Tony Vargas
Legend
The first time a DM insisted I roll to hit with a fireball was probably c1983. I believe there was an actual rule in 3e (a 'touch attack' to aim a fireball through a small opening, like an arrow slit), but I'm not sure.Except by RAW fireballs don't miss.
When's the last time you made someone roll to hit with (or to aim) one?
However, the point was probably that having your target roll a saving throw and succeed is mathematically the same as rolling an attack and missing. They're both binary succeed/fail rolls on a d20, the distinction is semantic, and adds nothing to the game apart from needless complexity.
There have even been saving throws in D&D that did litterally just indicate whether an attack spell hit or missed. The older-ed versions of Ray of Enfeeblement and Disintegrate, for instance.