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LawProse Lesson #124: Is person that (as opposed to who) proper?

Is it permissible to say people that, or must you always say people who? One often hears language aficionados who proclaim that who is best for people, and that that, strictly speaking, is loose or even taboo as a relative pronoun referring to humans.

They’re wrong: people that has always been good English, and it’s a silly superstition to insist that who is the only relative pronoun that can refer to humans. Consider a sampling of authorities that (or who) explain the situation:

• “That has been the standard relative pronoun for about eight hundred years and can be used in speaking of persons, animals, or things. . . . Three hundred years ago who also became popular as a relative. It was used in speaking of persons and animals but not of things. . . . Who may in time drive out that as a relative referring to persons, but it has not yet done so. . . . That may still be used in speaking of a person, as in the child that has been subject to nagging is in perpetual terror.” Bergen Evans & Cornelia Evans, A Dictionary of Contemporary American Usage 555 (1957).

• “Since when is that rather than who permissible in referring to persons? The answer, of course, is: since the language was in its infancy.” Theodore M. Bernstein, Miss Thistlebottom’s Hobgoblins: The Careful Writer’s Guide to the Taboos, Bugbears and Outmoded Rules of English Usage 81 (1971).

• “Of these relative pronouns, . . . that [refers] to things and persons; who to persons only.” Eric Partridge, Usage and Abusage 375 (1982).

• “Down through the centuries, that has often been used with a human antecedent. Chaucer, Langland, and Wyclif are all cited in the OED using that in this way, and examples are also given from writers in each of the later centuries.” R.W. Burchfield, The New Fowler’s Modern English Usage 773 (3d ed. 1996).

• “Who . . . normally refers to a person . . . . That refers to a person, animal, or thing . . . .” Bryan A. Garner, “Grammar and Usage,” in The Chicago Manual of Style § 5.54, at 218 (16th ed. 2010).

My recommendation: don’t be one of those people that insist on not using that in reference to humans. And be curious enough to consult usage books when you suspect that someone is linguistically errant.


Garner’s Dictionary of Legal Usage 945 (3d ed. 2011).
Garner’s Modern American Usage 808, 862 (3d ed. 2009).

Thanks to Steven Biagi and David Gurnick for suggesting this topic.

Bryan A. Garner, President of LawProse Inc., is the most prolific CLE presenter in the U.S., having trained more than 150,000 lawyers and judges. His book — most prominently Black’s Law Dictionary and Garner’s Modern American Usage — have been cited as authority by every state and federal appellate court, including the highest. For more about him, go to To follow him on Twitter: @bryanagarner.

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