Many textualists see canons of interpretation as a means to deal with statutory ambiguity, while nontextualists are more likely to turn to legislative history. This Essay explores some of the problems with each approach: for canons, determining which context is the best one to analyze, and for legislative history, determining which statements are reliable and which are hot air.
Easterbrook, Frank H.
"The Absence of Method in Statutory Interpretation,"
University of Chicago Law Review: Vol. 84
, Article 5.
Available at: http://chicagounbound.uchicago.edu/uclrev/vol84/iss1/5