John Doe (male) and Jane Doe (female) are multiple-useplaceholder names that are used when the true name of a person is unknown or is being intentionally concealed. In the context of
law enforcement in the United States
Law enforcement in the United States is one of three major components of the criminal justice system of the United States, along with courts and corrections. Although each component operates semi-independently, the three collectively form a c ...
everyman
The everyman is a stock character of fiction. An ordinary and humble character, the everyman is generally a protagonist whose benign conduct fosters the audience's identification with them.
Origin
The term ''everyman'' was used as early as ...
" 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, Baby Doe, and Janie Doe/Johnny Doe (for children).
In criminal investigation
In other
English-speaking countries
The following is a list of English-speaking population by country, including information on both native speakers and second-language speakers.
List
* The European Union is a supranational union composed of 27 member states. The total En ...
, unique placeholder names, numbers or
codename
A code name, call sign or cryptonym is a code word or name used, sometimes clandestinely, to refer to another name, word, project, or person. Code names are often used for military purposes, or in espionage. They may also be used in industrial c ...
s have become more often used in the context of police investigations. This has included the
United Kingdom
The United Kingdom of Great Britain and Northern Ireland, commonly known as the United Kingdom (UK) or Britain, is a country in Europe, off the north-western coast of the European mainland, continental mainland. It comprises England, Scotlan ...
, where usage of "John Doe" originated during the
Middle Ages
In the history of Europe, the Middle Ages or medieval period lasted approximately from the late 5th to the late 15th centuries, similar to the post-classical period of global history. It began with the fall of the Western Roman Empire ...
. However, the legal term ''John Doe injunction'' or ''John Doe order'' has survived in English law and other legal systems influenced by it. Other names, such as "
Joe Bloggs
"Joe Bloggs" and "Fred Bloggs" are placeholder names used primarily in the United Kingdom to represent the average man on the street. It is used by students, on standardized test preparation courses, to represent the average test-taker. Many coun ...
" or "John Smith", have sometimes been informally used as placeholders for an everyman in the UK, Australia and New Zealand; however 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 (but are not limited to):
* the landmark 1973
US Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point of ...
decisions regarding abortion: ''
Roe v. Wade
''Roe v. Wade'', 410 U.S. 113 (1973),. was a landmark decision of the U.S. Supreme Court in which the Court ruled that the Constitution of the United States conferred the right to have an abortion. The decision struck down many federal and s ...
'' ("Roe" being a pseudonym) 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), ''McKeogh v. John Doe'' (Ireland; 2012) and ''Uber Technologies, Inc. v. Doe I'' (California, 2015).
Use of "John Doe" in the sense of an everyman, includes:
* the 1941 film ''
Meet John Doe
''Meet John Doe'' is a 1941 American comedy-drama film directed and produced by Frank Capra, written by Robert Riskin, and starring Gary Cooper and Barbara Stanwyck. The film is about a "grassroots" political campaign created unwittingly by ...
''.
Use of "John Doe" in the sense of an unidentified man (anonymous), includes:
* the 1995 film '' Seven''.
Use of "Jane Doe" in the sense of an unidentified corpse, includes:
* the 2016 film ''
The Autopsy of Jane Doe
''The Autopsy of Jane Doe'' is a 2016 supernatural horror film directed by André Øvredal. It stars Emile Hirsch and Brian Cox as father-and-son coroners who experience supernatural phenomena while examining the body of an unidentified woman ( ...
''.
Use of "John Doe" in the sense of a placeholder, includes:
* The
Valve
A valve is a device or natural object that regulates, directs or controls the flow of a fluid (gases, liquids, fluidized solids, or slurries) by opening, closing, or partially obstructing various passageways. Valves are technically fitting ...
Steam Deck
The Steam Deck is a handheld gaming computer developed by Valve Corporation. Released on February 25, 2022, the Steam Deck can be played as a handheld or connected to a monitor in the same manner as the Nintendo Switch. It is an x86-64-v3 de ...
desktop mode default email. (Or any
KDE Plasma 5
KDE Plasma 5 is the fifth and current generation of the graphical workspaces environment created by KDE primarily for Linux systems. KDE Plasma 5 is the successor of KDE Plasma 4 and was first released on 15 July 2014.
It includes a new default ...
based
linux
Linux ( or ) is a family of open-source Unix-like operating systems based on the Linux kernel, an operating system kernel first released on September 17, 1991, by Linus Torvalds. Linux is typically packaged as a Linux distribution, w ...
plaintiff
A plaintiff ( Π in legal shorthand) is the party who initiates a lawsuit (also known as an ''action'') before a court. By doing so, the plaintiff seeks a legal remedy. If this search is successful, the court will issue judgment in favor of t ...
s.
The names "John Doe" (or "John Do") and "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). Though the rationale behind the choices of Doe and Roe is unknown, there are many suggested
folk etymologies
Folk etymology (also known as popular etymology, analogical reformation, reanalysis, morphological reanalysis or etymological reinterpretation) is a change in a word or phrase resulting from the replacement of an unfamiliar form by a more famili ...
. 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"). The ''
Oxford English Dictionary
The ''Oxford English Dictionary'' (''OED'') is the first and foundational historical dictionary of the English language, published by Oxford University Press (OUP). It traces the historical development of the English language, providing a co ...
'' 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
Ejectment is a common law term for civil action to recover the possession of or title to land. It replaced the old real actions and the various possessory assizes (denoting county-based pleas to local sittings of the courts) where boundary disp ...
, the fictitious defendant being called Richard Roe".
This usage is mocked in the 1834 English song "John Doe and Richard Roe":
This particular use became obsolete in the UK in 1852:
In the UK, usage of "John Doe" survives mainly in the form of John Doe injunction or John Doe order (see above).
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'' 007HRLR 4.
Well-known cases of unidentified decedents include " Caledonia Jane Doe" (1979) and "
Princess Doe
Dawn Olanick (August 5, 1964 – July 1982), previously known as Princess Doe, was a previously unidentified American teenage decedent from Bohemia, New York who was found murdered in Cedar Ridge Cemetery in Blairstown Township, New Jersey ...
" (1982), both of whom have been identified. The baby victim in a 2001 murder case in Kansas City, Missouri, was referred to as Precious Doe.
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
A pseudonym (; ) or alias () is a fictitious name that a person or group assumes for a particular purpose, which differs from their original or true name (orthonym). This also differs from a new name that entirely or legally replaces an individua ...
. He had been questioned repeatedly by airport security staff. Another man named John Doe was often suspected of being an incognito celebrity.
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. "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), 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), 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''.
In
, "Mary Moe" is used to refer to pregnant women under the age of 18 petitioning the Superior Court for a
judicial bypass
Many jurisdictions have laws applying to minors and abortion. These parental involvement laws require that one or more parents consent or be informed before their minor daughter may legally have an abortion.
Minors and abortion in law Australia ...
exception to the parental consent requirement for abortion.
"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
India, officially the Republic of India (Hindi: ), is a country in South Asia. It is the seventh-largest country by area, the second-most populous country, and the most populous democracy in the world. Bounded by the Indian Ocean on the so ...
;
* the abbreviation ''N.N.'', which is commonly used in European legal systems, as an abbreviation for Latin terms such as:
** ''
nomen nescio
''Nomen nescio'' (), abbreviated to ''N.N.'', is used to signify an anonymous or unnamed person. From Latin ''nomen'' – "name", and ''nescio'' – "I do not know", it literally means "I do not know the name". The generic name Numerius Negidius ...
'' ("I do not know the name") in
Belgium
Belgium, ; french: Belgique ; german: Belgien officially the Kingdom of Belgium, is a country in Northwestern Europe. The country is bordered by the Netherlands to the north, Germany to the east, Luxembourg to the southeast, France to th ...
,
Germany
Germany,, officially the Federal Republic of Germany, is a country in Central Europe. It is the second most populous country in Europe after Russia, and the most populous member state of the European Union. Germany is situated betwe ...
,
Italy
Italy ( it, Italia ), officially the Italian Republic, ) or the Republic of Italy, is a country in Southern Europe. It is located in the middle of the Mediterranean Sea, and its territory largely coincides with the homonymous geographical ...
and
Serbia
Serbia (, ; Serbian: , , ), officially the Republic of Serbia (Serbian: , , ), is a landlocked country in Southeastern and Central Europe, situated at the crossroads of the Pannonian Basin and the Balkans. It shares land borders with Hungar ...
and;
** ''nomen nominandum'' ("the name must be mentioned") in the
Netherlands
)
, anthem = ( en, "William of Nassau")
, image_map =
, map_caption =
, subdivision_type = Sovereign state
, subdivision_name = Kingdom of the Netherlands
, established_title = Before independence
, established_date = Spanish Netherl ...
.
** ''
Ploni
This is a list of placeholder names (words that can refer to things, persons, places, numbers and other concepts whose names are temporarily forgotten, irrelevant, or unknown in the context in which they are being discussed) in various languages. ...
'', ''Almoni'', or ''Ploni Almoni'' are used in Israel, the names originating in the
abortion
Abortion is the termination of a pregnancy by removal or expulsion of an embryo or fetus. An abortion that occurs without intervention is known as a miscarriage or "spontaneous abortion"; these occur in approximately 30% to 40% of pre ...
cases ''
Roe v. Wade
''Roe v. Wade'', 410 U.S. 113 (1973),. was a landmark decision of the U.S. Supreme Court in which the Court ruled that the Constitution of the United States conferred the right to have an abortion. The decision struck down many federal and s ...
'' and '' Doe v. Bolton'' get their names from anonymous plaintiffs later revealed to be, respectively,
Norma McCorvey
Norma Leah Nelson McCorvey (September 22, 1947 – February 18, 2017), also known by the pseudonym "Jane Roe", was the plaintiff in the landmark American legal case ''Roe v. Wade'' in which the U.S. Supreme Court ruled in 1973 that individual ...
and Sandra Cano.
* A
Toronto
Toronto ( ; or ) is the capital city of the Canadian province of Ontario. With a recorded population of 2,794,356 in 2021, it is the most populous city in Canada and the fourth most populous city in North America. The city is the anch ...
woman, publicly known only as Jane Doe, waged an 11-year court battle against the
Toronto Police Service
The Toronto Police Service (TPS) is a municipal police force in Toronto, Ontario, Canada, and the primary agency responsible for providing law enforcement and policing services in Toronto. Established in 1834, it was the first local police ser ...
after being
rape
Rape is a type of sexual assault usually involving sexual intercourse or other forms of sexual penetration carried out against a person without their consent. The act may be carried out by physical force, coercion, abuse of authority, or ...
d 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'' Woman of the Year that year. 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 provider
An online service provider (OSP) can, for example, be an Internet service provider, an email provider, a news provider (press), an entertainment provider (music, movies), a search engine, an e-commerce site, an online banking site, a health site, ...
s and
ISP
An Internet service provider (ISP) is an organization that provides services for accessing, using, or participating in the Internet. ISPs can be organized in various forms, such as commercial, community-owned, non-profit, or otherwise private ...
s to obtain the identity of the author of an
anonymous post
An anonymous post, is an entry on a textboard, anonymous bulletin board system, or other discussion forums like Internet forum, without a screen name or more commonly by using a non-identifiable pseudonym.
Some online forums such as Slashdot do n ...
.
*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
India, officially the Republic of India (Hindi: ), is a country in South Asia. It is the seventh-largest country by area, the second-most populous country, and the most populous democracy in the world. Bounded by the Indian Ocean on the so ...
on 21 July 2011 on some ISPs including
Bharti Airtel
Bharti Airtel Limited, commonly known as (d/b/a) Airtel, is an Indian multinational telecommunications services company based in New Delhi. It operates in 18 countries across South Asia and Africa, as well as the Channel Islands. Currently, ...
Reliance Communications
Reliance Communications Limited (RCOM) was an Indian mobile network provider headquartered in Navi Mumbai that offered voice and 2G and 3G and 4G data services.
In February 2019, the company filed for bankruptcy as it was unable to sell asse ...
, because
Reliance BIG Pictures
Reliance Entertainment Pvt Ltd is an Indian media and entertainment company. It is a division of Reliance Group, handling its media and entertainment business, across content and distribution platforms. The company was founded on 15 February 20 ...
got a "John Doe" order from Delhi High Court allowing them to serve cease and desist notices on people illegally redistributing the film ''
Singham
''Singham'' is a 2011 Indian Hindi-language action film directed by Rohit Shetty and produced by Reliance Entertainment, based on a script by writers Yunus Sajawal and Farhad-Sajid. It serves as first installment of Shetty's Cop Universe. A ...
''. This allegedly brought down copyright infringement of the film by 30%.
*On 29 August 2011,
Reliance Entertainment
Reliance Entertainment Pvt Ltd is an Indian media and entertainment company. It is a division of Reliance Group, handling its media and entertainment business, across content and distribution platforms. The company was founded on 15 February 20 ...
procured a 'John Doe' order from the
Delhi High Court
The High Court of Delhi ( IAST: ''dillī uchcha nyāyālaya'') was established on 31 October 1966, through the ''Delhi High Court Act, 1966'', with four judges, Chief Justice K. S. Hegde, Justice I. D. Dua, Justice H. R. Khanna and Justice S ...
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.
The use and selection of pseudonyms is not standardized in U.S. courts. The practice was rare prior to 1969, and is sometimes objected to on legal grounds.
*On 18 January 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 the year" by '' Glamour'' magazine. She publicly revealed her real name,
Chanel Miller
Chanel Elisabeth Miller (born June 12, 1992) is an American writer and artist based in San Francisco, California and New York City. She was known anonymously after she was sexually assaulted on the campus of Stanford University in 2015 by Broc ...
, in 2019.
*On 10 March 2015, HTG Capital Partners LLC filed a federal lawsuit against unnamed "spoofers", whom 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.
*In November 2016, a woman only identified as "Jane Doe" abandoned plans to go public about allegedly being raped by
Donald Trump
Donald John Trump (born June 14, 1946) is an American politician, media personality, and businessman who served as the 45th president of the United States from 2017 to 2021.
Trump graduated from the Wharton School of the University of P ...
.
*In October 2017, an unidentified minor Jane Doe detained by
U.S. Immigration and Customs Enforcement
The U.S. Immigration and Customs Enforcement (ICE) is a federal law enforcement agency under the U.S. Department of Homeland Security. ICE's stated mission is to protect the United States from the cross-border crime and illegal immigration tha ...
sued to enjoin the government from obstructing her access to abortion in '' Garza v. Hargan''.
*In March 2021, Justice Molloy of the Ontario Superior Court of Justice named a mass murderer, who was seeking notoriety, as John Doe when reading a highly publicized court decision (R. v. Minassian, 2021 ONSC 1258).
Blackacre
Blackacre, Whiteacre, Greenacre, Brownacre, and variations are the placeholder names used for fictitious estates in land.
The names are used by professors of law in common law jurisdictions, particularly in the area of real property and occasio ...
*
Foo
The terms foobar (), foo, bar, baz, and others are used as metasyntactic variables and placeholder names in computer programming or computer-related documentation. - Etymology of "Foo" They have been used to name entities such as variables, f ...
*
Joe Bloggs
"Joe Bloggs" and "Fred Bloggs" are placeholder names used primarily in the United Kingdom to represent the average man on the street. It is used by students, on standardized test preparation courses, to represent the average test-taker. Many coun ...
*
Joe Shmoe
Joe Shmoe (also spelled Joe Schmoe and Joe Schmo), meaning "Joe Anybody", or no one in particular, is a commonly used fictional name in American English. Adding a "Shm" to the beginning of a word is meant to diminish, negate, or dismiss an argum ...
The Autopsy of Jane Doe
''The Autopsy of Jane Doe'' is a 2016 supernatural horror film directed by André Øvredal. It stars Emile Hirsch and Brian Cox as father-and-son coroners who experience supernatural phenomena while examining the body of an unidentified woman ( ...
*
The man on the Clapham omnibus
The man on the Clapham omnibus is a hypothetical ordinary and reasonable person, used by the courts in English law where it is necessary to decide whether a party has acted as a reasonable person would – for example, in a civil action for negli ...
List of placeholder names by language
This is a list of placeholder names (words that can refer to things, persons, places, numbers and other concepts whose names are temporarily forgotten, irrelevant, or unknown in the context in which they are being discussed) in various languages. ...
*
Somerton Man
The Somerton Man was an unidentified man whose body was found on 1 December 1948 on the beach at Somerton Park, a suburb of Adelaide, South Australia. The case is also known after the Persian phrase (Persian: تمام شد), meaning "is over" ...