Originalism has become the predominant form of constitutional interpretation in the Supreme Court, a rebuttal to the notion that the Constitution is a living document whose meaning evolves with the times.  "We are all originalists," Justice Elena Kagan famously said at her confirmation hearing. There are various forms of originalism—some little different from the living Constitution theory—but all depend to some extent on understanding the historical milieu in which the Constitution was drafted and ratified. Yet jurists are not historians and do not have the time or resources to do original research. As one frustrated district judge recently complained, "[t]his Court is not a trained historian. … [y]et we are now expected to play historian in the name of constitutional adjudication."  Not surprisingly, when playing historian, judges sometimes get it wrong.