environment, Food, and Rural Affairs (Respondent) v Meier and another(FC) (Appellant) and others and another (FC)(Appellant) and another (2009).[10]

The term 'John Doe Injunction' (or John Doe Order)[11] is used in the UK to describe an injunction sought against someone whose identity is not known at the time it is issued:

"8.02 If an unknown person has possession of the confidential personal information and is threatening to disclose it, a 'John Doe' injunction may be sought against that person. The first time this form of injunction was used since 1852 in the United Kingdom was in 2005 when lawyers acting for JK Rowling and her publishers obtained an interim order against an unidentified person who had offered to sell chapters of a stolen copy of an unpublished Harry Potter novel to the media".[12]

Unlike in the United States the name (John) Doe does not actually appear in the formal name of the case, for example: X & Y v Persons Unknown [2007] HRLR 4.[13]

Court cases

  • The landmark 1973 United States Supreme Court abortion cases Roe v. Wade and Doe v. Bolton get half of their names from anonymous plaintiffs Jane Roe and Mary Doe, women later revealed to be named Norma McCorvey and Sandra Cano.
  • A Toronto woman, publicly known only as Jane Doe, waged an 11-year court battle against the Toronto Police Service after being raped in 1986, alleging that the police had used her as bait to catch the Balcony Rapist. She won the case in 1998, and was named Chatelaine's Woman of the Year that year.[14] She published a book about her experience, The Story of Jane Doe: A Book about Rape, in 2003.
  • A Doe subpoena is an investigatory tool that a plaintiff may use to seek the identity of an unknown defendant. Doe subpoenas are often served on online service providers and ISPs to obtain the identity of the author of an anonymous post.[15]
  • Serial killer Richard Laurence Marquette confessed to the murder of an unknown woman identified only as Jane Doe.
  • File sharing websites were blocked in India on 21 July 2011 on some ISPs including Bharti Airtel, BSNL, and Reliance Communications, because Reliance BIG Pictures got a "John Doe" order from Delhi High Court allowing them to serve cease and desist notices on people illegally redistributing the film Singham.[16] This allegedly brought down copyright infringement of the film by 30%.
  • On 29 August 2011 Reliance Entertainment procured a 'John Doe' order from the Delhi High Court to prevent the illegal broadcast or streaming of its upcoming film Bodyguard. This order gives protection to the intellectual property owner, Reliance Entertainment, from copyright violation by prospective anonymous offenders.[17]

The use and selection of pseudonyms is not standardized in U.S. courts and the practice itself is opposed on legal grounds by some and was rare prior to 1969.

"...Currently there are no court rules about pseudonym use. The rules of civil procedure,...are silent on the matter..." "Rule of Civil Procedure 10(a) reads, '...In the complaint, the title of the action shall include the names of all the parties . . . .' The rule contains no guidance as to what parties should do to keep their names confidential."[18]
"Prior to... 1969, only one Supreme Court case, three court of appeals' decisions, and one district court decision in the previous quarter-century featured an anonymous individual as the sole or lead plaintiff. Between 1969 and January 22, 1973, the date when the Supreme Court decided Roe and Doe, there were twenty-one district court and two court of appeals decisions featuring anonymous plaintiffs."[19]
  • On March 10, 2015, HTG Capital Partners LLC filed a federal lawsuit against unnamed “spoofers,” which the suit referred to as John Doe(s), in the hopes of getting a judge to force the Chicago Mercantile Exchange to reveal the names of the firms. HTG said it had found evidence of thousands of such manipulations over 2013 and 2014. "[20]

Other variants

In addition to Doe and Roe, other "_oe" names have been used when more than two unknown or unidentified persons are named in U.S. court proceedings, e.g., Poe v. Snyder, 834 F.Supp.2d 721 (W. D. Mich. 2011),[21] whose full style is

Jane Poe, John Doe, Richard Roe, Robert Roe, Mark Moe, Larry Loe, Degage Ministries, and Mel Trotter Ministries, Plaintiffs, v. Rick Snyder, Governor of the State of Michigan, Bill Schuette, Attorney General of the State of Michigan, Kriste Etue, Director of the Michigan State Police, William Forsyth, Kent County Prosecutor, in their official capacities, Defendants;

and Friedman v. Ferguson, No. 87-3758, unpublished disposition, 850 F.2d 689 (4th Cir., 29 June 1988),[22] whose full style is

Wilbur H. Friedman, Plaintiff-Appellant, v. Thomas B. FERGUSON, Director, Department of Animal Control, a State Actor, In His Official and Individual Capacities; Brett Boe; Carla Coe; Donna Doe; Frank Foe; Grace Goe; Harry Hoe; State Actors, Advisors To Defendant Ferguson, In Their Official and Individual Capacities (identities currently unknown); Marta Moe; Norma Noe; Paula Poe; Ralph Roe; Sammy Soe; Tommy Toe; Private Individuals Who Conspired With the Foregoing State Actors (identities currently unknown); Roger W. Galvin, Chairman, Animal Matters Hearing Board; Vince Voe; William Woe; Xerxes Xoe; Members of the Animal Matters Hearing Board, State Actors, In Their Official and Individual Capacities (identities currently unknown), Defendants-Appellees.[23]

In a lawsuit in the UK about the publication of D.H. Lawrence's novel "Lady Chatterley's Lover" the 'average person' was referred to as "the man on the Clapham omnibus". Parallels in other cultures are in France "Monsieur Brun", in Italy "Signor Rossi", in India "Ashok Kumar".[24]

See also


  1. ^ "Twitched Indictment" (PDF). Retrieved 2 October 2012. 
  2. ^ Goldblatt, Jeff (8 August 2002). "Slain Mystery Girl Brings Community Together". FOX News Network. Retrieved 30 June 2006. 
  3. ^ Quinion M (15 March 2003). "John Doe". World Wide Words. Retrieved 26 November 2008. 
  4. ^ Alison Leigh Cowan (29 July 2009). "Meet John Doe. No, really!". The New York Times. Retrieved 5 August 2009. 
  5. ^ McKeogh v. John Doe
  6. ^ "Uber Technologies, Inc. v. Doe I". Justia Dockets & Filings. 
  7. ^ What's In A Name. Merriam-Webster. 1996. ISBN 978-0-87779-613-8. [page needed]
  8. ^ "World Wide Words – John DoeZ". Retrieved 2 October 2012. 
  9. ^ The Universal Songster: Or, Museum of Mirth: Forming the Most Complete, Extensive, and Valuable Collection of Ancient and Modern Songs in the English Language, with a Copious and Classified Index, Volume 1. London: Jones and Company. 1827. p. 378. Retrieved 18 September 2015. 
  10. ^ "Supreme Court Decided Cases (pdf)" (PDF). Retrieved 2 October 2012. 
  11. ^ "Obtaining a John Doe order". PressGazette. Retrieved 2 October 2012. 
  12. ^ "THE LAW OF PROFESSIONAL-CLIENT CONFIDENTIALITY: Regulating the Disclosure of Confidential Personal Information, Update". Archived from the original on 7 July 2003. 
  13. ^ "Uncorrected Evidence 75". 18 February 2009. Retrieved 2 October 2012. 
  14. ^ "Who is JANE DOE?". Retrieved 2 October 2012. 
  15. ^ See, for example, Dendrite International, Inc. v. Doe, "775 A.2d 756".  (N.J. App. Div. 2001); Krinsky v. Doe 6, "159 Cal. App. 4th 1154 (pdf)" (PDF). [permanent dead link] (2008).
  16. ^ Nikhil Pahwa. "Update: Files Sharing Sites Blocked In India Because Reliance BIG Pictures Got A Court Order". MediaNama. Retrieved 2 October 2012. 
  17. ^ "'John Doe Order' for BODYGUARD to curb its piracy". 29 August 2011. 
  18. ^ Donald P. Balla. "John Doe Is Alive and Well: Designing Pseudonym Use in American Courts" (PDF). Arkansas Law Review. Retrieved 4 January 2014. 
  20. ^ Bradely Hope. "Was 'John Doe' Manipulating Treasury Futures? New Lawsuit Says Yes.". 
  21. ^ "Poe v. Snyder". 
  22. ^ "Friedman v. Ferguson". 
  23. ^ Note that the plaintiff-appellant Friedman represented himself, so his use of fictitious names may not reflect legal custom.
  24. ^ R Balaji (29 March 2012). "'Kolaveri' against piracy". The Hindu Business Line. 

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