11th Cir. Pattern Jury Instr. (Criminal) O34.3

18 U.S.C. § 922(a)(6)

It’s a Federal crime to make a false statement to a licensed firearms dealer

while buying a firearm.

The Defendant can be found guilty of this crime only if all the following

facts are proved beyond a reasonable doubt:

(1) the Defendant bought or tried to buy a firearm from a federally

licensed firearms dealer;

(2) the Defendant [knowingly made a false or fictitious statement,

orally or in writing] [knowingly furnished false identification] that

was [intended to deceive] [likely to deceive] the dealer; and

(3) the subject matter of the false [statement] [identification] was

material to the lawfulness of the sale.

A “firearm” is any weapon designed to or readily convertible to expel a

projectile by the action of an explosive. The term includes the frame or receiver of

any such weapon or any firearm muffler or silencer.

A [statement] [identification] is “false” if it is untrue when [made] [used]

and the person [making] [using] it knows it is untrue.

A false [statement] [identification] is “likely to deceive” if under the

circumstances a reasonable person of ordinary prudence would probably be deceived.

Whether the allegedly false [statement] [identification] is “material” is a

question of law for the court to decide. If you find the [statement] [identification]

in this case is false, then it was material to the sale.