How have courts treated statutory history in the context of statutory ambiguity?

MultiRegion, United States of America

The following excerpt is from Resisting Envtl. Destruction on Indigenous Lands v. U.S. Envtl. Prot. Agency, No. 12-70518 (9th Cir. 2012):

REDOIL ironically resorts to legislative history in an effort to avoid ambiguity. However, were the statutory language clear, as REDOIL posits, reference to the legislative history would be both unnecessary and inappropriate to illuminate unambiguous text. Ratzlaf v. United States, 510 U.S. 135, 147-48 (1994) ("[W]e do not resort to legislative history to cloud a statutory text that is clear."); Barnhill v. Johnson, 503 U.S. 393, 401 (1992) ("[A]ppeals to statutory history are well taken only to resolve statutory ambiguity.") (internal quotation marks omitted).

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