In United States v. Vaello Madero, the Supreme Court held that a defendant’s conviction for possession of an unregistered firearm under 26 U.S.C § 5861(d) was not barred by the statute of limitations because it is a continuing offense and thus does not begin to run until the defendant has completed his or her possession of the weapon in question. The case arose when Vaello Madero was charged with possessing an unregistered firearm after he had been found with one during a traffic stop three years prior; however, he argued that since more than five years had passed since then, his prosecution should be time-barred due to the applicable five-year statute of limitations period set forth in 18 U.S.C § 3282(a). The Supreme Court rejected this argument and affirmed Madero's conviction on grounds that Congress intended for offenses like these to be treated as “continuing offenses” which do not accrue until they are complete—in this case meaning when Madero no longer possessed the gun—and therefore were exempt from any statutory limitation periods established by Congress in other statutes such as 18 U.S.C § 3282(a).

In the dissenting opinion of United States v. Vaello Madero, Justice Scalia argued that the majority opinion was wrong in its interpretation of the statute in question. He argued that the majority opinion had failed to consider the plain language of the statute, which stated that a person could be convicted of a crime if they “willfully” committed the act in question. Justice Scalia argued that the majority opinion had failed to consider the plain meaning of the word “willfully” and instead had relied on a broad interpretation of the statute. He argued that the majority opinion had failed to consider the fact that the statute was intended to punish those who acted with intent, and that the majority opinion had failed to consider the fact that the defendant had not acted with intent. Justice Scalia argued that the majority opinion had failed to consider the fact that the defendant had acted out of ignorance and not out of intent, and that the majority opinion had failed to consider the fact that the defendant had not acted with the intent to commit a crime. He argued that the majority opinion had failed to consider the fact that the defendant had acted out of ignorance and not out of intent, and that the majority opinion had failed to consider the fact that the defendant had not acted with the intent to commit a crime. Justice Scalia argued that the majority opinion had failed to consider the fact that the defendant had acted out of ignorance and not out of intent, and that the majority opinion had failed to consider the fact that the defendant had not acted with the intent to commit a crime. He argued that the majority opinion had failed to consider the fact that the defendant had acted out of ignorance and not out of intent, and that the majority opinion had failed to consider the fact that the defendant had not acted with the intent to commit a crime. Justice Scalia argued that the majority opinion had failed to consider the fact that the defendant had acted out of ignorance and not out of intent, and that the majority opinion had failed to consider the fact that the defendant had not acted with the intent to commit a crime. He argued that the majority opinion had failed to consider the fact that the defendant had acted out of ignorance and not out of intent, and that the majority opinion had failed to consider the fact that the defendant had not acted with the intent to commit a crime. Justice Scalia concluded that the majority opinion had failed to consider the plain language of the statute and had instead relied on a broad interpretation of the statute. He argued that the majority opinion