Small v. United States

Summary

The Court held that the phrase 'convicted in any court' in 18 U.S.C. § 922(g)(1) applies only to domestic convictions, not foreign ones. This conclusion rests on the presumption that Congress legislates with domestic concerns in mind and the inconsistencies that would arise from including foreign convictions. Justice Thomas dissented, arguing the plain meaning of 'any court' includes foreign courts.