John Doe

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This article is about a term for anonymous characters. For other uses, see John Doe (disambiguation).

The names "John Doe" for males, "Jane Doe" or "Jane Roe" for females, or "Jonnie 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 rarely used in other English-speaking countries including the United Kingdom itself, from where the use of "John Doe" in a legal context originates. The names Joe Bloggs or John Smith are used in the UK instead,[citation needed] as well as in Australia and New Zealand.[2]


John Doe is sometimes used to refer to a typical male in other contexts as well, in a similar manner to John Q. Public, known in Great Britain as Joe Public, John Smith or Joe Bloggs. For example, the first name listed on a form is often 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 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.[3] Other unidentified female murder victims are 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.[4]

The Doe names are often, though not always, used for anonymous or unknown defendants. Another set of names often used for anonymous parties, particularly plaintiffs, are Richard Roe for males and Jane Roe for females (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.[5]

The term is sometimes used in lawsuits in Ireland—see for example McKeogh v. John Doe.[6]

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


The name "John Doe", often spelled "Doo," along with "Richard Roe" or "Roo" 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 (1312–1377).[7]

Other fictitious names for a person involved in litigation under English law were John-a-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 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).[9]

The term 'John Doe Injunction' (or John Doe Order)[10] 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".[11]

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.[12]

Court cases[edit]

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."[17]
"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."[18]

Other variants[edit]

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),[19] 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),[20] 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.[21]

In Indian courts, a "John Doe" order may be dubbed an "Ashok Kumar" order.[22]

In the Philippines the common man, in legalese or journalism is referred to as "Juan de la Cruz". In a signal judgment in the UK, that argued the case for publication of D.H. Lawrences's novel "Lady Chatterly's Lover" the 'average person' was referred to as "the man on the Clapham omnibus". The French favour "Messieur Brun" and the Italians like Signor Rossi.

See also[edit]


  1. ^ "Twitched Indictment". Retrieved 2 October 2012. 
  2. ^ "Isro sees red over fake Mars mission pages". (Times of India). 17 December 2013. Retrieved 1 January 2014. 
  3. ^ Goldblatt, Jeff (8 August 2002). "Slain Mystery Girl Brings Community Together". FOX News Network. Retrieved 30 June 2006. 
  4. ^ Quinion M (15 March 2003). "John Doe". World Wide Words. Retrieved 26 November 2008. 
  5. ^ Alison Leigh Cowan (29 July 2009). "Meet John Doe. No, really!". The New York Times. Retrieved 5 August 2009. 
  6. ^ McKeogh v. John Doe
  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. ^ "Supreme Court Decided Cases (pdf)". Retrieved 2 October 2012. 
  10. ^ "Obtaining a John Doe order". PressGazette. Retrieved 2 October 2012. 
  11. ^ "THE LAW OF PROFESSIONAL-CLIENT CONFIDENTIALITY: Regulating the Disclosure of Confidential Personal Information, Update". Archived from the original on 7 July 2003. 
  12. ^ "Uncorrected Evidence 75". 18 February 2009. Retrieved 2 October 2012. 
  13. ^ "Who is JANE DOE?". Retrieved 2 October 2012. 
  14. ^ 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)".  (2008).
  15. ^ Nikhil Pahwa. "Update: Files Sharing Sites Blocked In India Because Reliance BIG Pictures Got A Court Order". MediaNama. Retrieved 2 October 2012. 
  16. ^ "'John Doe Order' for BODYGUARD to curb its piracy". 29 August 2011. 
  17. ^ Donald P. Balla. "John Doe Is Alive and Well: Designing Pseudonym Use in American Courts". Arkansas Law Review. Retrieved 4 January 2014. 
  19. ^ "Poe v. Snyder". 
  20. ^ "Friedman v. Ferguson". 
  21. ^ Note that the plaintiff-appellant Friedman represented himself, so his use of fictitious names may not reflect legal custom.
  22. ^ R Balaji (29 March 2012). "'Kolaveri' against piracy". The Hindu Business Line. 

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