In Lewis v. United States, 445 U.S. 55 (1980), the United States Supreme Court addressed "the question whether a defendant's extant prior conviction, flawed because he was without counsel, . . . may constitute the predicate for a subsequent conviction under the former federal firearms statute, 18 U.S.C. app. 1202(a)(1)" (1976). Based primarily on the statute's clear language and "plain meaning," the Court concluded that "the fact of a felony conviction imposes a firearm disability until the conviction is vacated or the felon is relieved of his disability by some affirmative action." 445 U.S. at 60-61. The Court "viewed the language Congress chose as consistent with the common-sense notion that a disability based upon one's status as a convicted felon should cease only when the conviction upon which that status depends has been vacated." Id. at 61. The Court in Lewis noted that the federal firearms statute contained "no exception . . . for a person whose outstanding felony conviction ultimately might turn out to be invalid for any reason." Id. at 62. Accordingly, the Court held that the statute "prohibits a felon from possessing a firearm despite the fact that the predicate felony may be subject to collateral attack on constitutional grounds." Id. at 65. In so holding, the Court distinguished three prior cases in which it had disallowed use of constitutionally invalid convictions "to impeach the general credibility of the defendant," to "sentence a defendant after a subsequent conviction," and to enhance "punishment under a State's recidivist statute." Id. at 59-60. The United States Supreme Court ruled that the constitutional invalidity of an accused's underlying felony conviction was no defense to a conviction under federal law for being a felon unlawfully possessing a firearm. In that case, shortly before trial on the possession charge, the trial court learned the defendant had not been represented by counsel on the underlying conviction some 16 years earlier. The defendant claimed that under the rule of Gideon v. Wainwright (1963) 372 U.S. 335 9 L.Ed.2d 799, 83 S. Ct. 792, a violation of the federal possession statute could not be predicated on an earlier conviction obtained in violation of his constitutional rights. (Lewis, supra, 445 U.S. at pp. 57-58.) The Supreme Court disagreed. Justice Blackmun wrote the opinion for a six-member majority. Relying on the possession law's language, the court found the law applied upon the fact of conviction, even if that conviction was later found to be invalid. The law proscribed possession of a firearm by any person "convicted" of a felony. Nothing indicated any restriction on the term "convicted," or any intent to limit the law's coverage to persons whose felony convictions are not subject to collateral attack. The statute's plain meaning "is that the fact of a felony conviction imposes a firearm disability until the conviction is vacated or the felon is relieved of his disability by some affirmative action, such as a qualifying pardon or a consent from the Secretary of the Treasury." (Lewis, supra, 445 U.S. at pp. 59-61.) The high court also determined the law's legislative history and purpose supported this interpretation. The law's authoring senator repeatedly stressed conviction as the sole criterion, not a "valid" conviction or a conviction not subject to constitutional challenge. (Lewis, supra, 445 U.S. at pp. 62-63.) The law also was adopted in response to the political and social violence of the 1960's. " 'Congress sought to rule broadly--to keep guns out of the hands of those who have demonstrated that "they may not be trusted to possess a firearm without becoming a threat to society." ' " (Id. at p. 63.) In the face of such clear language, strong legislative history, and broad purpose, the court ruled the unambiguous law prohibited a felon from possessing a firearm despite the fact the predicate conviction may be subject to collateral attack on constitutional grounds. (Lewis, supra, 445 U.S. at p. 65.)