About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline

27 Penn St. Int'l L. Rev. 895 (2008-2009)
Taking Judicial Notice in the Genocide in Rwanda: The Right Choice

handle is hein.journals/psilr27 and id is 901 raw text is: I Comments I
Taking Judicial Notice of the Genocide in
Rwanda: The Right Choice
Rebecca Faulkner*
I.  INTRODUCTION
At the Roman Catholic Church compound in Shangi, Rwanda,
bloody handprints remain on the walls as a gruesome reminder of the
Hutu massacre of Tutsis that occurred on April 18, 1994.1 In one room,
handprints stretch from floor to ceiling, showing how Tutsis stood on one
another's shoulders in desperate efforts to reach ceiling crawl spaces and
the roof in order to hide from Hutu militiamen.2 Other rooms are bullet-
pocked or partially blown apart by hand grenades.3 Although no one
knows for sure, it is estimated that as many as 4,000 Tutsis-adults and
children alike-were hacked, shot, or beaten to death at the Shangi
* Juris Doctor, The Dickinson School of Law of the Pennsylvania State
University, 2009; Bachelor of Arts, Wheaton College, Norton, Massachusetts, 2006.
Special thanks to my family and friends who supported and encouraged me during the
writing process. Thank you also to the PILSR members who took the time to read this
Comment and provide thoughtful critique.
1. See Jonathan C. Randal, A Mosaic of Bloody Handprints Recalls 4,000 Tutsis'
Last Day of Life, WASH. POST, June 29, 1994, at A 17.
2. See id.
3. See id.

What Is HeinOnline?

HeinOnline is a subscription-based resource containing nearly 3,000 academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.



Short-term subscription options include 24 hours, 48 hours, or 1 week to HeinOnline with pricing starting as low as $29.95

Contact us for annual subscription options:

Already a HeinOnline Subscriber?

profiles profiles most