The term just finished reminds us once again how central appeals to “history and tradition” have become to the Roberts Court’s constitutional project. But what’s perhaps most surprising—and ironic—about the history and tradition test is that the test itself is not “deeply rooted in the Nation’s history and tradition” at all. Instead, Bruen now insisted that the relevant test that courts must apply is whether modern gun regulations were consistent with the nation’s historical tradition of firearm regulation. There is irony, of course, in pointing out that the “history and tradition” test itself is not deeply rooted in this nation’s history and tradition. But one could imagine asking a different question: Was there a deeply rooted historical tradition protecting bodily integrity?