In the 1985 case United States Department of the Treasury, Bureau of Alcohol, Tobacco and Firearms v. Galioto, the Supreme Court ruled on whether a federal law barring convicted felons from owning firearms also applied to those whose civil rights had been restored. The plaintiff was Michael Galioto who had previously been convicted for a felony but later pardoned by Wisconsin's governor. Despite his pardon, he was denied an application to deal in firearms due to his past conviction under federal law which prohibited any person "convicted in any court" from dealing with guns. The Supreme Court held that once a felon’s civil rights have been restored through mechanisms such as gubernatorial pardon or expungement of criminal records, they are no longer considered “convicted” within the meaning of this particular statute and therefore can legally own guns again.

In the dissenting opinion for the case between United States Department of Treasury, Bureau of Alcohol, Tobacco and Firearms v. Galioto (1985), Justice Stevens argued that Congress did not intend to deprive individuals who had been committed to a mental institution but later recovered their sanity from owning firearms. He pointed out that there was no evidence in legislative history suggesting such an intention. Furthermore, he contended that this interpretation violated equal protection principles as it irrationally discriminated against those who have regained their mental health after institutionalization by permanently denying them firearm rights while allowing others with histories of dangerous behavior or substance abuse issues to possess guns if they were never committed. Thus, he disagreed with the majority's decision upholding ATF's broad interpretation of federal law prohibiting gun ownership by anyone ever "committed to any mental institution".