United States v. Pierotti
United States Court of Appeals for the Seventh Circuit
777 F.3d 917 (2015)
David Pierotti (defendant) pleaded guilty to misdemeanor domestic battery, and after his probation ended, went to buy a hunting rifle. On the required federal purchase form, he initially answered "yes" to whether he'd been convicted of a misdemeanor crime of domestic violence, but after a pop-up prompted him to review his answers, he changed that one answer to "no" and resubmitted, without clicking a linked instruction button that would have clarified his conviction qualified. He claimed his probation officer and a sheriff friend had told him he could buy a gun if his conviction wasn't a felony. Pierotti was indicted for knowingly making a false statement on the form, the jury received both a standard "knowingly" instruction and a willful-blindness ("ostrich") instruction, and he was convicted and appealed the giving of that instruction.
Whether acting "knowingly" includes willful blindness or deliberately avoiding the truth.