Statutory history represents the evolution of a statute through enacted amendments. Although textualists have widely rejected traditional forms of legislative history, statutory history has not received the same fate. Instead, textualists have accepted the use of statutory history as a resource separate from—and superior to—legislative history. Thus, this Note examines how courts are using statutory history, focusing primarily on the author’s analysis of a set of courts of appeals cases that rely on statutory history. Using these cases, this Note explores whether statutory history is best understood as text or context within the interpretation process. Further, this Note challenges the textualist ideal that statutory history is a superior interpretive resource compared to traditional legislative history. Ultimately, this Note proposes that statutory history is best used as context but should remain flexible to be considered as both text and context. Lastly, this Note proposes two exceptions to the textualist bar on traditional legislative history when used to interpret statutory history.