In Barrett v. United States (1975), the Supreme Court ruled that a federal law prohibiting felons from receiving firearms did not apply to intrastate transactions, as long as the seller was unaware of the buyer's criminal record. The case involved James Dillard Barrett who had been convicted for receiving a firearm shipped in interstate commerce after being previously convicted of a felony. He argued that he should not be held liable because his purchase was made within state lines and thus outside federal jurisdiction. The court agreed with him, stating that Congress intended to regulate only those transactions where it could reasonably assume an effect on its charge over interstate commerce or where it is explicitly stated otherwise.

In the dissenting opinion for Barrett v. United States, Justice Marshall argued that the majority's interpretation of 18 U.S.C. § 2113(e) was too broad and not in line with congressional intent. He contended that Congress intended to punish more severely those bank robbers who forced another person "to accompany him" during a robbery or while fleeing from it, but did not intend to include situations where victims were merely moved around within one room as part of the crime scene control strategy by criminals. According to Justice Marshall, such an expansive reading could lead to absurd results where minor movements would trigger harsher penalties under federal law than state laws for kidnapping or hostage-taking offenses which typically require substantial confinement or movement of victims.