In Scarborough v. United States (1976), the U.S Supreme Court ruled that a prior felony conviction is sufficient to satisfy the "felony" element of 18 U.S.C §1202(a) - a federal law prohibiting convicted felons from possessing firearms, regardless of whether or not the firearm has traveled in interstate commerce. The case involved petitioner Scarborough who was charged with violating this statute after being found in possession of two firearms. He had previously been convicted for felonies but argued that his conviction under §1202(a) should be overturned because there was no evidence showing that his possession affected interstate commerce as required by the law. However, the court held that it's enough if at any time since its manufacture, the firearm moved across state lines.

In the dissenting opinion for Scarborough v. United States, Justice William Rehnquist disagreed with the majority's interpretation of 18 U.S.C. §922(h), which prohibits convicted felons from receiving firearms that have been shipped or transported in interstate commerce. He argued that Congress intended to limit this prohibition only to those instances where the felon was involved in, or had knowledge of, the firearm's movement across state lines. The majority’s broader interpretation would mean any felon who possesses a gun is potentially violating federal law if it can be shown that at some point in time - even before his conviction - the weapon moved across state lines; an idea he found absurd and not within Congressional intent when drafting this legislation.