Michael Bryant Jr. (defendant) was convicted in federal court of violating 18 U.S.C. § 117(a), which made it a federal crime to commit domestic assault in Indian country, if the defendant had at least two prior convictions for domestic violence in any court, including Indian tribal courts. Bryant had several previous domestic-violence convictions in tribal court for which he had been sentenced to incarceration for under one year. Bryant contended that these convictions should not qualify as prior convictions under 18 U.S.C. § 117(a) because he was indigent but not represented by counsel. For crimes charged in state or federal court, indigent defendants were entitled to an attorney if they faced the possibility of jail time. However, for crimes charged in tribal court, the right to appointed counsel attached only if the defendant was facing a potential sentence of more than one year of imprisonment.