Scarborough v. United States

Summary

The Supreme Court held that, under 18 U.S.C. App. § 1202(a)(1), proof that a firearm previously traveled in interstate commerce satisfies the required commerce nexus for a convicted felon's possession offense. The Court affirmed the conviction, concluding that Congress intended a minimal nexus requirement and did not require contemporaneous movement of the firearm or possession beginning after the felony conviction. Justice Stewart dissented, arguing that the rule of lenity required limiting the statute to firearms first possessed after conviction.

Holdings

1. Proof that the firearm possessed by a convicted felon previously traveled in interstate commerce is sufficient to establish the statutory commerce nexus under 18 U.S.C. App. § 1202(a)(1). The Government need not prove that the defendant purchased the firearm across state lines, carried it across state lines, acquired it after conviction, or possessed it contemporaneously with interstate commerce.
2. The rule of lenity and the canon against interpreting ambiguous statutes to alter the federal-state balance do not justify the petitioner's narrower interpretation because the statutory purpose and legislative history clearly support the Government's construction.

Questions Presented

1. Whether proof that a firearm previously traveled in interstate commerce, without proof that the defendant acquired or possessed it contemporaneously with interstate commerce, satisfies the commerce-nexus requirement of 18 U.S.C. App. § 1202(a)(1).
2. Whether the rule of lenity or concern for the federal-state balance required construing § 1202(a)(1) to reach only possession beginning after the defendant's felony conviction or having a contemporaneous connection with commerce.

Disposition

affirmed