The following excerpt is from U.S. v. Scholl, 166 F.3d 964 (9th Cir. 1999):
Scholl contends that he was prejudiced by two improper jury instructions: (1) the materiality instruction that he argues improperly took the issue from the jury; and (2) the instruction on recordkeeping that he asserts created a strict liability guilt assumption in violation of Sandstrom v. Montana, 442 U.S. 510, 99 S.Ct. 2450, 61 L.Ed.2d 39 (1979).
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