Unidentified people are called “Jane Doe” because the name descends from a medieval English courtroom fiction. Starting in the 14th century, English lawyers used invented parties named “John Doe” and “Richard Roe” to sneak property disputes past the slow machinery of common law, and the placeholder habit stuck. Centuries later, “Jane Doe” emerged as the feminine counterpart, and today the name is used for unidentified bodies, anonymous plaintiffs, unknown online defendants, and anyone else whose real identity is missing or deliberately shielded.
The Medieval Courtroom Trick That Invented the Name
During the reign of Edward III (1327–1377), English courts developed a shortcut for resolving land ownership called an “action of ejectment.” Proving title under common law was a slow, technical process, so a landlord would file suit on behalf of a made-up tenant named “John Doe,” claiming that another fictional person named “Richard Roe” had ejected Doe from the property. To sort out the rights of these imaginary people, the court first had to decide who actually owned the land, which was the landlord’s real goal all along.
The fiction worked, and it stayed in use for centuries. “John Doe” and “Richard Roe” became fixtures of English pleadings, familiar enough that lawyers and judges stopped pretending they referred to real people at all.
Why “Doe,” and Why “Jane”
The names were chosen for their ordinariness. “John” and “Richard” were among the most common English given names of the period. “Doe” and “roe” are both types of deer common in Britain. Pairing a familiar first name with an animal-based surname produced labels that sounded vaguely plausible without fooling anyone about their fictional nature.
“Jane Doe” was not part of the original set. The medieval ejectment cases used “John Doe” and “Richard Roe,” both male. “Jane Doe” came along later as a natural feminine adaptation once the names had broken free of property law and were being used as general-purpose stand-ins. “Jane Roe” gained its own wide recognition through Roe v. Wade in 1973, when plaintiff Norma McCorvey filed under that pseudonym. In some federal filings, “Mary Major” has turned up as an alternative female placeholder, but it never took hold the way “Jane Doe” did.
How the Names Survived the End of the Fiction
By the 1830s, American states began dropping the ejectment fiction, recognizing that property disputes were really between flesh-and-blood people rather than imaginary tenants. Britain’s Parliament formally abolished Doe and Roe in 1852. The procedure that gave birth to the names was gone, but the names themselves had already escaped the courtroom and taken on a life of their own as placeholders for anyone whose identity was unknown or needed hiding.
A couple of 20th-century cases cemented the names in American public memory. Roe v. Wade made “Roe” a household word. In 1982, an infant born in Bloomington, Indiana, with significant disabilities became the center of a national controversy over medical treatment decisions, and “Baby Doe” entered the vocabulary of medical ethics as shorthand for debates over care for critically ill newborns.
Where “Jane Doe” Shows Up Today
The name does three main jobs in modern American life.
The first is forensic. When a body is found and nobody can identify it, law enforcement assigns a “Jane Doe” or “John Doe” designation so the case can be tracked and cross-referenced against missing persons reports. The FBI’s Violent Criminal Apprehension Program maintains a national repository of unidentified persons cases filed under Doe names.1Federal Bureau of Investigation. ViCAP Unidentified Persons The National Missing and Unidentified Persons System (NamUs) tracked more than 15,500 unidentified person cases as of early 2026, with roughly 9,000 still open.2NamUs. Reports and Statistics Every open case sits in that database under a Doe name, waiting for a match.
Hospitals handle unidentified patients a little differently. Standard intake protocols at most facilities use labels like “Unidentified Male” or “Unidentified Female,” with sequential numbering when more than one unidentified patient arrives at once, and detailed physical descriptions go into the record so staff can match incoming family inquiries to the right person.
The second job is pseudonymous litigation. Federal court rules require a complaint to name all parties,3Legal Information Institute (LII) / Cornell Law School. Rule 10 – Form of Pleadings so filing as “Jane Doe” is the exception rather than the rule. A plaintiff who wants anonymity needs the judge’s permission, and courts weigh factors like whether the suit challenges government action, how sensitive the underlying facts are, and whether identification would expose the plaintiff to a credible threat of harm. Judges have found those concerns compelling in cases involving sexual assault, reproductive choices, mental health, immigration status, and situations where naming the plaintiff would invite harassment or retaliation. Filing under a false name without the court’s blessing can trigger sanctions under Rule 11.4Legal Information Institute (LII) / Cornell Law School. Rule 11 – Signing Pleadings, Motions, and Other Papers; Representations to the Court; Sanctions
The third job is unmasking anonymous online defendants. When someone posts defamatory or harassing content behind a screen name, the target often files suit against “John Doe” and then uses discovery to identify the poster through the platform and the internet service provider. Because anonymous speech carries First Amendment protection, courts usually require real evidentiary showings before ordering disclosure.
Related Placeholder Names
“John Doe” is the default male placeholder, “Jane Doe” the female equivalent, and “Baby Doe” is reserved for unidentified children. When a case involves multiple unknown parties, courts historically added names like “Richard Roe” and “Jane Roe,” though modern practice more commonly numbers them sequentially: Doe 1, Doe 2, and so on. The older convention of cycling through surnames like Roe, Stiles, and Miles has largely faded.
What is striking about “Jane Doe” is its sheer durability. A naming convention invented to game medieval property courts outlasted the procedure it was designed for, survived formal abolition in England, crossed the Atlantic, and found new work in forensics, civil rights litigation, internet law, and emergency medicine. Few legal fictions have had that kind of career.