Professor Massey’s article first distinguishes between purpose and motive, a distinction that the Supreme Court frequently elides, then examines what the Court has done, and proposes what the Court should do. The article argues that although the stringency of the applicable level of review has some influence upon the relevance of purpose, the Court’s consideration of purpose is unguided by any discernible principle. Purpose is sometimes derived from statutory text, sometimes from the effects of the action, sometimes from hypothesis, and sometimes from inferences of motive, and these varying methods are largely untethered from the applicable level of review. To provide a modicum of grounding, Professor Massey suggests approaches the Court should adopt when examining the role of purpose within the different tiers of scrutiny.