How would an historical fact simpliciter confer constitutional status on a proposition entirely apart from any legal basis? If it means that the Justices may have been motivated by the importance of the freedom to travel to the American experience, I imagine this may have been so (although consistency with "absent forensic evidence" moves again close to the mystery genre). But the relevance of this point depends upon confusing motivation with causality. The mere wish to celebrate interstate travel does not write an opinion.

DEFINE: Distinguishes judicial motivation from legal causality in constitutional interpretation, clarifying that historical celebration alone doesn't create constitutional doctrine.

Philip Chase Bobbitt, Philip Chase Bobbitt - Refl…, loc. 807