In the 1992 case of Thomas Lee Deal v. United States, the Supreme Court ruled in favor of the government, upholding a sentence enhancement under federal law for possession of a firearm by a convicted felon. The defendant, Thomas Lee Deal, had been sentenced to fifteen years without parole after being found guilty on three counts related to illegal firearms possession and transfer. On appeal, he argued that his sentence was unfairly enhanced due to prior convictions which were unrelated to firearms offenses. However, the court held that Congress intended for such enhancements under the Armed Career Criminal Act (ACCA), regardless of whether previous crimes involved guns or not. This decision reaffirmed congressional authority over sentencing guidelines and clarified how past criminal history could be used in determining sentences.

In the dissenting opinion for Thomas Lee Deal v. United States, Justice Stevens argued that the majority's interpretation of 18 U.S.C §924(c) was overly broad and inconsistent with Congress' intent. He believed that the statute should only apply to crimes involving firearms in a way directly related to their destructive capacity or potential use as weapons, not simply because they were present during a crime. The defendant had been convicted under this law for trading an unloaded firearm for drugs - an act which Stevens did not believe constituted "use" of a firearm in relation to drug trafficking, as defined by the statute. Furthermore, he expressed concern over the harsh mandatory sentence imposed on Deal due to his prior convictions under this same broadly-interpreted law; each subsequent conviction carried increasingly severe penalties regardless of whether any violence occurred or was even threatened.