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The Supreme Court has taken a turn toward text. Its recent opinions in statutory cases by and large focus on the text of the statute in question. Infrequent has become the opinion in which the Court relies on the" in-tent" of the legislature as expressed in legislative history or on considera-tion of the consequences of its decision. This change in interpretative focus has been well noted; 1 what remains in question is the propriety of the Court's textualist approach. 2 Most commentators reject textualism, and instead argue that the Court should expressly resolve interpretive issues through what is called" dynamic interpretation." 3 The advocates