Reposted with permission from Bryan Garner, Distinguished Research Professor of Law, Southern Baptist University.
- "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).
Sources:Garner's Dictionary of Legal Usage 945
(3d ed. 2011).Garner's Modern American Usage 808, 862
(3d ed. 2009).