1971—In a unanimous opinion in Citizens to Preserve Overton Park v. Volpe, Justice Thurgood Marshall hilariously illustrates the topsy-turvy understanding of the relationship between statutory text and legislative history that dominated the Warren Court and that prevailed for years after. Marshall first observes that the “legislative history of [two statutes] is ambiguous” and only then turns to the statutory text: “Because of this ambiguity [in legislative history], it is clear that we must look primarily to the statutes themselves to find the legislative intent.”