After the Golden State Killer was arrested and sentenced in 2018, interest in investigative genetic genealogy spiked.
May
2025
She thanks the University of Chicago Law Review Online team.
After the Golden State Killer was arrested and sentenced in 2018, interest in investigative genetic genealogy spiked.
I thank Professor William H.J. Hubbard for his expert guidance and thoughtful feedback as well as the editors of the University of Chicago Law Review.
This Comment explores the history of Rule 12(d), describes courts’ varying uses of the exception, and proposes a unifying method of interpretation for the future. Drawing on other procedural rules and an analogous doctrine in contract law, it argues that only unmistakably referenced written instruments may be incorporated.