John Doe

"John Doe" (for males) and "Jane Doe" (for females) are multiple-
use names that are used when the true name of a person is unknown
or is being intentionally concealed.[1][2][3] In the context of law
enforcement in the United States, such names are often used to refer
to a corpse whose identity is unknown or unconfirmed. Secondly,
such names are also often used to refer to a hypothetical "everyman"
in other contexts, in a manner similar to "John Q. Public" or "Joe
Public". There are many variants to the above names, including
"John Roe", "Richard Roe", "Jane Roe" and "Baby Doe", "Janie
Doe" or "Johnny Doe" (for children). Four headstones marking the single
grave of four unknown people in the
Pima County Cemetery, Tucson,
Arizona, United States. They are
Contents called "John Doe" or "Jane Doe"
followed by a number sign (#) and a
Use in criminal investigation
number. In the same cemetery, the
History murdered Deanna Criswell was
Other variants called "Jane Doe 19" for 27 years
until she was genetically identified in
Famous court cases 2015 by her relatives with help from
See also the FBI and The Doe Network.

References
External links

Use in criminal investigation

In other English-speaking countries, unique placeholder names, numbers or codenames have become more
often used in the context of police investigations. This has included the United Kingdom, where usage of
"John Doe" originated during the Middle Ages. However, the legal term John Doe injunction or John Doe
order[4] has survived in English law and other legal systems influenced by it. Other names such as "Joe
Bloggs" or "John Smith" have sometimes been informally used as placeholders for an everyman in the UK,
Australia and New Zealand; such names are seldom used in legal or police circles in the same sense as John
Doe.

Well-known legal cases named after placeholders include:

the landmark 1973 US Supreme Court decisions regarding abortion: Roe v. Wade and Doe v.
Bolton (1973) and;
the civil cases Doe dem. John Hurrell Luscombe v Yates, Hawker, and Mudge (1822) 5 B. &
Ald. 544 (England),[5] McKeogh v. John Doe (Ireland; 2012)[3] and Uber Technologies, Inc. v.
Doe I (California, 2015).[6]

Use of "John Doe" in the sense of an everyman, includes:

 the 1941 film Meet John Doe.

Use of "Jane Doe" in the sense of an unidentified corpse, includes:

the 2016 film The Autopsy of Jane Doe.

History
Under the legal terminology of Ancient Rome, the names "Numerius Negidius" and "Aulus Agerius" were
used in relation to hypothetical defendants and plaintiffs.

The name "John Doe" (or "John Doo"), "Richard Roe", along with "John Roe", 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] Though the rationale behind the
choices of Doe and Roe is unknown, there are many suggested folk etymologies.[8] Other fictitious names
for a person involved in litigation in medieval English law were "John Noakes" (or "Nokes") and "John-a-
Stiles" (or "John Stiles").[9] 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".[8]

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 ...[10]

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 v Meier and others (2009).[11]

In the UK, usage of "John Doe" survives mainly in the form of John Doe injunction or John Doe order (see
above).

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 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]

Well-known cases of unidentified corpses include "Cali Doe" (1979) and "Princess Doe" (1982). The baby
victim in a 2001 murder case in Kansas City, Missouri, was referred to as Precious Doe.[14]

In 2009, the New York Times reported the difficulties and unwanted attention experienced by a man actually
named John Doe, who had often been suspected of using a pseudonym. He had been questioned repeatedly
by airport security staff. Another man named John Doe was often suspected of being an incognito
celebrity.[15]

Other variants
In cases where a large number of unidentified individuals are mentioned, numbers may be appended, such as
"Doe #2" or "Doe II". Operation Delego (2009), which targeted an international child sexual abuse ring,
cited 21 numbered "John Does", as well as other people known by the surnames "Doe", "Roe", and "Poe".

"John Stiles", "Richard Miles" have been used for the third and fourth participants in an action. "Mary
Major" has been used in some federal cases in the US.[16] "James Doe" and "Judy Doe" are among other
common variants.

Less often, other surnames ending in -oe 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),[17]
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),[18] 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.[19]

In Massachusetts, "Mary Moe" is used to refer to pregnant women under the age of 18 petitioning the
Superior Court for a judicial bypass exception to the parental consent requirement for abortion.[20] "Mary
Moe" is also used to refer to such cases generally, i.e. "Mary Moe cases". Sometimes "Mary Doe" may be
used for the individuals.
Parallels in other countries include:

"Ashok Kumar" has been used in court cases in India;[21]

the abbreviation N.N., which is commonly used in European legal systems, as an abbreviation
for Latin terms such as:
nomen nescio ("I do not know the name") in Belgium, Germany, Italy and Serbia and;
nomen nominandum ("the name must be mentioned") in the Netherlands.

Since 1903 a hypothetical "ordinary and reasonable person" has often been known, in the legal parlance of
the UK and other Commonwealth countries as "the man on the Clapham omnibus".[22][23]

Famous court cases

The landmark 1973 abortion cases Roe v. Wade and Doe v. Bolton get their names from
anonymous plaintiffs later revealed to be, respectively, 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.[24] 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.[25]
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.[26] 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.[27]

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 ...bare
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.[28]

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.[29]
 On January 18, 2015, a woman was sexually assaulted on the campus of Stanford University
in California. The victim impact statement that the woman, referred to as Emily Doe in court
documents, read at her assailant's sentencing hearing the following year went viral, and she
was named a "woman of a year" by Glamour magazine.[30] She publicly revealed her real
name, Chanel Miller, in 2019.[31]

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.[32]
In November 2016, a woman only identified as "Jane Doe" abandoned plans to go public about
allegedly being raped by Donald Trump.[33]
In October 2017, an unidentified minor Jane Doe detained by U.S. Immigration and Customs
Enforcement sued to enjoin the government from obstructing her access to abortion in Garza
v. Hargan.

See also
Israel Israeli
Average Joe
Rudolf Lingens
Joe Shmoe
Joe Bloggs
Tom, Dick and Harry
Mr. X
Blackacre
Multiple-use name
Nomen nescio
Foo
List of placeholder names by language

The Autopsy of Jane Doe

References
1. "Twitched Indictment" (https://www.justice.gov/opa/documents/ceos-delego-indictment-twitche
d.pdf) (PDF). Justice.gov. Retrieved 2 October 2012.
2. "The People of the State of California v. John Doe" (https://www.courts.ca.gov/documents/BTB
_23_5L_9.pdf) (PDF). Judicial Council of California. Retrieved 8 February 2019.
3. Ireland, Courts Service of. "McKeogh -v- John Doe 1 & ors : Judgments & Determinations :
Courts Service of Ireland" (http://www.courts.ie/Judgments.nsf/09859e7a3f34669680256ef300
4a27de/219f33309598cd3980257a00003d3c0e?OpenDocument). www.courts.ie. Retrieved
4 December 2018.
4. "Obtaining a John Doe order" (https://web.archive.org/web/20120911032452/http://www.press
gazette.co.uk/story.asp?storyCode=30920&sectioncode=1). PressGazette. Archived from the
original (http://www.pressgazette.co.uk/story.asp?storyCode=30920&sectioncode=1) on 11
September 2012. Retrieved 2 October 2012.
 5. "Deed Poll Office (D·P·O)" (https://deedpolloffice.com/change-name/law/case-law/Doe-dem-Lu
scombe-v-Yates-1822). Deed Poll Office. Retrieved 4 December 2018.
6. "Uber Technologies, Inc. v. Doe I" (http://dockets.justia.com/docket/california/candce/3:2015cv
00908/285209). Justia Dockets & Filings.
7. What's In A Name (https://archive.org/details/whatsinnamerefle00dick). Merriam-Webster.
1996. ISBN 978-0-87779-613-8.
8. "Why Are Unidentified People Called John or Jane Doe?" (http://mentalfloss.com/article/29996/
why-are-unidentified-people-called-john-or-jane-doe). mentalfloss.com. 15 February 2012.
Retrieved 4 December 2018.
9. "World Wide Words – John DoeZ" (http://www.worldwidewords.org/qa/qa-joh2.htm).
Worldwidewords.org. Retrieved 2 October 2012.
10. 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 (https://books.google.com/?id=VWQLAAAAYAA). London:
Jones and Company. 1827. p. 378. Retrieved 18 September 2015.
11. "Supreme Court Decided Cases (pdf)" (https://web.archive.org/web/20140408214749/http://ww
w.supremecourt.uk/decided-cases/docs/UKSC_2009_0087_Judgment.pdf) (PDF).
Supremecourt.gov.uk. Archived from the original (http://www.supremecourt.uk/decided-cases/d
ocs/UKSC_2009_0087_Judgment.pdf) (PDF) on 8 April 2014. Retrieved 2 October 2012.
12. "The Law of Professional-Client Confidentiality: Regulating the Disclosure of Confidential
Personal Information, Update" (https://web.archive.org/web/20030707131130/http://www.uea.a
c.uk/law/resources/8-02.htm). Uea.ac.uk. Archived from the original (http://www.uea.ac.uk/law)
on 7 July 2003.
13. "Uncorrected Evidence 75" (https://publications.parliament.uk/pa/cm200809/cmselect/cmcume
ds/memo/press/uc7502.htm). Publications.parliament.uk. 18 February 2009. Retrieved
2 October 2012.
14. Goldblatt, Jeff (8 August 2002). "Slain Mystery Girl Brings Community Together" (https://web.ar
chive.org/web/20080408162535/http://www.foxnews.com/story/0,2933,59905,00.html). FOX
News Network. Archived from the original (http://www.foxnews.com/story/0,2933,59905,00.htm
l) on 8 April 2008. Retrieved 30 June 2006.
15. Alison Leigh Cowan (29 July 2009). "Meet John Doe. No, really!" (http://cityroom.blogs.nytime
s.com/2009/07/29/a-name-only-a-lawyer-could-love/). The New York Times. Retrieved
5 August 2009.
16. Quinion M (15 March 2003). "John Doe" (http://www.worldwidewords.org/qa/qa-joh2.htm).
World Wide Words. Retrieved 26 November 2008.
17. "Poe v. Snyder" (http://www.leagle.com/decision/In%20FDCO%2020111228719).
www.leagle.com.
18. "Friedman v. Ferguson" (http://law.justia.com/cases/federal/appellate-
courts/F2/850/689/3734/). Law.justia.com.
19. Note that the plaintiff-appellant Friedman represented himself, so his use of fictitious names
may not reflect legal custom.
20. "Superior Court Standing Order 5-81: Uniform Procedures Regarding Petitions for Abortion
Authorization under G.L. c. 112, § 12" (http://www.mass.gov/courts/case-legal-res/rules-of-cour
t/superior/sup-orders/sup5-81.html). Massachusetts Superior Court. 1 October 1988. Retrieved
18 December 2017.
21. R Balaji (29 March 2012). " 'Kolaveri' against piracy" (http://www.thehindubusinessline.com/ind
ustry-and-economy/article3258958.ece). The Hindu Business Line.
22. McQuire v Western Morning News [1903] 2 K.B. 100 at 109 per Collins MR.
23. Room, Richard, ed. (1996), Brewer's Dictionary of Phrase and Fable (https://archive.org/detail
s/brewersdictionar00room_0/page/761) (15th ed.), Cassell, p. 761 (https://archive.org/details/b
rewersdictionar00room_0/page/761), ISBN 978-0062701336
24. "Who is JANE DOE?" (http://www.walnet.org/jane_doe/news/toronto_99/chatelaine-9901.html).
Walnet.org. Retrieved 2 October 2012.
25. See, for example, Dendrite International, Inc. v. Doe, "775 A.2d 756" (http://pub.bna.com/eclr/2
77400t3.htm). (N.J. App. Div. 2001); Krinsky v. Doe 6, "159 Cal. App. 4th 1154 (pdf)" (https://w
eb.archive.org/web/20090325151157/http://www.courtinfo.ca.gov/opinions/archive/H030767.P
DF) (PDF). 14 January 2019. Archived from the original (http://www.courtinfo.ca.gov/opinions/a
rchive/H030767.PDF) (PDF) on 25 March 2009. (2008).
26. Nikhil Pahwa (21 July 2011). "Update: Files Sharing Sites Blocked In India Because Reliance
BIG Pictures Got A Court Order" (http://www.medianama.com/2011/07/223-files-sharing-sites-
blocked-in-india-because-reliance-big-pictures-got-a-court-order/). MediaNama. Retrieved
2 October 2012.
27. " 'John Doe Order' for BODYGUARD to curb its piracy" (http://www.bollywoodtrade.com/trade-
news/john-doe-order-for-bodyguard-to-curb-its-piracy/ddaefdca-3999-4fc7-a38d-fafb32c81b9
0/). Bollywoodtrade.com. 29 August 2011.
28. Donald P. Balla. "John Doe Is Alive and Well: Designing Pseudonym Use in American Courts"
(https://web.archive.org/web/20120721122745/http://lawreview.law.uark.edu/wp-content/uploa
ds/2011/02/ballaforweb.pdf) (PDF). Arkansas Law Review. Archived from the original (http://la
wreview.law.uark.edu/wp-content/uploads/2011/02/ballaforweb.pdf) (PDF) on 21 July 2012.
Retrieved 4 January 2014.
29. Milani, Adam A. "Doe v. roe: An argument for defendant anonymity when a pseudonymous
plaintiff alleges a stigmatizing intentional tort" (https://litigation-essentials.lexisnexis.com/webc
d/app?action=DocumentDisplay&crawlid=1&srctype=smi&srcid=3B15&doctype=cite&docid=41
+Wayne+L.+Rev.+1659&key=d76535e5079120df8de61ccdfa1ed478). Lexisnexis.com.
Retrieved 18 February 2012.
30. "Glamour Women of the Year: Stanford Sexual Assault Case Survivor Emily Doe Speaks Out"
(http://www.glamour.com/story/women-of-the-year-emily-doe). glamour.com. Glamour
Magazine. Retrieved 3 November 2016.
31. de León, Concepción (4 September 2019). "You Know Emily Doe's Story. Now Learn Her
Name" (https://www.nytimes.com/2019/09/04/books/chanel-miller-brock-turner-assault-stanfor
d.html). The New York Times. Retrieved 6 September 2019.
32. Bradely Hope (12 March 2015). "Was 'John Doe' Manipulating Treasury Futures? New Lawsuit
Says Yes" (http://on.wsj.com/1HKj7CK).
33. Carroll, Rory (3 November 2016). "Woman accusing Trump of raping her at 13 cancels her
plan to go public" (https://www.theguardian.com/us-news/2016/nov/02/donald-trump-rape-laws
uit-13-year-old-cancels-public-event). The Guardian. Retrieved 16 October 2017.

External links
PDF Operation Delego indictment featuring twenty John Does. Accessed 8 January 2014.

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