In Scarborough v. United States, 431 U.S. 563, 97 S.Ct. 1963, 52 L.Ed.2d 582 (1977), the Supreme Court revisited former 18 U.S.C. section 1202(a), this time to describe the nature of the proof required of the government in order to establish that a possession had been "in commerce or affecting commerce." Scarborough had been convicted of possessing firearms as a convicted felon, notwithstanding his argument that "proof that the firearms had at some time traveled in interstate commerce did not provide an adequate nexus between the possession and commerce." Scarborough, 431 U.S. at 566, 97 S.Ct. at 1964. The Court framed the question presented as "whether proof that the possessed firearm previously traveled in interstate commerce is sufficient to satisfy the statutorily required nexus between the possession of a firearm by a convicted felon and commerce." Id. at 564, 97 S.Ct. at 1964. To the Court, this question was one of simple statutory construction. The Court reiterated that "Congress is aware of the 'distinction between legislation limited to activities "in commerce" and an assertion of its full Commerce Clause power so as to cover all activity substantially affecting interstate commerce.' " Id. at 571, 97 S.Ct. at 1967. The Court noted that: the purpose of former section 1202(a) was to proscribe mere possession but that there was some concern about the constitutionality of such a statute. It was that observed ambivalence that made us unwilling in Bass to find the clear intent necessary to conclude that Congress meant to dispense with a nexus requirement entirely. However, we see no indication that Congress intended to require any more than the minimal nexus that the firearm have been, at some time, in interstate commerce. Scarborough, 431 U.S. at 575, 97 S.Ct. at 1969. The Court explained that it had decided not to follow dicta in Bass that had suggested that there might be a stricter nexus requirement for possession than for receipt of a firearm. The Court noted that the requirement "would make sense, ... but that that was not the choice Congress made. Congress was not particularly concerned with the impact on commerce except as a means to insure the constitutionality of section 1202(a) ." Id. at 575 n. 11, 97 S.Ct. at 1969 n. 11.