Congressman Abraham Lincoln, used judicial notice to establish that a claim by a witness to have used moonlight to see events could not have taken place since there was no visible moon that evening. This led to Armstrong's acquittal. In the 1934 United States Supreme Court case Home Building & Loan Association v. Blaisdell, Chief Justice Charles Evans Hughes took judicial notice of the economic conditions of the Great Depression to help conclude that a state of emergency existed, and thus the State of Minnesota could properly impose on the contracts made by private persons to promote a broad societal interest. Specifically, the Court upheld a Minnesota statute preventing loan companies from foreclosing on homes before 1935, despite mortgage agreements allowing companies the right to do so. In the 1981 case of Mel Mermelstein v. Institute for Historical Review, the Superior Court of Los Angeles County took judicial notice of the fact that Jews were gassed to death at the Auschwitz Concentration Camp in 1944. Judicial notice in Australia In Australia, judicial notice may be taken of facts that are "not reasonably open to question". This may include, for example, the location of well-known geographical features. However, both parties must be given notice of the judicial officer's intention to rely upon the information. Judicial notice in Canada Besides the categories of judicially noticed facts found in other common law jurisdictions, the Supreme Court of Canada has required Canadian courts to take judicial notice (connaissance d'office) of such facts as the history of colonialism in Canada and its harmful effects on Indigenous peoples: To be clear, courts must take judicial notice of such matters as the history of colonialism, displacement, and residential schools and how that history continues to translate into lower educational attainment, lower incomes, higher unemployment, higher rates of substance abuse and suicide, and of course higher levels of incarceration for Aboriginal peoples. —R. v. Ipeelee, at para. 60 Some judges have taken a similar approach to the history of racism against other ethnic groups in Canada, such as African Canadians, concerning whom Justice Nakatsuru of the Ontario Superior Court of Justice wrote: I find that for African Canadians, the time has come where I as a sentencing judge must take judicial notice of such matters as the history of colonialism (in Canada and elsewhere), slavery, policies and practices of segregation, intergenerational trauma, and racism both overt and systemic