Chief Justice John Roberts Jr.'s offhand 2011 criticism of law review articles has stung legal academics ever since. Nearly four years later, his comment has finally met its match in the form of … a law review article.

“Someone had to do it,” said George Washington University Law School professor Orin Kerr, the author of the piece.

What Kerr did was the first—and perhaps the last—examination of the influence of German philosopher Immanuel Kant on the law of evidence in 18th century Bulgaria.