The United States Supreme Court brought conformity to the Circuit Courts of Appeal by holding that the "convicted in any court" element of a federal firearm statute encompasses only domestic convictions.
Small v. United States, 125 S. Ct. 1752 (2005).
Robert A. Bracken,
Foreign Convictions Are Not Proper Predicate Offenses under the Statutory Language "Convicted in Any Court": Small v. United States,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol44/iss2/10