It looks like I am not the only one confused by this. One site that I checked, stated that either way was correct, you just needed to be consistent in your useage. So far, that one seems to be the most senisble, as it is something I have noticed being done.
I have been known to completely reword a sentence to avoid the issue, but that isn't always possible, especially when you are referring to a person directly.
Thanks for the input. If nothing else, I no longer feel as if I am stupid for not knowing which way is correct.