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. 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).

## History

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

The name "John Doe" (or "John Do"), "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. 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* 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":

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 [2007] HRLR 4.

*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.*

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.

## 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. 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.
* 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*. 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.

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.

* 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 a year" by *Glamour* magazine. She publicly revealed her real name, Chanel Miller, in 2019.
* On 10 March 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.
* In November 2016, a woman only identified as "Jane Doe" abandoned plans to go public about allegedly being raped by Donald Trump.
* 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*.
* In March 2021, Justice Molloy of the Ontario Superior Court of Justice named a mass murder, who was seeking notoriety, as John Doe when reading a highly publicized court decision (R. v. Minassian, 2021 ONSC 1258).

## See also

* Average Joe
* Blackacre

## References

1. **^** Campbell, Jean (15 February 2021). "John Doe Exhumed in 40-Year Old Case". *Medium*. Retrieved 19 February 2021.
2. John Doe may also be a reference to a retired, presumed dead, hitman known as Coyote.