WHEN HANDWRITING EVIDENCE WAS FIRST LEGALLY ADMITTED IN THE EARLY 1800'S, THE COURTS LIMITED SPECIMENS TO THOSE WHICH WERE 'IN THE CASE FOR SOME OTHER PURPOSE.' GRADUALLY COURTS BEGAN TO ACCEPT OTHER CASUALLY WRITTEN SPECIMENS. IT WAS NOT UNTIL 1967 THAT THE COURTS CLAIMED TO HAVE THE POWER TO COMPEL A PERSON TO SUBMIT A HANDWRITING SAMPLE FOR ANALYSIS. THE U.S. SUPREME COURT UPHELD THIS PRACTICE IN 1971. NOW THAT BOTH A REFUSAL TO SUBMIT A SPECIMEN AND AN ATTEMPT TO DISGUISE A SPECIMEN CAN CARRY CONTEMPT CITATIONS, HANDWRITING EXAMINERS MUST BE EXTREMELY CAREFUL BEFORE STATING THAT A PIECE OF WRITING WAS INTENTIONALLY DISGUISED. ALL SUSPICIONS MUST BE CAREFULLY DOCUMENTED. AN ILLUSTRATION COMPARES NATURAL VERSUS DISGUISED WRITING. VARIOUS WAYS TO DISGUISE WRITING ARE EXAMINED. THE EXAMINER IS ALSO WARNED TO LOOK AT THE CIRCUMSTANCES UNDER WHICH THE SPECIMEN WAS COLLECTED. THE SIGNIFICANCE OF QUESTIONABLE FEATURES MUST BE THOROUGHLY EVALUATED. CAUTIONS ARE SPELLED OUT. REFERENCES ARE MADE TO MORE DETAILED TREATMENTS OF THE SUBJECT. (GLR)