In the case of Lewis v. United States in 1954, the Supreme Court ruled that a federal grand jury does not have to mirror the racial makeup of its district. The petitioner, an African American man named Joseph Lewis Jr., was indicted and convicted for murder on a government reservation by an all-white grand jury from southern Florida. He appealed his conviction arguing that African Americans were systematically excluded from serving on juries in this area which violated his rights under the Fourteenth Amendment's Equal Protection Clause. However, Justice Hugo Black delivered the unanimous opinion stating that while systematic exclusion based on race is unconstitutional when selecting trial juries (as per previous cases), it did not apply to grand juries because they only decide whether there is enough evidence for a trial and do not determine guilt or innocence.

In the dissenting opinion for Lewis v. United States, Justice Hugo Black argued that the majority's decision was a departure from established Fourth Amendment principles. He contended that allowing federal officers to enter and search a private home without a warrant based on an informant's tip violated constitutional protections against unreasonable searches and seizures. According to Justice Black, this ruling effectively gave law enforcement officials unchecked power to invade privacy rights at their discretion, which he believed was contrary to the intent of the Founding Fathers when they drafted the Fourth Amendment. Furthermore, he expressed concern about potential abuses of this power by authorities who might use it as a pretext for conducting arbitrary or discriminatory searches.