## Facts

- U.S. Postal Service inspectors intercepted an Express Mail package that contained cocaine.
- The package was addressed to “Karen White” at a Washington, D.C. address, and inspectors believed the name was fictitious.
- Inspectors arranged a controlled delivery as part of a federal investigation.
- A postal inspector, posing as a mail carrier, delivered the package to the address listed on the label.
- Marlin Moore answered the door and signed the delivery form using the name “Kevin Jones.”
- Moore also told the undercover inspector that “Karen White” was his girlfriend.
- After Moore took possession of the package and later left the premises with it, officers arrested him and recovered the cocaine.
- Moore was charged with multiple offenses, including making a false statement in violation of 18 U.S.C. § 1001 based on falsely identifying himself to the postal inspector.
- A jury convicted Moore, and he appealed, arguing that his false name was not material and challenging the sufficiency of the proof of the required mental state.

## Issues

1. Whether Moore’s false identification (and related statement about the addressee) was “material” under 18 U.S.C. § 1001, even though the inspector did not ask for Moore’s name and the delivery would have proceeded anyway.
2. Whether the false statement was made in a matter within federal jurisdiction when it was made to a postal inspector conducting a controlled delivery.
3. Whether the evidence was sufficient for a rational jury to find Moore acted “knowingly and willfully” as required by § 1001.

## Decision

- The D.C. Circuit affirmed Moore’s conviction under 18 U.S.C. § 1001.
- The court held that Moore’s use of a false name (and his statement linking himself to the named addressee) was material because it was capable of influencing the government’s investigation of the drug package.
- The court held the statement was made in a matter within federal jurisdiction because it was made to a federal postal inspector acting in an official investigative capacity.
- The court held the evidence permitted the jury to find Moore acted knowingly and willfully in making the false statement.

## Legal Principles

- A false statement is material under § 1001 if it has “a natural tendency to influence, or [is] capable of influencing,” the decision or functioning of the governmental body involved; actual influence need not be shown.
- Materiality is assessed objectively; the government is not required to prove the agent relied on the statement or that the investigation changed course.
- In a controlled delivery tied to a narcotics investigation, the recipient’s identity and claimed connection to the addressee can be capable of influencing investigative steps, attribution of responsibility, and follow-up leads.
- The “within the jurisdiction” element is satisfied when the statement is made to a federal officer carrying out an authorized federal investigation.
- Section 1001 requires proof the defendant acted knowingly and willfully; on these facts, the jury could infer willfulness from the deliberate choice to provide a false name while taking possession of a cocaine shipment during a law-enforcement delivery.

## Conclusion

United States v. Moore held that a defendant’s false signature and related statements to a postal inspector during a controlled delivery of a cocaine package could satisfy § 1001’s materiality and federal-jurisdiction elements, and that the trial evidence allowed a jury to find the defendant acted knowingly and willfully; the D.C. Circuit therefore affirmed the § 1001 conviction.


United States v. Moore, 612 F.3d 698 (2010)