The 9th circuit took a limited view of interstate commerce? Interesting.
US v. Stewart, 9th Circuit, 2003.
Based on the four-factor Morrison test, section 922(o) cannot be viewed as having a substantial effect on interstate commerce. We therefore conclude that section 922(o) is unconstitutional as applied to Stewart.
As said before, SCOTUS was offended by this, and ordered the 9th Circuit to find 922(o) constitutional as applied to an article that was fabricated in one's own house, and never left that house, and was never offered (e.g., for sale) outside that house.