Presumably without an attorney (for the purposes of the Court's argument),[1] George Calvin Lewis Jr. plead guilty in Florida to the felony of breaking and entering with intent to commit a misdemeanor in 1961.

Although Gideon v. Wainwright was decided two years later, at no point did Lewis make an effort to challenge his conviction on appeal.

During his bench trial, he argued that the allegedly unconstitutional 1961 conviction should not hold weight as inculpatory evidence for the firearm charge.

The trial court considered this objection irrelevant as Lewis provided no direct evidence that he was tried without counsel.

Analyzing the Congressional Record, the Court concluded that the Omnibus Crime Control Act worked to broadly keep firearms out of the hands of people who demonstrated that "they may not be trusted to possess a firearm without becoming a threat to society".