Every historical film must contend with the possibility that its viewers will be scandalized by its mixture of fact and fiction, but no recent historical film has faced such pressure to justify its hybrid nature as Selma has, in large part because no recent film has taken on so momentous and controversial a historical subject: the civil rights marches from Selma to Montgomery that led to the passage of the Voting Rights Act in 1965. The renewed urgency of the issues Selma dramatizes, along with the film’s own commitment to the “moral certainty” of the civil rights movement, helps explain why Selma wavers in a self-defense that links the fictionality of its historical reenactments to the purposely theatrical element of the marches themselves. But politics are not the only problem for fiction in Selma, and to show why, this essay compares Selma to an earlier historical film, The Westerner (1940), that openly flaunts the commercial nature of its fictionality.