In the 1984 case of Ball v. United States, the Supreme Court ruled that a defendant cannot be convicted for both receiving a firearm in violation of federal law and possessing it. The court held that Congress did not intend to punish defendants twice for essentially the same offense. In this case, two brothers were charged with multiple counts related to unlawful possession and receipt of firearms due to their previous felony convictions which prohibited them from owning guns under federal law. They argued that they could not be punished separately for each count as these charges constituted "cumulative punishment" for identical acts, violating double jeopardy principles enshrined in Fifth Amendment rights against being tried or punished more than once for the same crime. The Supreme Court agreed with them on this point; however, it also stated that when such cases occur where there is evidence supporting both charges (receipt and possession), prosecutors can charge defendants with both crimes but must choose one upon conviction.

In the dissenting opinion for Ball v. United States, Justice Stevens argued that the majority's decision to overturn both of Ball's convictions - one for receiving a firearm and another for possessing it - due to concerns about double jeopardy was incorrect. He believed that Congress intended these two offenses to be separate when they enacted the law, as each offense requires proof of an element that the other does not. Furthermore, he pointed out that there are situations where someone could commit one crime without committing the other (for example, by receiving a gun but then immediately giving it away). Therefore, in his view, convicting someone of both crimes would not violate their protection against double jeopardy because they were being punished separately for separate acts.