Barrett v. United States
In Barrett v. United States, 423 U.S. 212, 96 S.Ct. 498, 45 L.Ed.2d 450 (1976), the Court held that the interstate commerce nexus requirement of 18 U.S.C. 922(h) could be met by proof that the firearm had previously traveled in interstate commerce.
The Court cited the language of 922(h), the structure of the Title IV of the Omnibus Act and the "manifest purpose of Congress" as supportive of their conclusion.
In discussing the legislative history, the Court emphasized the purpose of Congress in passing Title IV as opposed to Title VII, was not directed to interstate trafficking in firearms but, rather, to the acquisition and possession of firearms by certain classes of people. Id. 96 S.Ct. at 502-03.