United States v. Stewart, ___ F.3d ___ (9th Cir. November 13, 2003) (conviction for machine gun possession is reversed where 18 U.S.C. 922(o) is an invalid exercise of Congress's commerce Power, as it lacks any jurisdictional element; conviction for possession of firearms by a felon affirmed)
http://caselaw.lp.findlaw.com/data2/circs/9th/0210318p.pdf