A documentary drama about the American Wallis Simpson (the influence upon Edward VIII causing him to abdicate the throne of England on 10th December 1936) is titled 'Wallis : The Queen That Never Was'.

The piece is written and directed by Paul Olding, a British writer and director.

Immediately I saw the title, I paused as I would have expected it to say 'who never was', since Wallis Simpson was a person and the usual pronoun regarding persons is 'who', not 'that'.

It is true there is a mixture of concepts, here.

The title is not questioning the historic existence of the person, but is stating that she never became Queen of England. So the title is stating something about the office of Queen. That office was never upon that historic person.

In which case the title of the piece actually means 'The Woman who never became Queen'. And in that case, one would not say :

The Woman That Never Became Queen

but rather :

The Woman Who Never Became Queen

Should not the pronoun be 'who' in this particular case ?

Edit : The Ngram suggested in @Peter Shor 's answer is interesting and I have added 'a/the woman who// a/the woman that' which shows a significantly greater modern weighting for 'the woman who' and an even greater modern weighting for 'a woman who', which is notable for with the indefinite article the phrase, supposedly, becomes less 'specific'.

Ngram additonal.

Edit: The suggested duplicate does not answer my question as this situation is specific to the mixed concept of person and office and it is clear from answers and comments, thus far, that the language is changing in regard, especially, to the use of 'that' and 'who' in relation to women, as can be seen from the Ngram.

I believe that this question has highlighted something interesting happening within the language and I believe that the subject is worth pursuing further.

  • 1
    It author's choice. "That" places more emphasis on the office, while "who" emphasizes the person.
    – Hot Licks
    Dec 8, 2019 at 14:00
  • Sometimes the ambiguity is desirable. When Shakespeare has Romeo say "He jests at scars that never felt a wound" (Romeo and Juliet, Act II, scene ii) it ramifies into a "who/that" dichotomy. On the one hand, it means someone who has never felt a wound can jest about it; on the other, it suggests Romeo's own "scars" may be imaginary. Had who replaced that it would have been a bald statement of the former, not nearly as deep.
    – Robusto
    Dec 8, 2019 at 16:09
  • Does this answer your question? How to use "who" vs. "that" Dec 8, 2019 at 23:13
  • I did notice that one @EdwinAshworth, but this case is specific (mixed concepts) and as Peter Shor states, the language is changing. The Ngram shows that usage is adapting to modern requirements. Also, there is a shade of meaning between 'who' and 'that' : which is what I am trying to get at.
    – Nigel J
    Dec 9, 2019 at 4:37
  • 1
    Speaking for myself, if I actually had to choose a title, I'd be worried about the depersonalising nuance of 'that'. I'd be less exercised over using 'The World Ruler that never was' for Sauron. Dec 9, 2019 at 15:06

4 Answers 4


That used instead of who:

Research proves it isn’t quite the hard-and-fast rule one might imagine. For example, the indispensible Fowler’s Modern English Usage says: ‘That can also replace who (or whom), especially when the reference is non-specific, as in The person that I saw was definitely a woman.’ And examples of this usage can be found in work by Chaucer, Shakespeare and in the King James Version of the Bible.


That or who:

Most writers use that and which as the relative pronouns for inanimate objects, and who as the relative pronoun for humans. This widespread habit has led to the mistaken belief that using that in reference to humans is an error. In fact, while most editors prefer who for people, there is no rule saying we can’t use that, and that has been widely used in reference to people for many centuries. It remains so today, especially in British writing.

(The Grammarist)

And also from the AHD:

There is a widespread belief, sometimes taught as correct usage, that only who and not that should be used to introduce a restrictive relative clause identifying a person. But that has been used in this way for centuries, going back to the Old English period, and has been used by the finest writers in English, as in "The man that once did sell the lion's skin / While the beast liv'd, was kill'd with hunting him" (Shakespeare). and "Scatter thou the people that delight in war" (King James Bible).

In contemporary usage, who predominates in such contexts, but that is used with sufficient frequency to be considered standard, as in "The atoms in a diamond ... outnumber all the people that have ever lived or ever will" (Richard Dawkins). That also occurs idiomatically in reference to groups (where who would sound peculiar), as in "[She] had two sons, and settled into raising a family that soon included twin daughters" (David Freeman).

  • Indeed, 'that' is non-specific. But we know who Wallis Simpson was and we are not unfamiliar with the woman. In which case, it should be 'who'. Yes ?
    – Nigel J
    Dec 8, 2019 at 13:44
  • @NigelJ it should probably be “who”, but as noted the rule is not that hard-and-fast and usage may vary.
    – user 66974
    Dec 8, 2019 at 13:52
  • Chaucer, Shakespeare, and the King James Bible also use thou art, I am come, and many other constructions that are considered ungrammatical today. Dec 8, 2019 at 14:39

The English language seems to be changing. Google Ngrams shows that in the 1750s, "A person that" was used maybe a third as often as "A person who" (note that I start these with capital letters to avoid counting phrases like "to convince a person that"); while today, "A person that" occurs with the something like 1% the frequency of "A person who".

Is using that for people ungrammatical? It certainly wasn't in the 18th and 19th centuries, but it certainly seems to be headed that way, and you could probably make a good argument that it is today.

In my opinion, you should be very careful about calling things that were widely used 100 years ago "ungrammatical", as usages change with different frequencies in different dialects, and there probably are still some people who grew up in households and communities that used these constructions. However, I think we can safely say that you should avoid this construction—it will annoy or confuse a large number of native English speakers.

The Grammar Monster says

It is quite unfashionable to use that for people. (The consensus seems to be that using that for people is still acceptable in speech and informal writing, but you should avoid doing it in formal writing.)

  • The Ngram agrees with my own perception and my own usage.
    – Nigel J
    Dec 8, 2019 at 14:21
  • Can you please cite a source that agrees with you opinion?
    – user 66974
    Dec 8, 2019 at 14:29
  • @user067531: Done. Dec 8, 2019 at 14:33
  • Good, it is always wise to support your own personal opinions with reliable sources.
    – user 66974
    Dec 8, 2019 at 14:47

As an additional observation:

'The Queen That Never Was', to me, indicates that there was a woman who really existed but who never became Queen.

'The Queen Who Never Was', to me, indicates a fictional or mythical Queen who did not ever actually exist.

Above and beyond the usage rules described above, using 'Who' implies that it is the person who never was; using 'That' implies that some attribute of that person never was.


Strunk and White's The Elements of Style says this of "that/which":

"That" is the defining, or restrictive pronoun, "which" the nondefining or nonrestrictive. See Rule 3.

And Rule 3 says:

Enclose parenthetic expressions between commas.

E.g. compare:

  • The book that is on the table is very interesting.
  • The book, which is on the table, is very interesting.

The first is restrictive. It defines the book of interest as the specific book located on the table, not any of the books on the shelf or elsewhere.

The second is parenthetical. The listener already knows what "the book" refers to, and that it is on the table is supplemental information letting the listener know where it can be found.

The words "who" and "whom" are used exactly like "which", except when referring to people rather than things. "That" can be applied equally to things or people.


  • The woman that never became queen is at the left in the photo.
  • The woman, who never became queen, is at the left in the photo.

In the first, the photograph contains several women and the speaker is pointing out which one never became queen. The description is restrictive or defining, so it uses "that" and no commas.

In the second, the listener already knows who "the woman" is, but might not know what she looks like. The speaker is pointing out which image is hers. That she never became queen is additional information. It is parenthetical and can be omitted without changing the basic meaning of the sentence.

(These are the formal rules, and of course in practice many people use a different rule: when choosing between "that" or "which", use whichever one sounds best (as in Rudyard Kipling's story, "The Man Who Would Be King").)

  • But who and whom can, even in formal writing, be used like either that or which. It works for both restrictive and unrestrictive clauses. There is absolutely nothing wrong with the grammar of The Man Who Would Be King. For example, Lexico gives an example of ‘Joan Fontaine plays the mouse who married the playboy’ Do you have a reliable source that says otherwise? Dec 8, 2019 at 15:56
  • @PeterShor, As I said, there's the other rule of using whichever sounds best. Dec 8, 2019 at 16:04
  • Your answer certainly implies that The Man Who Would Be King violates the formal rules. It doesn't. Even Strunk and White say this. Dec 8, 2019 at 16:06

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