Defendant was found guilty of knowingly making a false oral or written statement on a fact material to a transaction for including false information on firearms transaction records in connection with her purchase of five separate guns. Defendant challenged her conviction, arguing that the prohibition against knowingly falsifying documents when buying a firearm contained in 18 U.S.C. § 922(a)(6) conflicted with the Second Amendment. The Seventh Circuit affirmed, explaining that an in-depth analysis of the Second Amendment was not required because § 922(a)(6) restricts fraudulent statements, not firearm purchases and that the Second Amendment does not immunize purchasers from knowingly providing misstatements on firearm transaction records. (BRENNAN and LEE, concurring)
Federal 7th Circuit Court
Criminal Court
Second Amendment