United States v. Echo Scheidt, 103 F.4th 1281

Echo Scheidt bought five handguns from licensed dealers in Indiana, completing ATF Form 4473 for each transaction.
Scheidt knowingly provided false addresses on all five forms, listing places she did not live.
She resold the guns, and two were later used in shootings, including a murder.
After police traced the guns back to her, Scheidt admitted to lying on the forms and in an initial police interview.
A federal grand jury indicted her for making false statements to gun dealers (18 U.S.C. § 922(a)(6)) and to government agents (18 U.S.C. § 1001(a)).
The district court denied her motion to dismiss the charges based on a Second Amendment challenge; she pleaded guilty and appealed.

Issue	Scheidt's Argument	Government's Argument	Held
Does 18 U.S.C. § 922(a)(6) violate the Second Amendment by requiring truthful statements on ATF Form 4473 in firearm purchases?	Statute burdens Second Amendment rights by conditioning gun purchases on compliance with registration/ information requirements; Bruen requires historical analysis.	Truth-in-information requirements do not implicate Second Amendment rights; Section 922(a)(6) only penalizes falsehoods, not the purchase itself.	Court held § 922(a)(6) does not implicate Second Amendment rights and Bruen does not require historical analysis for such false statement statutes.

New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022) (establishing test for Second Amendment challenges, focusing on text and history)
Huddleston v. United States, 415 U.S. 814 (1974) (ATF Form 4473 provides truthful information to assist law enforcement)
United States v. Knox, 396 U.S. 77 (1969) (false statements to government not immunized by challenging requirement's validity)
United States v. Holden, 70 F.4th 1015 (7th Cir. 2023) (distinguishing between information-gathering and substantive firearm restrictions)
Class v. United States, 583 U.S. 174 (2018) (constitutional challenges survive an unconditional guilty plea)
Grzegorczyk v. United States, 997 F.3d 743 (7th Cir. 2021) (unconditional guilty plea waives statutory arguments)