How have courts interpreted the meaning of the phrase "possession of a firearm" in the context of relief?

[noting interpretive canon that "'the expression of certain things in a statute necessarily involves exclusion of other things not expressed'"], superseded by statute on another ground.) This argument, too, has been rejected: "But of course, the mere possession of the firearm, without arming, is not a disqualifying crime. And in this case, the trial court determined defendant did not merely 'possess' the firearm, he was armed with it. He was disqualified from relief based upon his arming, not his mere possession." (People v. White, supra, 243 Cal.App.4th at p. 1364.)